[NCSG-PC] [Public Comment] Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations

[Tomslin Samme-Nlar]

Dear members and PC,

Thanks to Farzi, here
<https://docs.google.com/document/d/1fhUPo5iMZ82K0nOMSso78AtzBL-4EVVEeZ13r5yRYaI/edit?usp=sharing>
is our draft response to amendments to the base gTLD RA and RAA DNS abuse
contract obligations. A reminder that the deadline to submit the comment is
on Thursday 13 July 2023. So, if you could please review/comment by 23:59
UTC Tuesday 11 July, that will be much appreciated.

Warmly,
Tomslin
NCSG Policy Chair


On Thu, 1 Jun 2023 at 14:08, Tomslin Samme-Nlar <mesumbeslin at gmail.com>
wrote:

> Dear members,
>
> One of the results of the community conversations surrounding DNS Abuse is
> that the contracted party house (CPH) is proposing amendments to the gTLD
> RA and 2013 RAA Agreements with the intention to "enhance obligations by
> requiring registrars and registry operators to promptly take reasonable and
> appropriate action to stop or otherwise disrupt DNS Abuse"
>
> NCSG councillors in the council specifically requested that the CPH put
> the negotiated text for public comments when this was discussed in the
> council and this comment proceeding is as a result of that. With this in
> mind, the NCSG PC is seeking volunteers to draft a comment to this effect.
> I know there are many folks interested in DNS abuse here so I look forward
> to you all contacting me at mesumbeslin at gmail.com
>
> Deadline to submit the comment is 13 July 2023 but we expect the draft
> about 2 weeks before then. You can find more information here:
> https://www.icann.org/en/public-comment/proceeding/amendments-base-gtld-ra-raa-modify-dns-abuse-contract-obligations-29-05-2023
> I have created a draft Google doc for the comment here:
> https://docs.google.com/document/d/1fhUPo5iMZ82K0nOMSso78AtzBL-4EVVEeZ13r5yRYaI/edit?usp=sharing
>
> *Some things to note:*
>
> The proposed revisions include the following:
>
>    - Requirements to ensure abuse contacts are readily accessible on the
>    contracted party’s webpage and to produce receipt confirmation for
>    reporters upon receipt of abuse reports
>    - Possibility for registrars and registry operators to use webforms
>    instead of email as an abuse reporting mechanism
>    -  A definition of DNS Abuse for purposes of the Agreements
>    -  A new requirement to promptly take appropriate mitigation actions
>    against domains for which the contracted party has actionable evidence
>    demonstrating that the domains are being used for DNS Abuse
>    -  Permits contracted parties (CPs) to exercise reasonable discretion
>    in selecting and implementing the appropriate mitigation actions depending
>    on the circumstances of each case
>    -  Recognition of the different roles of the registrar and registry
>    operator
>    -  Focus on the target outcome of stopping or disrupting the use of
>    gTLD domain names for DNS Abuse
>    - The proposed amendments do not specify the mitigation actions, or
>    their timing, as such approach may not guarantee the desired outcome in all
>    instances.
>
>
> Warmly,
> Tomslin
> @LinkedIn: https://www.linkedin.com/in/tomslin/
>
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