Name: Business Constituency
Date: 20 Jul 2023
Affiliation: ICANN Business Constituency (BC)
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
Summary of Attachment
Our attachments are in lieu of completing this form.
The PDF attachment shows our Section 2 comments in context.
Readers of the Word doc attachment should "Show comments" when reviewing Section 2.
Summary of Submission
The BC greatly appreciates the efforts of contracted parties and ICANN Org for their good-faith negotiations on amendments to the Registrar Accreditation Agreement (RAA) and base gTLD Registry Agreement (RA) on the important issue of DNS Abuse. These proposed amendments are a good first step, represent meaningful progress, and will serve as a solid foundation for what we hope will be a long-term effort by industry to address this persistent and evolving problem. We respectfully suggest a few additional targeted improvements to the proposal to ensure that the worst cases of DNS abuse are effectively mitigated in a timely manner by all contracted parties.
Section 1 of our comment conveys the BC position, highlights areas for improvement, and provides suggestions for next steps to advance this issue.
In the second section, we suggest edits and provide comments on the May-2023 draft "Advisory: Compliance With DNS Abuse Obligations in the Registrar Accreditation Agreement and the Registry Agreement"