SSAC's purported "findings" and "recommendations" are inappropriate, unsubstantiated, and themselves contrary to longstanding written standards and specifications for the operation of the DNS and the Internet. None of SSAC's findings conclude that Site Finder, or wildcards generally, pose a threat to the security and stability of the Internet's naming and address allocation system. That is the limit of SSAC's mandate. Accordingly, those "findings" and "recommendations" it does make exceed the scope of SSAC's charter as a limited technical advisory committee - to evaluate security and stability threats to the Internet's naming and address allocation systems - and are not derived from the supposed principles espoused by SSAC.

Such overreaching is an understandable by-product of the context in which the Report was created. SSAC began its analysis with the predetermined conclusion that Site Finder, and all other wildcards, should be prohibited. Indeed, a draft of SSAC's September 22, 2003 report reveals that the "Opinions" and "Recommendations" were drafted before the committee had undertaken any reasoned evaluation of Site Finder. The September 19, 2003 draft of the report entitled Recommendations Regarding Veri[S]ign's Introduction of Wild Card Response to Unregistered Domains within .com and .net., circulated by Steven Crocker, contained fully formed conclusions and recommendations, yet nothing under the "Analysis" heading except a plea for Paul Vixie, among others, to "please dump stuff into this section." Under these circumstances, SSAC's adherence to its preliminary conclusion, notwithstanding the absence of any evidence of a security or stability threat to the DNS or the Internet, should come as no surprise. Moreover, the Report appears primarily to have been composed and/or contributed to by persons who are opponents of Site Finder and/or competitors of VeriSign, a fact the Report fails to acknowledge.

The Report is fundamentally flawed in its process, analysis and recommendations. SSAC had a single, limited mandate with respect to Site Finder - to assess quantitatively the technical effect of Site Finder on the stability and security of the DNS and the Internet. SSAC mustered no evidence that Site Finder adversely impacted the security of the DNS or Internet. SSAC found no evidence that Site Finder adversely impacted the stability of the DNS or Internet. SSAC was forced to acknowledge that Site Finder did not cause DNS or Internet failures or outages. These facts should have ended SSAC's Site Finder process.

Instead, having concluded before it had even begun its investigation that Site Finder should be suspended, and having been stacked during its purported technical evaluation with Site Finder opponents, SSAC proceeded in the absence of evidence or quantification to formulate the biased and unsupported conclusions and recommendations appearing in the Report. Those conclusions and recommendations do not follow from any evidence or technical analysis by SSAC. Rather, they derive from and reflect the purely personal philosophies and preferences of SSAC's conflicted membership. As SSAC member Paul Vixie recognized: "[I] was publicly critical of *.com and *.net, but that's a policy problem, not an operational problem." (Emphasis added.) SSAC's conclusions and recommendations should thus be recognized for what they are - policy recommendations by a body that was not charged with, and has no expertise in, policymaking.

Indeed, SSAC's policies espoused in the Report are misguided and wrong-headed. They equate "stability" with a total lack of change. However, as the RFC's themselves recognize, the history of the Internet is change, and the future of the Internet is change. To remain vibrant and responsive, the Internet must change, at its core as well as at the periphery. By aligning itself with an immutable status quo, SSAC has done a thorough disservice - to Site Finder, to the Internet, and to present and future Internet users who expect innovation to keep the Internet expanding and responsive to their needs.

VeriSign reserves all rights and remedies it has with respect to the actions of ICANN and SSAC regarding Site Finder or any other matter, including those rights subject to claims in the pending litigation VeriSign has commenced against ICANN. A statement of the violations of VeriSign's rights by reason of the conduct of ICANN and SSAC, including in connection with the Report, is beyond the scope of this letter.