The gTLD Registries Stakeholder Group (RySG) welcomes the opportunity to comment on the Names Collision Procedure Documentation and provides the following three items as input to ICANN :

The most important parts of the Name Collision assessment should be conducted before the “Day in the Life of the Internet (DITL)” measurement (the DNS-OARC April event mentioned in the Name Collision Initial Assessment document on p.2). Only additional or supplementary assessments should take place afterward, and their results should be interpreted with caution.  This would minimize opportunities for third parties to deliberately influence the assessment.

Under procedure 2, Temporary Delegation, a string may remain in the data collection and monitoring phase up to 365 days (point b on page 4).  Fees paid for the integration in the TMCH during this period should be waived or deducted from the subsequent TMCH annual fee. 

If the TRT decides that Temporary Delegation is required for longer than 90 days they should provide an explanation as to why. The document states that  “ICANN will provide a public status update on the progress of the Temporary Delegation,” but this is somewhat vague and may not necessarily include an explanation of the underlying concern. If a string remains in Temporary Delegation for a longer period, additional periodic updates should also be provided.

The gTLD Registries Stakeholder Group (RySG) provides comments on three items: main parts of the Name Collision assessment to be conducted before DITL; TMCH fee to be updated in function of the duration of the collection and monitoring phase; providing an explanation of underlying concerns when a string remains in Temporary Delegation.