One of ICANN’s proposed methods of reducing the risk of name collisions in new gTLDs actually may create its own “significant risk for abuse”, according to RIPE NCC.
Asking registry operators to send a notification to the owner of IP address blocks that have done look-ups of their TLD before it is delegated risks creating a “backlash” against ICANN and registry operators, RIPE said.
Earlier this month, ICANN said that for the 80% of applied-for strings that are categorized as low risk, “the registry operator will notify the point of contacts of the IP addresses that issue DNS requests for an un-delegated TLD or names under it.”
The proposal is intended to reduce the risk of harms caused by the collision of new gTLDs and matching names that are already in use on internal networks.
For example, if the company given .web discovers that .web already receives queries from 100 different IP blocks, it will have to look up the owners of those blocks with the Regional Internet Registries and send them each an email telling them than .web is about to hit the internet.
RIPE is the RIR for Europe, responsible for allocating IP addresses in the region, so its view on how effective a mitigation plan this is cannot be easily shrugged off.
Chief scientist Daniel Karrenberg told ICANN today that the complexity of the DNS, with its layers of recursive name servers and such, makes the approach pointless:
The notifications will not be effective because they will typically not reach the party that is potentially at risk.
In addition, it will be trivial for mischief-makers to create floods of useless notifications by conducting deliberately erroneous DNS queries for target TLDs, he said:
anyone can cause the registry operator to send an arbitrary amount of mandatory notifications to any holder of IP address space. It will be highly impractical to detect such attacks or find their source by technical means. On the other hand there are quite a number of motivations for such an attack directed at the recipient or the sender of the notifications. The backlash towards the registry operator, ICANN and other parties in the chain will be even more severe once the volume increases and when it turns out that the notifications are for “non-existing” queries.
With a suitably large botnet, it’s easy to see how an attacker could generate the need for many thousands of mandatory notifications.
If the registry has a manual notification process, such a flood would effectively DDoS the registry’s ability to send the notices, potentially delaying the gTLD.
Even if the process were to be automated, you can imagine how IP address block owners (network admins at ISPs and hosting companies, for example) would respond to receiving notifications, each of which creates work, from hundred of affected gTLD operators.
It’s an interesting view, and one that affected new gTLD applicants (which is most of them) will no doubt point to in their own comments on the name collisions mitigation plan.