This attachment is submitted in lieu of completing the Public Comment Proceeding form.

ENS Labs, Ltd. submits this comment on the Name Collision Procedure Documentation for the 2026 New gTLD Round. ENS is the developer of the Ethereum Name Service (.eth), operating since 2017 with approximately 1.6 million active registrations. ENS supports ICP-3 and the single authoritative DNS root.

The comment identifies a critical gap in the Procedure Documentation. The framework defines name collision to include collisions between the DNS and alternative naming systems, but the assessment tools are calibrated for traditional private-namespace leakage (.corp, .home, .mail). The 2026 round will include applicants who operate alternative naming systems with millions of pre-existing registrations under strings they seek to operate as gTLDs. Name collisions of this type have already occurred with the Handshake naming system. The current framework has no mechanism to assess this category of risk.

The comment proposes eight recommendations: (1) amend AGB Section 6.7.2 to enumerate qualitative evidence types; (2) require applicants to disclose alternative namespace operations; (3) expand the TRT's data sources beyond DNS query data; (4) publish the TRT's assessment methodology before the application window; (5) create a pre-existing alternative namespace risk factor; (6) require overlapping namespace mitigation plans at application; (7) ensure the TRT can consult expertise in alternative naming and blockchain resolution; and (8) evaluate applicant track records, including strings previously launched and abandoned.

ENS Labs can provide technical expertise, data, and further input as ICANN finalizes these procedures.

 The Name Collision framework for the 2026 round correctly identifies the risk of collision

  between the DNS and alternative naming systems. But the assessment tools do not match the

  definition. The TRT's data sources (root server logs, recursive resolver data, NCO

 magnitude scores) were designed to detect intranet leakage. They cannot detect millions of

  registrations that resolve via blockchain smart contracts, browser extensions, or

 peer-to-peer networks and never generate DNS queries.

 This is not theoretical: name collisions between the Handshake naming system and

 ICANN-delegated TLDs have already occurred. The 2026 round will be the first in which

 applicants bring pre-existing namespaces with large installed bases into the ICANN

 process. Some of these applicants created dozens of TLD strings outside the DNS, abandoned

  most, and now seek delegation for a subset. The framework must be able to assess the

 collision risk this creates.

 ICANN should require alternative namespace disclosure from applicants, expand the TRT's

 data sources consistent with SAC130 Recommendation 3, publish the assessment methodology

 before the application window opens, and ensure the TRT has access to expertise in

 blockchain resolution and alternative naming systems. The procedures should be finalized

 before applications open on April 30, 2026.