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

[Farell Folly]

I agree with you Milton.

We can't not pretend that a null effect (always) means that the safeguards
are ineffective. There are many reasons that could justify this. Even a
decrease does not necesarily indicate that they are effective (chosen time
span might be too short for evaluation, or the study could have been
conducted too early).

When there is a null effect, one must ask what if there was no safeguard ?
i.e we can possible (and only) say that the safeguards are ineffective if
their presence of absence absolute result in the same rate.

But from development point of view, when there is an economic growth, it is
high likely that criminality will increase because money flow increase and
this is normal (criminals always develop new means and bypass).
Transposing this to the Internet world means that there is growth in the
DNS space associated with interesting business opportunities, there will be
also fraud, abuse, increase and possibly in a non proportionned way no
matter how many safeguards we put in place, especially when there is too
much legal restriction. However, the safeguards are also necessary :
monitoring, dissuasive, evidence collection, etc...

I hope the CCT-RT will use the best approach/model to cope with complex
case, since the nine safeguards report was conducted for the prupose to
help their work.

Le mer. 20 sept. 2017 à 19:40, Mueller, Milton L <milton at gatech.edu> a
écrit :

> 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
> à 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
>
> [image: 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
>
-- 
Regards
@__f_f__
https://www.linkedin.com/in/farellf
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