[Ncsg-discuss] SCCI Criteria 4 - “domain name security threats”

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Julf, I agree with the analysis by Abbas. Explicitly Including “DNS abuse” broadens the indicator into an area unsuitable for the GNSO Council for the reasons he describes.

 

In terms of a statement, we can perhaps relate something like “the ICANN community has reached general consensus around a narrow set of DNS security threats (phishing, malware, botnets, pharming, and spam as a delivery mechanism). However, there has not been universal stakeholder consensus on the broader conceptual definition of DNS Abuse or on where the boundary lies between DNS abuse and content abuse. Therefore, since the term DNS abuse” can mean different things to different stakeholders, even within the narrow threats mentioned, by including "DNS abuse" as an indicator for evaluating the performance of the GNSO council risks creating unclear, and potentially unrealistic, expectations for achieving the stated criteria, to say nothing of the opportunity for debate regarding whether or not the criteria has been met.”

 

I hope this helps.

 

Ken

 

From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU> On Behalf Of Abbas Sibai
Sent: Monday, June 15, 2026 9:33 AM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU
Subject: Re: SCCI Criteria 4 - “domain name security threats”

 

Hi Julf,

Thanks for flagging this. As an individual member of the NCUC, I completely share your concerns. Specifically inserting the term "DNS Abuse" into the GNSO Continuous Improvement Program framework is a major red flag that we definitely need to push back against during the upcoming call on Wednesday, 1 July 2026.

>From our constituency’s perspective, my understanding is that there are two distinct "cans of worms" this proposal opens up:

*	Mission Creep and Content Regulation: Broadening the text to explicitly name "DNS Abuse" risks shifting the GNSO's focus from core technical layer infrastructure toward content regulation. What I understood is that the NCUC has a long-standing commitment to fiercely protecting freedom of expression and digital rights. If the indicators explicitly target "DNS Abuse" rather than strictly defined security threats, it invites outside pressure on the GNSO to police website content, a precedent that directly undermines our core mission and human rights principles.
*	Disproportionality and Human Rights Impacts: I also understood that  NCUC has consistently advocated that any policy intervention addressing domain security must be narrow, proportionate, and strictly scoped. Tying the evaluation of the GNSO's performance to broad and subjective perceptions of "DNS Abuse" (especially via a survey indicator) creates an incentive to pass sweeping, reactive policies. This places innocent registrants at risk of collective or automated domain suspensions without adequate due process or Human Rights Impact Assessments (HRIAs).

The original text, focusing strictly on "mitigating domain name security threats," keeps the evaluation grounded within the GNSO's technical and contractual scope. The proposed revision unnecessarily complicates it and opens the door to over-policing at the registry/registrar level.

I fully support our leadership taking a strong stance against this text on Wednesday. Please let me know if you need any assistance with drafting a formal statement or if there are specific points you want supported during the call.




Warm Regards,




Abbas Sibai
Policy & Advocacy Specialist





 <tel:+9613824725> +9613824725


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 <https://www.linkedin.com/in/abbas-sibai/> https://www.linkedin.com/in/abbas-sibai/

		

 

 

On Mon, Jun 15, 2026 at 12:28 PM Johan Helsingius <00001963cc94b85a-dmarc-request at listserv.syr.edu <mailto:00001963cc94b85a-dmarc-request at listserv.syr.edu> > wrote:

Hi all,

I am the NCSG representative to the Standing Committee on Continuous
Improvement (SCCI) that is formulating the Continuous Improvement
Program framework. The SCCI is chaired by Manju, another NCSG:er, but
as chair she has to remain neutral.

The work until now has been developing the Criteria and Indicators
that will be used to judge how well the GNSO processes are working.

We have made good progress under the very capable leadership of Manju,
and most issues haven't been very controversial, but I want to flag
the current issue where we probably want to speak up against the current
proposal.

The issue is Criteria 4, "The GNSO actively combats domain name
security threats", where there is a proposal to change the draft
text from:

     Indicator 1: The GNSO has demonstrated meaningful activity towards
                  mitigating domain name security threats.

     Indicator 2:  66% of surveyed respondents agree that the GNSO
                   combats domain name security threats.

to:

     Indicator 1: The GNSO has demonstrated meaningful activity towards
                  mitigating DNS Abuse and security threats relating to
                  domain names that are in scope for the GNSO.


     Indicator 2:  66% of surveyed respondents agree that the GNSO has
                   demonstrated meaningful activity towards mitigating
                   DNS Abuse and security threats relating to domain
                   names that are in scope for the GNSO.

While we probably are OK with mitigating domain name security threats,
specifically mentioning DNS Abuse opens up some cans of worms.

We will have a chance to present our views at the next SCCI call on
Wednesday, 1 July 2026, so I welcome your comments/opinions.

        Julf

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