Name: Ephraim Percy Kenyanito
Date: 20 Jul 2023
Affiliation: Cross-Community Working Party on ICANN and Human Rights (CCWP-HR)
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
Summary of Submission
In June 2023, ICANN published the Amendments to the Base gTLD Registry Agreement (RA) and Registrar Accreditation Agreement (RAA) to Modify Domain Name System (DNS) Abuse Contract Obligations.
We welcome ICANN’s decision to release the document in its entirety, in line with Workstream 2 Recommendations on ICANN Transparency. This statement is made on our own behalf. We also endorse comments by the Non-Commercial Stakeholder Group (NCSG) and Non-Commercial Users Constituency (NCUC).
We urge for amendments within the definitions to make it clear that this will not be a slippery slope to allow for ICANN Contracted Parties to use the tool to address matters outside of ICANN’s remit. We also urge procedural safeguards that will allow registrants to have their rights respected and protected.