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Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

هذا المحتوى متوفر فقط باللغة (أو اللغات)

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Name: Amy Cadagin
Date: 7 Oct 2025
Affiliation: Messaging, Malware and Mobile Anti-Abuse Working Group ( M3AAWG )
Email: [email protected]
Original Public Comment: Preliminary Issue Report on a Policy Development Process on DNS Abuse Mitigation
Attachment

M3AAWG Input on ICANN's Next Abuse Policy Initiative .pdf (406.8 KB)

Summary of Attachment

In our public comment document, M3AAWG provides a detailed evaluation of the ideas that the GNSO is considering. Our attachment is in lieu of completing the Public Comment Proceeding form.

Summary of Submission

The GNSO is considering policy-making ideas to curb the abuse of domain names. In our full comment document, M3AAWG evaluates these ideas in detail for effectiveness, practicality, and impact. M3AAWG is a global, technology-neutral industry association that develops cooperative approaches for fighting online abuse. M3AAWG’s members are experts at fighting DNS abuses including malware, spam, phishing, botnets, DoS attacks, and other online exploitation. We urge the GNSO and the ICANN Org staff to examine our full comments.

 

Regarding the three ideas or “gaps” that the GNSO’s Issue Report recommends be prioritized for policy, our summary is:

“Unrestricted Application Programming Interface (API) access for domain name registration for new customers:” M3AAWG believes that a policy placing limitations on bulk domain registrations offers significant opportunities for abuse prevention and has the greatest potential value. The problem is that bad actors easily register and use large numbers of domains, and the purpose of this policy should be to prevent bad actors from obtaining large numbers of domains. The GSNO should note that “APIs” or “access to APIs” are an aspect of the problem, and are how some of this abusive activity is carried out, but “access to APIs” is not the problem itself, and “limiting access to APIs” is not the entire solution. Discussions should recognize that APIs are often a tool used somewhere in the process, but just “restricting access to APIs” may not solve the problem.

“Associated domain checks:” this idea has some merit because it could help with both prevention and mitigation. However, its efficacy will depend upon diligent and professional execution, and it poses some enforcement/compliance challenges.

“Limited coordination on Domain Generation Algorithm (DGA)-based abuse:” M3AAWG does not believe that ICANN has the ability to create an effective solution here, and that this idea should be put aside in favor of better ones.