Reported mass exodus from .com explained

Did Verisign suffer from a massive 2,600% increase in the number of deleted .com domain names this April?
Not quite, although the bizarre spike in deletes may have highlighted an area where the company was previously out of compliance with its ICANN Registry Agreements.
April’s .com registry report, filed with ICANN and published last week, shows 2.4 million domains were deleted, compared to just 108,000 in March and 90,000 in April 2013.

The spike looks surprising, and you may be tempted to think it is in some way related to the arrival of new gTLDs.
But look again. Could .com, a registry with over 116 million domains under management, really only see roughly 100,000 deletes every month? Clearly that number is far too low.
So what’s going on? I asked Verisign.
The company said that it has implemented “voluntary” changes to its reporting of deleted domains, based on the standard new gTLD Registry Agreement, which specifies what must be reported by new gTLD registries.
It said:

Prior to the April 2014 monthly reports, and per the ICANN gTLD registry reporting guidelines, Verisign reported on only deleted domains outside of any grace period.

There are five “grace periods” permitted by ICANN contracts: the Add Grace Period, Renew/Extend Grace Period, Auto-Renew Grace Period, Transfer Grace Period, and Redemption Grace Period.
The familiar Add Grace Period allows registrars to cancel registrations within a week of registration if the registrant made a typo, for example, and asked for a refund.
The Redemption Grace Period covers domains that have expired and do not resolve, but can still be restored for 30 days at the request of the registrant.
According to Verisign, before April, domains that were deleted outside of any of the five grace periods were reported as “deleted-domains-nograce”.
From April, the company is reporting domains only as “deleted-domains-nograce” if they delete outside of the Add Grace Period.
According to my reading of the .com contract, that’s what Verisign should have been doing all along.
The contract, which Verisign and ICANN signed in late 2012, defines “deleted-domains-nograce” only as “domains deleted outside the add grace period”. There’s no mention of other grace periods.
The same definition can be found in the 2006 contract.
It appears to me that Verisign may have been under-reporting its deletes for quite some time.
Verisign said in response that it does not believe it has a compliance issue. A spokesperson said: “[We] voluntarily updated our reporting of deleting domain names so that our reporting is aligned with ICANN’s reporting clarifications for the new gTLDs.”

Verisign: 41% of new gTLD sites are parked

As much as 41% of domains registered in new gTLDs are parked with pay-per-click advertising, according to research carried out by Verisign.
That works out to over 540,000 domains, judging by the 1.3 million total I have on record from June 29, the day Verisign carried out the survey.
Domains classified as carrying “business” web sites — defined as “a website that shows commercial activity” — accounted for just 3% of the total, according to Verisign.
There are some big caveats, of course, not least of which is .xyz, which tends to skew any surveys based on “registered” names appearing in the zone file. Verisign noted:

XYZ.COM LLC (.xyz) has a high concentration of PPC websites as a result of a campaign that reportedly automatically registered XYZ domains to domain registrants in other TLDs unless they opted out of receiving the free domain name. After registration, these free names forward to a PPC site unless reconfigured by the end user registrant.

On June 29, .xyz had 225,159 domains in its zone file. I estimate somewhat over 200,000 of those names were most likely freebies and most likely parked.
The practice of registry parking, carried out most aggressively by Uniregistry and its affiliate North Sound, also threw off Verisign’s numbers.
Whereas most new gTLD registries reserve their premium names without adding them to the zone files, Uniregistry registers them via North Sound to park and promote them.
Tens of thousands of names have been registered in this way.
Coupled with the .xyz effect, this leads me to conclude that the number of domains registered by real registrants and parked with PPC is probably close to half of Verisign’s number.
That’s still one out of every five domains in new gTLDs, however.
Judging by a chart on Verisign’s blog, .photography appears to have the highest percentage of “business” use among the top 10 new gTLDs so far.
Verisign also found that 10% of the names it scanned redirect to a different domain. It classified these as redirects, rather than according to the content of their final destination.

ICANN says Verisign should stay in charge of root zone

Verisign should stay in its key role in root zone management after the IANA transition process is complete, according to ICANN CEO Fadi Chehade.
The company currently acts as “maintainer”, alongside the US government as “administrator” and ICANN/IANA as “operator”.
This means Verisign is responsible for actually making changes — adding, deleting or amending the records for TLDs — in the root zone file.
In a blog post yesterday, Chehade said that ICANN will “establish a relationship directly with the third-party Maintainer”, adding:

As a means to help ensure stability, ICANN’s recommended implementation option is to have Verisign continue its role as the Maintainer. However, we will be working closely with all relevant parties including the Root Zone Operators to ensure there are contingency options in place to meet our absolute commitment to the stability, security and resiliency of the Domain Name System.

I wholeheartedly agree that Verisign should stay in its role, or at the very least that ICANN should not take over.
As we’ve learned over the last couple of years of software glitches in the new gTLD program, some of them security-related, ICANN would be a poor choice today to maintain this critical resource.
Chehade noted that the US National Telecommunications and Information Administration would be replaced in its “administrator” role by whatever mechanism the ICANN community comes up with during the transition process.

Verisign stock punished after US move from root control

Verisign’s share price is down around 8% in early trading today, after analysts speculated that the US government’s planned move away from control of the DNS root put .com at risk.
The analyst firm Cowan & Co cut its rating on VRSN and reportedly told investors:

With less US control and without knowledge of what entity or entities will ultimately have power, we believe there is increased risk that VRSN may not be able to renew its .com and .net contracts in their current form.

It’s complete nonsense, of course.
The US announced on Friday it’s intention to step away from the trilateral agreements that govern control of the root between itself, ICANN and Verisign. But that deal has no dollar value to anyone.
What’s not affected, as ICANN CEO Fadi Chehade laboriously explained during his press conference Friday, are the contracts under which Verisign operates .com and .net.
The .com contract, through which Verisign derives most of its revenue, is slightly different to regular gTLD contracts in that the US has the right to veto terms if they’re considered anti-competitive.
The current contract, which runs through 2018, was originally going to retain Verisign’s right to increase its prices in most years, but it was vetoed by the US, freezing Verisign’s registry fee.
So not only has the US not said it will step away from .com oversight, but if it did it would be excellent news for Verisign, which would only have to strong-arm ICANN into letting it raise prices again.
Renewal of the .com and .net contracts shouldn’t be an issue either. The main rationale for putting .com up for rebid was to improve competition, but the new gTLD program is supposed to be doing that.
If new gTLDs, as a whole, are considered successful, I can’t see Verisign ever losing .com.
Verisign issued a statement before the markets opened today, saying:

The announcement by NTIA on Friday, March 14, 2014, does not affect Verisign’s operation of the .com and .net registries. The announcement does not impact Verisign’s .com or .net domain name business nor impact its .com or .net revenue or those agreements, which have presumptive rights of renewal.

ICANN reveals gTLD objections appeals process

Two new gTLD applicants would get the opportunity to formally appeal String Confusion Objection decisions that went against them, under plans laid out by ICANN today.
DERCars and United TLD (Rightside), which lost SCOs for their .cars and .cam applications respectively, would be the only parties able to appeal “inconsistent” objection rulings.
DERCars was told that its .cars was too similar to Google’s .car, forcing the two bids into a contention set. But Google lost similar SCO cases against two other .cars applicants.
Likewise, Rightside’s .cam application was killed off by a Verisign SCO that stated .cam and .com were too similar, despite two other .cam applicants prevailing in virtually identical cases.
Now ICANN plans to give both losing applicants the right to appeal these decisions to a three-person panel of “Last Resort” operated by the International Centre for Dispute Resolution.
ICDR was the body overseeing the original SCO process too.
Notably, ICANN’s new plan would not give Verisign and Google the right to appeal the two .cars/.cam cases they lost.

Only the applicant for the application that was objected to in the underlying SCO and lost (“Losing Applicant”) would have the option of whether to have the Expert Determination from that SCO reviewed.

There seems to be a presumption by ICANN already that what you might call the “minority” decision — ie, the one decision that disagreed with the other two — was the inconsistent one.
I wonder if that’s fair on Verisign.
Verisign lost two .cam SCO cases but won one, and only the one it won is open for appeal. But the two cases it lost were both decided by the same ICDR panelist, Murray Lorne Smith, on the same grounds. The decisions on .cam were really more 50-50 than they look.
According to the ICANN plan, there are two ways an appeal could go: the panel could decide that the original ruling should be reversed, or not. The standard of the review is:

Could the Expert Panel have reasonably come to the decision reached on the underlying SCO through an appropriate application of the standard of review as set forth in the Applicant Guidebook and procedural rules?

The appeals panelists would basically be asked to decide whether the original panelists are competent or not.
If the rulings were not reversed, the inconsistency would remain in place, making the contention sets for .car, .cars and .cam stay rather confusing.
ICANN said it would pay the appeals panel’s costs.
The plan (pdf) is now open for public comment.

MarkMonitor infiltrated by Syrian hackers targeting Facebook

The corporate brand protection registrar MarkMonitor was reportedly hacked yesterday by the group calling itself the Syrian Electronic Army, in an unsuccessful attempt to take out Facebook.
While MarkMonitor refused to confirm or deny the claims, the SEA, which has been conducting a campaign against high-profile western web sites for the last couple of years, tweeted several revealing screenshots.
One was a screen capture of a DomainTools Whois lookup for facebook.com, which does not appear to have been cached by DomainTools.

Happy Birthday Mark! http://t.co/yWBwvXPGRZ owned by #SEA http://t.co/gk8nGxATLt pic.twitter.com/eAeGp1TvBF

— SyrianElectronicArmy (@Official_SEA16) February 5, 2014

Another purported to be a cap of Facebook’s control panel at the registrar.

MarkMonitor Administration Panel. #SEA pic.twitter.com/7zDbUxHbYJ

— SyrianElectronicArmy (@Official_SEA16) February 6, 2014

The SEA tweeted more caps purporting to show it had access to domains belonging to Amazon and Yahoo!.
In response to an inquiry, MarkMonitor rather amusingly told DI “we do not comment on our clients — including neither confirming nor denying whether or not a company is a client.”
This despite the fact that the company publishes a searchable database of its clients on its web site.
The attackers were unable to take down Facebook itself because the company has rather wisely chosen to set its domain to use Verisign’s Registry Lock anti-hijacking service.
Registry Lock prevents domains’ DNS settings being changed automatically via registrar control panels. Instead, registrants need to provide a security pass phrase over the phone.

It’s official: Verisign has balls of steel

Verisign has spent the last six months telling anyone who will listen that new gTLDs will kill Japanese people and cause electricity grids to fail, so you’d expect the company to be a little coy about its own activities that (applying Verisign logic) endanger life and the global economy.
But apparently not.
Verisign today decided to use the same blog it has been using to play up the risks indicated by NXDOMAIN traffic in new gTLDs to plug its own service that actively encourages people to register error-traffic domains.
The company has launched DomainScope, which combines several older “domain discovery” tools — DomainFinder, DomainScore and DomainCountdown — under one roof.
According to an unsigned corporate blog post, with my emphasis:

DomainScope enables users to discover domain name registration opportunities through learning about the recent history of a domain name, understanding a domain name’s DNS traffic patterns, and knowing which domains are available that are receiving traffic.

That’s right, Verisign is giving malicious hackers the ability, for free, to find out which .com, .net and .tv domains currently receive NXDOMAIN traffic, so that the hackers can pay Verisign to register them and cause mayhem.
I used the service today see what mischief might be possible, and hit paydirt on my first query.
Typing in “mail” as the search query, ordering the results by “Traffic Score” — a 1 to 10 measure of how much error traffic a domain already gets — I got these results:

You’ll notice (click to enlarge if you don’t) that the third result, with a 9.9 out of 10 score, is netsoolmail.net.
That caught my attention for obvious reasons, and a little Googling seems to confirm that it’s a typo of netsolmail.net, a domain Network Solutions uses for its mail servers (or possibly a spam filter).
Network Solutions is of course a top-ten registrar with millions of mostly high-end customers.
So what?
Well, if Verisign’s arguments are to be believed, this poses a huge risk of information leakage — something that should be avoided at all costs in new gTLDs but which is apparently just fine in .com and .net.
Emails set to go to netsoolmail.net will fail today due to an NXDOMAIN response. But what happens when somebody registers that domain (which is likely to happen about 10 minutes after this post is published)?
Do they suddenly start receiving thousands of sensitive emails intended for NetSol’s customers?
Could NetSol’s spam filters all start to fail, causing SOMEBODY TO DIE! from a dodgy Viagra?
I don’t know. No clue. Probably not.
But there’s a risk, right? Even if it’s a very small risk (as Verisign argues), shouldn’t ICANN be preventing Verisign from promoting these domains, maybe using some kind of massive block-list?
Data leakage is important enough to Versign that it was the headline risk it posed in a recent report aimed at getting new gTLDs delayed.
In an August “technical report” entitled “New gTLD Security, Stability, Resiliency Update: Exploratory Consumer Impact Analysis”, somebody from Verisign wrote (pdf):

once delegated, the registrants under new gTLDs have the ability to register specific domains for targeted collisions
…
This form of information leakage can violate privacy of users, provide a competitive advantage between business rivals, expose details of corporate network infrastructures, or even be used to infer details about geographical locations of network assets or users

What the report fails to mention is that registrants today have this ability, and that Verisign is actively encouraging the practice.
In Yiddish they call what Verisign has done today chutzpah.
In British English, we call it taking the piss.

Verisign targets bank claims in name collisions fight

Verisign has rubbished the Commonwealth Bank of Australia’s claim that its dot-brand gTLD, .cba, is safe.
In a lengthy letter to ICANN today, Verisign senior vice president Pat Kane said that, contrary to CBA’s claims, the bank is only responsible for about 6% of the traffic .cba sees at the root.
It’s the latest volley in the ongoing fight about the security risks of name collisions — the scenario where an applied-for gTLD string is already in broad use on internal networks.
CBA’s application for .cba has been categorized as “uncalculated risk” by ICANN, meaning it faces more reviews and three to six months of delay while its risk profile is assessed.
But in a letter to ICANN last month, CBA said “the cause of the name collision is primarily from CBA internal systems” and “it is within the CBA realm of control to detect and remediate said systems”.
The bank was basically claiming that its own computers use DNS requests for .cba already, and that leakage of those requests onto the internet was responsible for its relatively high risk profile.
At the time we doubted that CBA had access to the data needed to draw this conclusion and Verisign said today that a new study of its own “shows without a doubt that CBA’s initial conclusions are incorrect”.
Since the publication of Interisle Consulting’s independent review into root server error traffic — which led to all applied-for strings being split into risk categories — Verisign has evidently been carrying out its own study.
While Interisle used data collected from almost all of the DNS root servers, Verisign’s seven-week study only looked at data gathered from the A-root and J-root, which it manages.
According to Verisign, .cba gets roughly 10,000 root server queries per day — 504,000 in total over the study window — and hardly any of them come from the bank itself.
Most appear to be from residential apartment complexes in Chiba, Japan, where network admins seem to have borrowed the local airport code — also CBA — to address local devices.
About 80% of the requests seen come from devices using DNS Service Discovery services such as Bonjour, Verisign said.
Bonjour is an Apple-created technology that allows computers to use DNS to automatically discover other LAN-connected devices such as printers and cameras, making home networking a bit simpler.
Another source of the .cba traffic is McAfee’s antivirus software, made by Intel, which Verisign said uses DNS to check whether code is virus-free before executing it.
While error traffic for .cba was seen from 170 countries, Verisign said that Japan — notable for not being Australia — was the biggest source, with almost 400,000 queries (79% of the total). It said:

Our measurement study reveals evidence of a substantial Internet-connected infrastructure in Japan that lies beneath the surface of the public-facing internet, which appears to rely on the non-resolution of the string .CBA.
This infrastructure appear hierarchical and seems to include municipal and private administrative and service networks associated with electronic resource management for office and residential building facilities, as well as consumer devices.

One apartment block in Chiba is is responsible for almost 5% of the daily .cba queries — about 500 per day on average — according to Verisign’s letter, though there were 63 notable sources in total.
ICANN’s proposal for reducing the risk of these name collisions causing problems would require CBA, as the registry, to hunt down and warn organizations of .cba’s impending delegation.
Verisign reiterates the point made by RIPE NCC last month: this would be quite difficult to carry out.
But it does seem that Verisign has done a pretty good job tracking down the organizations that would be affected by .cba being delegated.
The question that Verisign’s letter and presentation does not address is: what would happen to these networks if .cba was delegated?
If .cba is delegated, what will McAfee’s antivirus software do? Will it crash the user’s computer? Will it allow unsafe code to run? Will it cause false positives, blocking users from legitimate content?
Or will it simply fail gracefully, causing no security problems whatsoever?
Likewise, what happens when Bonjour expects .cba to not exist and it suddenly does? Do Apple computers start leaking data about the devices on their local network to unintended third parties?
Or does it, again, cause no security problems whatsoever?
Without satisfactory answers to those questions, maybe name collisions could be introduced by ICANN with little to no effect, meaning the “risk” isn’t really a risk at all.
Answering those questions will of course take time, which means delay, which is not something most applicants want to hear right now.
Verisign’s study targeted CBA because CBA singled itself out by claiming to be responsible for the .cba error traffic, not because CBA is a client of rival registry Afilias.
The bank can probably thank Verisign for its study, which may turn out to be quite handy.
Still, it would be interesting to see Verisign conduct a similar study on, say, .windows (Microsoft), .cloud (Symantec) or .bank (Financial Services Roundtable), which are among the 35 gTLDs with “uncalculated” risk profiles that Verisign promised to provide back-end registry services for before it decided that new gTLDs were dangerous.
You can read Verisign’s letter and presentation here. I’ve rotated the PDF to make the presentation more readable here.

Famous Four says that Demand Media’s .cam should be rejected

Demand Media’s application for .cam should be rejected because it lost a String Confusion Objection filed by .com registry Verisign, according to rival applicant Famous Four Media.
“The process in the applicant guidebook is now clear: AC Webconnecting and dot Agency Limited proceed to resolve the contention set, and United TLD’s application cannot proceed,” chief legal officer Peter Young told DI.
dot Agency is Famous Four’s applicant for .cam, which along with AC Webconnecting survived identical challenges filed by Verisign. United TLD is the applicant subsidiary of Demand Media.
Serious questions were raised about the SCO process after two International Centre for Dispute Resolution panelists reached opposition conclusions in the three .cam/.com cases last month.
Demand Media subsequently called for an ICANN investigation into the process, with vice president Statton Hammock writing:

String confusion objections are meant to be applicant agnostic and have nothing to do with the registration or use of the new gTLD.

However, Famous Four thinks it has found a gotcha in a letter (pdf) written by a lawyer representing Demand which opposed consolidation of the three .cam cases, which stated:

Consolidation has the potential to prejudice the Applicants if all Applicants’ arguments are evaluated collectively, without regard to each Applicant’s unique plan for the .cam gTLD and their arguments articulating why such plans would not cause confusion.

In other words, Demand argued that the proposed usage of the TLD should be taken into account before the ICDR panel ruled against it, and now it saying usage should not have been taken into account.
Famous Four’s Young said:

Whether or not one ascribes to the view that usage should not be taken into account, and we believe that it should (otherwise we would not have argued it), the fact is that United TLD were very explicit prior to the publication that usage should indeed be taken into account.

The SCO debate expanded yesterday when the GNSO Council spent some time discussing .cam and other SCO discrepancies during its regular monthly meeting.
Concerns are such that the Council intends to inform the ICANN board of directors and its New gTLD Program Committee that it is looking into the issue.
The NGPC, has “Update on String Similarity” on its agenda for a meeting on Tuesday, which will no doubt try to figure out what, if anything, needs to be done.

Name collisions comments call for more gTLD delay

The first tranche of responses to Interisle Consulting’s study into the security risks of new gTLDs, and ICANN’s proposal to delay a few hundred strings pending more study, is in.
Comments filed with ICANN before the public comment deadline yesterday fall basically into two camps:

• Non-applicants (mostly) urging ICANN to proceed with extreme caution. Many are asking for more time to study their own networks so they can get a better handle on their own risk profiles.
• Applicants shooting holes in Interisle’s study and ICANN’s remeditation plan. They want ICANN to reclassify everything except .home and .corp as low risk, removing delays to delegation and go-live.

They were responding to ICANN’s decision to delay 521 “uncalculated risk” new gTLD applications by three to six months while further research into the risk of name collisions — where a new gTLD could conflict with a TLD already used by internet users in a non-standard way — is carried out.
Proceed with caution
Many commenters stated that more time is needed to analyse the risks posed by name collisions, noting that Interisle studied primarily the volume of queries for non-existent domains, rather than looking deeply into the consequences of delegating colliding gTLDs.
That was a point raised by applicants too, but while applicants conclude that this lack of data should lead ICANN to lift the current delays, others believe that it means more delays are needed.
Two ICANN constituencies seem to generally agree with the findings of the Interisle report.
The Internet Service Providers and Connectivity Providers constituency asked for the public comment period be put on hold until further research is carried out, or for at least 60 days. It noted:

corporations, ISPs and connectivity providers may bear the brunt of the security and customer-experience issues resulting from adverse (as yet un-analyzed) impacts from name collision
…
these issues, due to their security and customer-experience aspects, fall outside the remit of people who normally participate in the ICANN process, requiring extensive wide-ranging briefings even in corporations that do participate actively in the ICANN process

The At-Large Advisory Committee concurred that the Interisle study does not currently provide enough information to fully gauge the risk of name collisions causing harm.
ALAC said it was “in general concurrence with the proposed risk mitigation actions for the three defined risk categories” anyway, adding:

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

Several individual stakeholders agreed with the ISPCP that they need more time to look at their own networks. The Association of Nation Advertisers said:

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 ANA wants the public comment period extended until November 22 to give its members more time to gather data.
While the ANA can always be relied upon to ask for new gTLDs to be delayed, its request was echoed by others.
General Electric called for three types of additional research:

• Additional studies of traffic beyond the initial DITL sample.
• Information and analysis of “use cases” — particular types of queries and traffic — and the consequences of the failure of particular use cases to resolve as intended (particular use cases could have severe consequences even if they might occur infrequently — like hurricanes), and
• Studies of the time and costs of mitigation.

GE said more time is needed for companies such as itself to conduct impact analyses on their own internal networks and asked ICANN to not delegate any gTLD until the risk is “fully understood”.
Verizon, Heinz and the American Insurers Association have asked for comment deadline extensions for the same reasons.
The Association of Competitive Technology (which has Verisign as a member) said:

ICANN should slow or temporarily suspend the process of delegating TLDs at risk of causing problems due to their frequency of appearance in queries to the root. While we appreciate the designation of .home and .corp as high risk, there are many other TLDs which will also have a significant destructive effect.

Numerically, there were far more comments criticizing ICANN’s mitigation proposal. All were filed by new gTLD applicants, whose interests are aligned, however.
Most of these comments, which are far more focused on the details and the data, target perceived deficiencies in Interisle’s report and ICANN’s response to it.
Several very good arguments are made.
The Svalbard problem
First, there is criticism of the cut-off point between “low risk” and “uncalculated risk” strings, which some applicants say is “arbitrary”.
That’s mostly true.
ICANN basically took the list of applied-for strings, ordered by the frequency Interisle found they generate NXDOMAIN responses at the root, and drew a line across it at the 49,842 queries mark.
That’s because 49,842 queries is what .sj, the least-frequently-queried real TLD, received over the same period
If your string, despite not yet existing as a gTLD, already gets more traffic than .sj, it’s classed as “uncalculated risk” and faces more delays, according to ICANN’s plan.
As Directi said in its comments:

The result of this arbitrary selection is that .bio (Rank 281) with 50,000 queries (rounded to the nearest thousand) is part of the “uncategorized risk” list, and is delayed by 3 to 6 months, whereas .engineering (Rank 282) with 49,000 queries (rounded to the nearest thousand) is part of the “low risk” list, and can proceed without any significant delays.

What neither ICANN nor Interisle explained is why this is an appropriate place to draw a line in the sand.
This graphic from DotCLUB Domains illustrates the scale of the problem nicely:
.sj is the ccTLD for Svalbard, a Norwegian territory in the Arctic Circle with fewer than 3,000 inhabitants. The TLD is administered by .no registry Norid, but it’s not possible to register domains there.
Does having more traffic than .sj mean a gTLD is automatically more risky? Does having less mean a gTLD is safe? The ICANN proposal assumes “yes” to both questions, but it doesn’t explain why.
Many applicants say that having more traffic than existing gTLDs does not automatically mean your gTLD poses a risk.
They pointed to Verisign data from 2006, which shows that gTLDs such as .xxx and .asia were already receiving large amounts of traffic prior to their delegation. When they were delegated, the sky did not fall. Indeed, there were no reports of significant security and stability problems.
The New gTLD Applicants Group said:

In fact, the least “dangerous” current gTLD on the chart, .sx, had 331 queries per million in 2006. This is a higher density of NXDOMAIN queries than all but five proposed new TLDs. 4 Again, .sx was launched successfully in 2012 with none of the problems predicted in these reports.
These successful delegations alone demonstrate that there is no need to delay any more than the two most risky strings.

Donuts said:

There is no factual basis in the study recommending halting delegation process of 20% of applied-for strings. As the paper itself says, “The Study did not find enough information to properly classify these strings given the short timeline.” Without evidence of actual harm, the TLDs should proceed to delegation. Such was the case with other TLDs such as .XXX and .ASIA, which were delegated without delay and with no problems post-delegation.

Applicants also believe that the release in June 2012 of the list of all 1,930 applied-for strings may have skewed the data set that Interisle used in its study.
Uniregistry, for example, said:

The sole fact that queries are being received at the root level does not itself present a security risk, especially after the release to the public of the list of applied-for strings.

The argument seems to be that a lot of the NXDOMAIN traffic seen in 2013 is due to people and software querying applied-for TLDs to see if they’re live yet.
It’s quite a speculative argument, but it’s somewhat supported by the fact that many applied-for strings received more queries in 2013 than they did in the equivalent 2012 sampling.
Second-level domains
Some applicants pointed out that there may not be a correlation between the volume of traffic a string receives and the number of second-level domains being queried.
A string might get a bazillion queries for a single second-level domain name. If that domain name is reserved by the registry, the risk of a name collision might be completely eliminated.
The Interisle report did show that number of SLDs and the volume of traffic do not correlate.
For example, .hsbc is ranked 14th in terms of traffic volume but saw requests for just 2,000 domains, whereas .inc, which ranked 15th, saw requests for 73,000 domains.
Unfortunately, the Interisle report only published the SLD numbers for the top 35 strings by query volume, leaving most applicants none the wiser about the possible impact of their own strings.
And ICANN did not factor the number of SLDs into its decision about where to draw the line between “low” and “uncalculated” risk.
Conspiracy theories
Some applicants questioned whether the Interisle data itself was reliable, but I find these arguments poorly supported and largely speculative.
They propose that someone (meaning presumably Verisign, which stands to lose market share when new gTLDs go live, and which kicked off the name collisions debate in the first place) could have gamed the study by generating spurious requests for applied-for gTLDs during the period Interisle’s data was being captured.
Some applicants put forth this view, while other limited their comments to a request that future studies rely only on data collected before now, to avoid tampering at the point of collection in future.
NTAG said:

Query counts are very easily gamed by any Internet connected system, allowing for malicious actors to create the appearance of risk for any string that they may object to in the future. It would be very easy to create the impression of a widespread string collision problem with a home Internet connection and the abuse of the thousands of available open resolvers.

While this kind of mischief is a hypothetical possibility, nobody has supplied any evidence that Interisle’s data was manipulated by anyone.
Some people have privately pointed DI to the fact that Verisign made a substantial donation to the DNS-OARC — the group that collected the data that Interisle used in its study — in July.
The implication is that Verisign was somehow able to manipulate the data after it was captured by DNS-OARC.
I don’t buy this either. We’re talking about a highly complex 8TB data set that took Interisle’s computers a week to process on each pass. The data, under the OARC’s deal with the root server operators, is not allowed to leave its premises. It would not be easily manipulated.
Additionally, DNS-OARC is managed by Internet Systems Consortium — which runs the F-root and is Uniregistry’s back-end registry provider — from its own premises in California.
In short, in the absence of any evidence supporting this conspiracy theory, I find the idea that the Interisle data was hacked after it was collected highly improbable.
What next?
I’ve presented only a summary of some key points here. The full list of comments can be found here. The reply period for comments closes September 17.
Several ICANN constituencies that can usually be relied upon to comment on everything (registrars, intellectual property, business and non-commercial) have not yet commented.
Will ICANN extend the deadline? I suppose it depends on how cautious it wants to be, whether it believes the companies requesting the extension really are conducting their own internal collision studies, and how useful it thinks those studies will be.