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

Wed Sep 20 15:32:28 EEST 2017

As a quantitative economist I would like to add to Milton's cautions 
about how to read the data, and raise a more problematic issue. Relative 
growth numbers, as between new DNS and new abuse by themselves mean 
nothing. First, DNS abuse is a "mixed bag" of abuses ranging from 
annoying to dangerous and criminal. Second, the numbers do not reflect 
the success or failure of abuse reduction efforts.

The measures can be recorded as cardinal (how many) and ordinal (these 
worse than those). Both numbers are useful in the appropriate context, 
for example the contexts of counter-abuse that might work (or might not 
work) in the design of the RDS and changed WhoIS, and what LEAs (Law 
Enforcement Agencies) or software designers might do to counter abuse.

However, overall measures of DNS abuse are composed of annoyances 
(search engine service solicitations), crimes (financial scams) and 
whatever. Bundled together as DNS abuse, their numbers tell us nothing 
about the merits, or demerits of expansion of the DNS system. These are 
two separate issued and we should not conflate them, or allow others to 
conflate them.

Sam L.

On 9/20/2017 2:40 PM, Mueller, Milton L wrote:
>
> 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 à*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 à*Ineffective 
> Safeguard Hypothesis.*
>
> ü*Model 3:*The expansion of the DNS has had a null effect on DNS abuse 
> àIneffective *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
>

-- 
------------------------------------------------
"It is a disgrace to be rich and honoured
in an unjust state" -Confucius
  邦有道，贫且贱焉，耻也。邦无道，富且贵焉，耻也
------------------------------------------------
Dr Sam Lanfranco (Prof Emeritus & Senior Scholar)
Econ, York U., Toronto, Ontario, CANADA - M3J 1P3
email: Lanfran at Yorku.ca   Skype: slanfranco
blog:  https://samlanfranco.blogspot.com
Phone: +1 613-476-0429 cell: +1 416-816-2852

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