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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Date:19 Jul 2023
Summary of Attachment

The file is my Public Comment, summary of which is described in "Summary of Submission".

Summary of Submission

I welcome the RA and RAA provisions requiring prompt action against DNS Abuse. However, the DNS Abuse definition currently only includes malware, botnets, phishing, etc., and doesn't cover content-related illegal activities like pirate sites. I ask for this definition to be expanded to include such activities.

Internet piracy is a severe issue, causing damages of about 2 trillion yen to Japanese content in 2022, with significant distress caused to manga artists. My work intended for youth is being illegitimately published with obscene ads on pirate sites.

"Domain hopping", the quick changing of domain names to dodge detection, is globally prevalent and exacerbates the damage from pirate sites. It crosses national boundaries, making individual responses and national laws and regulations insufficient. Collaboration of registries and registrars managing domains is critical to combat this, and the global rules imposed by the RA and RAA are effective.

ICANN, responsible for overseeing the safe operation of the Internet, should control blatantly illegal activities like the operation of pirate sites, while respecting digital freedoms.

Therefore, we call on ICANN to quickly include content-related illegal activities, like pirate site operations, in the activities requiring "prompt implementation of the appropriate mitigation action(s)" under the RA and RAA.