Public Comment on the Statistical Analysis of DNS Abuse in gTLDs (SADAG) Report

[Mueller, Milton L]

Farrell
Thanks for alerting us to this.
I have quickly skimmed the report and have one immediate comment, probably more later if I get time.

The report contains this stuff:

Three testable hypothetical scenarios derive from the suggested base model:

ü  Model 1: The expansion of the DNS has resulted in a proportional decrease in DNS abuse --> Effective Safeguard Hypothesis.

ü  Model 2: The expansion of the DNS via the New gTLD Program has resulted in a proportional increase in DNS abuse --> Ineffective Safeguard Hypothesis.

ü  Model 3: The expansion of the DNS has had a null effect on DNS abuse --> Ineffective Safeguard Hypothesis.

I would like to point out that Model 3 is completely illogical. If the growth of the name space results in a proportional increase in DNS abuse, then it means that the addition of new gTLDs has no effect on the overall rate of abuse. Therefore, the safeguards are effective and there should be no presumption against adding new TLDs.

Currently Model 3 says if there is a null effect it means the safeguards are ineffective. This is nonsense. It presumes that we can’t add new TLDs unless it somehow results in the secular rate of abuse going down across the entire name space, including legacy TLDs. This is like saying that if the growth of the internet results in a proportional increase in cybercrime, then we should stop adding people to the internet. It isn’t logically justified – and it isn’t fair to those who are not already on the internet, is it?

I hope everyone on that committee from NCSG understands that the IPR constituency and some in the BC have always opposed name space expansion and will search for any excuse and any reasons to block the expansion of the name space. And in many respects, these people are arguing against the expansion of the internet itself.


Dr. Milton L Mueller
Professor School of Public Policy
Georgia Institute of Technology
[igp email logo]<http://internetgovernance.org/>



From: NCSG-Discuss [mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU] On Behalf Of Farell Folly
Sent: Monday, September 18, 2017 6:03 PM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU
Subject: Public Comment on the Statistical Analysis of DNS Abuse in gTLDs (SADAG) Report


Dear All (Sorry for double posting - as I have no idea whether my first attempts was effectively delivered or not)

The NCSG is required to make a public comment on the SADAG report available at this link<https://www.icann.org/public-comments/sadag-final-2017-08-09-en>. Actually, following a call from Rafik, our policy Committte Chair, a few people volunteered to draft a proposal<https://docs.google.com/document/d/10K4cnqMrhRnF1mZFtBbQKpzGNMBcZv2OCjvly_8eYoQ/edit> which intends to represent the NCSG position on this report<https://www.icann.org/public-comments/sadag-final-2017-08-09-en>, therefore; all members are encouraged to review the draft and make any comment or suggestion by tomorrow september 19th (ideally - as the original deadline) or not later than thursday (we are trying to posptone the deadline to Friday).

The purpose of this public comment is to gather feedback and analyze the data, methodology, and results of the Statistical Analysis of DNS Abuse in the new gTLDs (SADAG) report. The report is under the review of the CCT Review Team which will use it as input to evaluate the effectiveness of the nine safeguards techniques to mitigate DNS abuse following the introduction of the new gTLDs.

To have a quick background on the topic, I drafted some materials that I want to share with those who have no idea about it but wish to contribute.
--
Regards
@__f_f__
https://www.linkedin.com/in/farellf
--
Regards
@__f_f__
https://www.linkedin.com/in/farellf
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