The Association of National Advertisers (ANA) has just weighted in on the Name Collision issue in a in a letter sent to ICANN.
The title of the letter is “ICANN is Falling Short of its Mission to Protect Internet Security and Stability”
It should be noted that the ANA has not been the greatest fan of the new gTLD program in general.
“The Interisle Consulting Group clearly stated in the “Name Collision in the DNS Report” (the “Study”) that nearly all proposed new gTLDs carry some risk of name clash and potential service interruptions. While we appreciate the candid admissions within the Study, the Study itself is woefully inadequate to gauge the level of risk associated with deploying new gTLDs. The Study’s author readily admits that the underlying data only counted the number of potential name clashes.
As a result, ICANN, as far as we are aware, has virtually no data to determine if it could interrupt important public safety communications, government web traffic, e-commerce applications, internal corporate communications or just casual web traffic by delegating new gTLDs.”
This is unacceptable.”
“ICANN plans to rank new gTLDs into three risk profiles: low risk and delegable (80% of the strings); uncalculated risk (20% of the strings); and high risk (2 strings). “
“Unfortunately, ICANN appears to be ready to make this determination without sufficiently knowing what service interruptions could result once delegation occurs. “
“ICANN must know what underlying services could potentially “break” on the Internet to begin to gauge risk. As stated by the Study’s author:
The risk associated with delegating a new TLD label arises from the potentially harmful consequences of name collision, not the name collision itself. This study was concerned primarily with the measurement and analysis of the potential for name collision at the DNS root. An additional qualitative analysis of the harms that might ensue from those collisions would be necessary to definitively establish the risk of delegating any particular string as a new TLD label, and in some cases the consequential harm might be apparent only after a new TLD label had been delegated. See the Study, pages 2-3 (emphasis added).
“Our member companies are working diligently to determine if DNS Clash issues are present within their respective networks. However the ANA had to communicate these issues to hundreds of companies, after which these companies must generate new data to determine the potential service failures on their respective networks.
“The fact that our member companies are now forced to rush to conduct this analysis is all the more disappointing when it is realized that ICANN has been aware of the DNS clash issues since at least 2009 during the OARC Workshop in Beijing
ICANN, in 2009, could have conducted additional research to ascertain the breadth of the problem, and reached out to companies and better publicized the risk. ICANN’s failure to do so means that many companies are learning about these DNS clash issues for the first time now on the eve of new gTLD deployment.
On August 9th, the ANA wrote ICANN seeking an extension of the period for public comments on ICANN’s Proposal to Mitigate Name Collision Risks. We renew this request to extend the public comment period to November 1st for initial comments and November 22nd for reply comments (a copy of our letter is appended).
ANA, and its member companies, are of course standing by ready and willing to work with ICANN, but we need time to produce the necessary data. Without the data on potential service interruptions, ICANN’s proposed risk categories are unfortunately simply an insufficiently researched estimate of potential risks and harm. ICANN’s primary mission under the Affirmation of Commitments is to maintain Internet security and stability in the public interest. Such a responsibility demands far more than a weakly researched estimate.
Without this data, we believe it would be highly risky and imprudent to go forward with a general rollout of new gTLDs.