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

[Remmy Nweke]

thanks Tomslin for sharing
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On Sun, Jul 9, 2023 at 8:59 AM Tomslin Samme-Nlar <mesumbeslin at gmail.com>
wrote:

> 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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