Important: DNS Abuse Small Group

[Yao Amevi A. Sossou]

Dear Farzi,

Thank you for sharing this crucial work and for the opportunity to provide
input. The small team has clearly done a thorough job in identifying some
existing gaps, and the proposed "principles for rights-respecting dns abuse
mitigation" are an excellent framework for shaping our response. Your
proposition correctly centers the discussion on due process, transparency,
and the protection of legitimate users, which should be the cornerstones of
the ncsg's position.

On a general note I would say that the provided list of gaps presents a
clear challenge, highlighting systemic issues ranging from contractual
ambiguities to a lack of coordinated enforcement. The principles you have
drafted offer a coherent and rights-based pathway to addressing them.
Instead of proposing purely technical or punitive measures, the principles
establish essential "garde-fous" to ensure that any new solutions are fair,
proportionate, and transparent.

Kind regards,
.............................................................
Yao Amevi A. Sossou

Digital Transformation Advocate | Design & Innovation Evangelist | Human
centered Entrepreneurship| SDG Advocate | Internet Governance

.............................................................

Email: soyames at gmail.com

Twitter: *https://twitter.com/_amevY2 <https://twitter.com/_amevY2>*

LinkedIn: Yao Amevi A. sossou | LinkedIn
<https://www.linkedin.com/in/ameviy/>

.............................................................

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On Fri, Jun 20, 2025 at 5:36 PM farzaneh badii <farzaneh.badii at gmail.com>
wrote:

> Dear Members,
>
> As I mentioned before the Council has a small team on DNS abuse and we
> need to write up an issue report. At the moment we are working on the gaps
> here:
> https://docs.google.com/spreadsheets/d/1TRyUYb4Dr1VqxJ1H9n983ClbGx968QK0/edit?gid=1836517289#gid=1836517289
> The small team members should consult with their stakeholder groups. So I
> am consulting with you, here are the concerns I see in the solutions and
> going to send a few of the concerns to the small team after your
> consideration. Please weigh in by next week:
>
>
> Principles for Rights-Respecting DNS Abuse Mitigation
>
> Associated Domains & Surveillance
> When investigating actionable DNS abuse, registrars may need to examine
> other domains associated with the same registrant data to disrupt broader
> abuse networks. However, such inspections must be conducted with strict
> safeguards to avoid undue surveillance of legitimate registrants.
> Investigations must be grounded in clear, specific evidence of abuse linked
> to the registrant—never on speculative or broad profiling. The focus must
> remain on the abusive activity, not on surveilling the registrant’s broader
> online presence.
>
> Domain Pricing & Access
> Affordable or free domain names are essential for digital inclusion. They
> allow individuals, small businesses, and civil society groups to establish
> a presence online.
>
>    -
>
>    Pricing should not be used as a blunt tool for abuse mitigation. Doing
>    so risks disproportionately harming legitimate users and undermining
>    efforts to expand equitable access to the Internet.
>    -
>
>    Abuse mitigation by registrars offering low-cost domains should
>    instead rely on rights-respecting measures: clear abuse reporting channels,
>    prompt investigation, proportionate response, and strong due process—not
>    financial barriers.
>
> Reactive vs. Proactive Measures
> Well-implemented reactive measures can be as effective as proactive
> strategies in addressing abuse.
>
>    -
>
>    However, overly broad or premature proactive interventions (e.g.,
>    preemptive takedowns, automated flagging) can generate false positives,
>    unjust suspensions, and chilling effects on lawful expression.
>    -
>
>    Any proactive measure must be subject to rigorous human rights risk
>    assessment, implemented with narrowly tailored scope, transparency, and
>    meaningful recourse options to ensure proportionality and accountability.
>
> Pre-Mitigation Due Diligence
> Before taking any mitigation action, registrars must carry out thorough
> and proportionate due diligence based on specific, actionable evidence.
> This helps prevent false positives and ensures that mitigation measures are
> appropriate to the verified abuse. Where possible, less restrictive
> alternatives should be considered before resorting to domain suspension.
>
> During Mitigation Transparency
> When action is taken against a domain, the registrant must be promptly
> notified. This notice should include:
>
>    -
>
>    The reason for the action;
>    -
>
>    The type of action taken;
>    -
>
>    The initiator of the action (e.g., registrar, third-party request);
>    -
>
>    A clear explanation in accessible language.
>
> Post-Mitigation Remedy & Recourse
> Registrars must maintain accessible and transparent mechanisms for
> registrants to seek remedy or challenge decisions. This includes:
>
>
>    -
>
>    Restoration Process: A pathway for legitimate registrants to
>    demonstrate that abuse has been resolved—or that the action was
>    mistaken—and regain control of their domain in a timely manner.
>    -
>
>    Complaints & Appeals: A clear and fair process through which
>    registrants can file complaints or appeal mitigation actions, reinforcing
>    procedural fairness and accountability.
>
>
> Farzaneh
>
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