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Neustar Analysis Shows ICANN Study Overstates Risk of Harmful Domain-Name Collision

Jeff Neuman

A Methodology for Assessing Collision Risk and New gTLDs
by Neustar (click to download)
As we blogged about recently, Neustar is committed to ensuring that the domain name system is secure and stable and has been operating top-level domains (TLDs) for over a decade.

Tuesday, Neustar submitted comments to the Internet Corporation for Assigned Names and Numbers (ICANN) in response to ICANN's proposal to delay the launch of hundreds of new generic top-level domains (gTLDs). ICANN's decision to delay the launch is based on a study it commissioned that measured the potential frequency of domain-name collision, or confusion with queries for existing domain names. The study designated two TLDs as being at "high risk" for collision, about 1,000 TLDs as "low risk" and another 150 TLDs as "uncalculated risk."

Neustar analyzed the same data used in the ICANN-commissioned study and found that ICANN's classification of 20 percent of the applied-for domains as having "uncalculated risk" is arbitrary and unwarranted. Neustar's analysis shows that the potential risk can, in fact, be calculated, and mitigated, and proposes a means for doing so.

ICANN's Flawed Analysis

Neustar believes ICANN's mitigation strategy is flawed because it rests entirely on the possibility of collision, not the consequences. ICANN's resulting plan would relegate many demonstrably low-risk gTLDs to the nether world of "uncalculated risk" and impose further unwarranted delay in the launch of those gTLDs. While Neustar agrees that caution is always called for in a system upgrade of this magnitude, ICANN's approach goes beyond simple prudence and unnecessarily slows down the process of rolling out the gTLDs, which enterprises have been working on for years. ICANN's "uncalculated risk" category throws too many clearly low-risk gTLDs into a nightmare of uncertainty, and needs to be fixed.

Neustar's Analysis

Neustar's findings show that the potential risk of every TLD can be quantified by examining four factors that contribute to a risk of harm. Those elements include: (i) TLD query volume; (ii) how many IP addresses those queries came from; (iii) queried second-level domain volume; and (iv) volume of digital certificates issued for those top-level domains.

Using this methodology, Neustar found that only three TLDs — .home, .corp and .mail — had considerably higher collision risk than other proposed strings. Those included in the "uncalculated risk" category have risk factors of less than 1 percent and should be classified as "low risk." The data and research necessary to calculate the potential risk of collision and to mitigate the consequences already exist. Therefore, there is no justifiable reason for ICANN to continue to delay for further study.

Neustar's Mitigation Approach

As a leading provider of information analytics, Neustar is an expert at assessing risk. We help the largest retailers, e-commerce providers, financial institutions and government agencies identify, assess and mitigate risk every day.

In response to ICANN's proposals to mitigate risks in a manner that slows growth unnecessarily, Neustar proposes several alternative methods that more appropriately address the reality of the risks.

  • ICANN proposed to evaluate domain-names with 'incalculable risks' for 120 days after a contract is signed; Neustar proposes that a better way to mitigate risk is to evaluate the domain-names now. Waiting for the contract to be signed unnecessarily slows the growth of business, and ICANN has the data and research to evaluate and mitigate the risks now.
  • Apply the domain name (SLD) activation restriction to only those names that account for 80 percent of NXD query volume.
  • Exclude second-level registrations that allow registry operators to operate and promote its TLD from the 30-day hold.
  • Remove the email notification requirement and replace it with a mandatory notification mechanism, such as a website, with information and instructions.

Importance of this Issue

Access to Internet domains is critical to the future of businesses, major cities and non-profit organizations. A city like New York can use .NYC to increase tourism and build a sense of community. Nonprofits like dotHIV and the National Association of Boards of Pharmacy can use new domains to continue to extend their reach and advance their causes. All of these entities have invested in new TLDs and look forward to participating in the next wave of online innovation. However, ICANN's current proposal will delay the launch of hundreds of new generic top-level domains, stifling the growth of key players like these in our economy and communities.

Read Neustar's full analysis and take a look at an infographic explaining its proposed methodology.

By Jeff Neuman, Senior Vice President, Com Laude USA / Valideus USA – He has been instrumental in providing policy assistance and advice in the fields of internet governance, intellectual property protection and domain name policy since the mid-1990s. Jeff has served in key business, policy and legal roles in the domain name industry more than 20 years. The views expressed herein reflect my own beliefs and may not be consistent with the views of Com Laude and/or Valideus. Visit Page
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