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

[Tomslin Samme-Nlar]

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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