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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The attachment is in lieu of completing this Public Comment Proceeding form.
CleanDNS welcomes ICANN’s initiative to address DNS abuse through targeted policy development. We strongly support the prioritisation of two key issues: Associated Domain Checks and Unrestricted API Access for High-Volume Registrations.
Associated Domain Checks: Malicious actors rarely use a single domain. CleanDNS advocates for registrars to investigate domains linked to abusive accounts, using a “pivot” approach to disrupt coordinated abuse. This method, already used by many CleanDNS clients, should be standardised.
Unrestricted API Access: Ungated API access enables large-scale automated registrations, often used for phishing and malware. CleanDNS supports introducing risk-based friction for new or untrusted accounts before granting bulk registration access. Policies should distinguish between retail and wholesale use to avoid disrupting legitimate business models.
We also highlight the role of registries in identifying abuse patterns across TLDs, support community-led DGA botnet mitigation, and call for robust data collection and transparency. Policies must respect registrant rights, with clear recourse for mistaken suspensions.
CleanDNS opposes a phased PDP approach, favouring two narrowly scoped PDPs with strong GNSO oversight to ensure timely and effective outcomes.