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

[Ken Herman]

Thanks Tomslin and Farzaneh

 

I’ve added some text which others may wish to consider.

 

Ken

 

From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU> On Behalf Of Tomslin Samme-Nlar
Sent: Sunday, July 9, 2023 3:56 AM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU
Subject: Re: [Public Comment] Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations

 

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 <mailto: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 <mailto: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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