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(*) Comments submitted after the posted Close Date/Time are not guaranteed to be considered in any final summary, analysis, reporting, or decision-making that takes place once this period lapses.

FINAL VERSION TO BE SUBMITTED IF RATIFIED

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FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

The ALAC welcomes the completion and publication of the "Name Collisions in the DNS" study report by Interisle Consulting Group and the subsequent response by ICANN in “New gTLD Collision Risk Mitigation Proposal".  The ALAC advises that it is in general concurrence with the proposed risk mitigation actions for the three defined risk categories.  In doing so, the ALAC recognises that the study, its conclusions, and ICANN's risk mitigation recommendations are based on analysis of a limited data set of query volume metrics ie how many times queries occur for a proposed new gTLD. As acknowledged in the study, such metrics are only one perspective of risk and do not reflect other risk that may arise through complex interactions between the DNS and applications at the root level.  In particular, the ALAC wishes to reiterate its previous Advice to the Board that, in pursuing mitigation actions to minimize residual risk, especially for those strings in the “uncalculated risk” category, ICANN must assure that such residual risk is not transferred to third parties such as current registry operators, new gTLD applicants, registrants, consumers and individual end users.  In particular, the direct and indirect costs associated with proposed mitigation actions should not have to be borne by registrants, consumers and individual end users.  The Board must err on the side of caution and ensuring that the DNS under ICANN's auspices remains highly trusted.

On a more general note, the ALAC remains concerned that this matter is being dealt with at such a late stage of the New gTLD Process.  The ALAC urges the Board to investigate how and why this crucial issue could have been ignored for so long and how similar occurrences may be prevented in the future.

FIRST DRAFT SUBMITTED

The ALAC welcomes the completion and publication of the "Name Collisions in the DNS" study report by Interisle Consulting Group and the subsequent response by ICANN in “New gTLD Collision Risk Mitigation Proposal".  The ALAC advises that it is in general concurrence with the proposed risk mitigation actions for the three defined risk categories.  In particular, the ALAC wishes to reiterate its previous Advice to the Board that, in pursuing mitigation actions to minimize residual risk, especially for those strings in the “uncalculated risk” category, ICANN must assure that such residual risk is not transferred to third parties such as current registry operators, new gTLD applicants, registrants, consumers and individual end users.  In particular, the direct and indirect costs associated with proposed mitigation actions should not have to be borne by registrants, consumers and individual end users.  The Board must err on the side of caution and ensuring that the DNS under ICANN's auspices remains highly trusted.

On a more general note, the ALAC remains concerned that this matter is being dealt with at such a late stage of the New gTLD Process.  The ALAC urges the Board to investigate how and why this crucial issue could have been ignored for so long and how similar occurrences may be prevented in the future.