Request for Comment re: Strengthening Federal Cybersecurity and Addressing Botnets

July 28, 2017

National Telecommunications and Information Administration
US Department of Commerce
1401 Constitution Avenue, NW #4725
Washington, DC 20230

Attn: Evelyn L. Remaley, Deputy Associate Administrator

Re: Request for Comment, Executive Order 13800, ‘‘Strengthening the Cybersecurity of Federal Networks and Critical Infrastructure” and the Government’s Role in Addressing Automated Distributed Attacks

…We appreciate the opportunity to comment on automated distributed attacks (hereinafter botnets) both in these comments and through participation in NIST’s July Workshop on Enhancing Resilience of the Internet and Communications Ecosystem. Because CDT recently discussed privacy at length in comments on your Internet of Things (IoT) green paper, these comments will highlight additional principles that are crucial to the government’s response to botnets.