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.

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Submissions for this Proceeding

Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations

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Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Interested Lawyers
14 July 2023

Submission Summary:

We welcome the revision of the RAA and RA to define DNS Abuse and to specify the measures to be taken by registrars and registries in the event of DNS Abuse. We hope that registrars and registries will comply with the revised RAA and RA in the future.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Tucows
13 July 2023

Submission Summary:

Tucows appreciates the hard work of the Contracted Party House and ICANN Org negotiating teams in drafting amendments to the gTLD base Registry Agreement and 2013 Registrar Accreditation Agreement that define DNS Abuse and set requirements for Contracted Parties when presented with actionable evidence that a domain name is being used for DNS Abuse. We believe that these amendments will benefit the whole Internet.

We are pleased that the ...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - (RySG), Registries Stakeholder Group
13 July 2023

Submission Summary:

The Registries Stakeholder Group (RySG) appreciates and welcomes the opportunity to provide a comment in support of these proposed amendments. Like our colleagues in the Registrar Stakeholder group, whose comment to this process we both support and appreciate, we recognize the significance and importance of these amendments to our agreements with ICANN. We believe they represent a vital step in both our members’, and the community’s efforts to...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Castex, Lucien
12 July 2023

Submission Summary:

A clarified scope is a premise to tackling what we are trying to mitigate and these amendments to the Base gTLD RA and RAA are a welcome development.

The expression “actionable evidence” could be further clarified to ensure a consistent and effective application.

Confirmation of reporting to the notifier is a useful addition to improve trust and transparency of the process.

The adoption of these amendments would be an achiev...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - M3AAWG - The Messaging, Malware and Mobile Anti-Abuse Working Group
12 July 2023

Submission Summary:

M3AAWG welcomes the Contracted Party House’s consideration of long overdue changes to the Base gTLDs Registry Agreement (RA) and the Registrar Accreditation Agreement (RAA) related to the pertinent issue of DNS Abuse. While we are happy to see this effort, we would like to note that this necessary step should be part of a coordinated effort to address DNS Abuse now and going forward. Individually, the proposed changes are insufficient to addre...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Japan Publisher’s Manga Anti-Piracy Conference (“JPMAC”)
12 July 2023

Submission Summary:

We welcome this revision of the RAA and RA to require registrars and registries to promptly take the action reasonably necessary to (or contribute to) stop or disrupt DNS abuse by registered domain names in the event of DNS abuse. This is an important first step by ICANN to improve the Internet environment.

In this revision, the definition of DNS abuse is limited to security-related matters. However, as stated by a speaker at the ICANN 7...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Amazon
11 July 2023

Submission Summary:

Amazon supports the proposed amendments and is encouraged by the process by which they were developed.

The amendments clarify that registrars must promptly mitigate DNS abuse upon receipt of an actionable abuse report. While most registrars already take such action, this additional clarity will enable ICANN Compliance to better enforce abuse provisions and help ensure no registrars are facilitating abusive behavior. The amendments also p...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - RrSG
07 July 2023

Submission Summary:

The RrSG recognizes the importance of these amendments and supports them as a vital next step in the ICANN community’s efforts to address DNS Abuse. The RrSG urges the amended wording of the RAA, the RA, and the Advisory to remain as currently drafted. These amendments represent significant efforts between ICANN and CPH, and any proposed changes should be considered by future policy efforts rather than resulting in changes to the amendments or...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Nominet UK
07 July 2023

Submission Summary:

As operator of the .cymru and .wales TLDs we wish to provide the following feedback in relation to the proposed contract amendments to the base gTLD registry and registrar accreditation agreements.

According to the DNS Abuse Institute Compass reporting on DNS Abuse, our TLDs currently have zero observed DNS Abuse. In cricketing terms we do not trouble the scorers. See: https://dnsabuseinstitute.org/dnsai-compass/.

These proposed c...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Zutah, Prince Andrew Livingstone
06 July 2023

Submission Summary:

The issue of DNS abuse, which includes activities like phishing, malware distribution, and spam, is a significant concern for internet users and organizations. Promptly taking appropriate mitigation actions against domains involved in DNS abuse is generally considered a positive step to protect users and maintain the integrity of the online ecosystem.

In many cases, contracted parties (such as domain registrars or hosting providers) have...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - AFRALO
04 July 2023

Submission Summary:

The concept of DNS abuse is broad. DNS abuse facilitates cyber attacks and as such everyone in the DNS chain must be accountable. Thus foresaid, a clear model needs to be implemented to manage DNS processes as gTLDs are used as the first asset to conduct cyber crime.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Olorundare, James
28 June 2023

Submission Summary:

I concur. this will eliminate or reduce abuse.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - TLD Registry Limited OY
26 June 2023

Submission Summary:

TLD Registry Limited OY is the Registry Operator for xn--3ds443g (在线) and xn--fiq228c5hs (中文网).


TLD Registry Limited OY welcomes and supports the proposed amendments to the gTLD Registry Agreement and Registrar Accreditation Agreement.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - DE LA CHAPELLE, Bertrand
14 June 2023

Submission Summary:

After long and often conflictual discussions around the very notion of DNS Abuse, these concise and balanced amendments represent significant progress and deserve to be welcomed by all actors. Within a clearly defined scope of abuses, they set very specific, yet flexible, responsibilities for contracted parties when dealing with abuse reports. The Secretariat of the Internet & Jurisdiction Policy Network (I&JPN) therefore strongly enco...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Pfeifer, Matthias
06 June 2023

Submission Summary:

ICANN is not doing enough to protect the PI. gTLDs SHOULD be forced to take serious actions on abused domain names in theyr zones.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - HOSSEN, MD IMRAN
30 May 2023

Submission Summary:

I fully support the proposed amendments to the gTLD Registration Agreement (RA) and 2013 Registrar Accreditation Agreement (RAA) aimed at strengthening DNS Abuse mitigation. These amendments provide a comprehensive framework to promptly address malware, botnets, phishing, pharming, and spam.

The provisions regarding abuse contacts and reporting mechanisms are commendable. Requiring accessible abuse contacts and offering webforms for repo...