Name: At-Large Advisory Committee (ALAC) Policy staff in support of the At-Large Community
Date: 19 Jul 2023
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
The At-Large Advisory Committee (ALAC) has submitted its comments via the enclosed attachment.
The official ALAC statement has been discussed by the Consolidated Party Working Group (CPWG) and was ratified by the ALAC ahead of submission.
ICANN Policy Staff in support of the At-Large Community
Summary of Attachment
The attached statement is in lieu of completing this form.
Summary of Submission
DNS Abuse has been discussed and debated within ICANN for well over a decade. The ALAC has repeatedly heard registrars say that ICANN Contractual Compliance should take action against “bad actors” and ICANN Contractual Compliance saying that they did not have the tools to enforce compliance by such “bad actors”.
It was evident that the only way to address this stalemate was for the Contracted Parties and ICANN Org to sit down and ensure that ICANN Org had the necessary tools to compel Registrars (and even Registry Operators) to take appropriate action on a timely basis to either stop or at least disrupt clear incidences of DNS Abuse, or even contemplate prevention of DNS Abuse.
It is with collective pleasure that the ALAC compliments the Registrar Stakeholder Group, the Registry Stakeholder Group and ICANN Org for finally doing just that.
The ALAC supports the proposed contractual improvements to section 3.18 of the Registrar Accreditation Agreement and section 4, Specification 6 the Registry Agreement, and strongly encourages the Registrar Stakeholder Group and the Registry Stakeholder Group to adopt them, enabling all relevant parties to take whatever action necessary to ensure that they are implemented without delay.
In particular, the ALAC is pleased to note the proposed introduction of a new section 4.2 within Specification 6 of the Registry Agreement which seeks to provide for specific baseline action by a Registry Operator to stop, or otherwise disrupt a domain name from being used for DNS Abuse, and especially for such Registry Operator to take direct action where it deems appropriate.
The ALAC welcomes the accompanying Draft ICANN Advisory explaining the new requirements, and which provides guidance and expectations for action by registrars and registries to ensure compliance with the new contractual terms. We believe that the case scenarios spelt out therein offer some clarity on actions expected by registrars and/or registries in terms of appropriaten