Public Comment

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Name: Nobuhisa Nishigata
Date:20 Jul 2023
Affiliation: Director, Computer Communications Division, Telecommunications Bureau, Ministry of Internal affairs and Communications of Japan
Other Comments

About the author of this comment:

Nobuhisa NISHIGATA (Mr.) is the Director of Computer Communications Division at the Ministry of Internal affairs and Communications (MIC-Japan). His responsibilities include the Internet - its operation and governance, oversight over the telecommunications businesses and reinforcement and decentralization of digital infrastructure (e.g. datacenter). Nobu also serves as i) Vice-chair for the OECD's Working Party on AI Governance (WP-AIGO) and ii) Representative of Japan for ICANN's Governmental Advisory Committee (GAC).

Nobu worked at the OECD from 2017 to 2021, serving as economist and policy analyst on AI. He was engaged in various work and publications – notably the scoping process and the development of the OECD AI Principles (adopted by the OECD Council in May 2019) and the creation of the OECD.AI Policy Observatory (launched in February 2020), among others.

Before that, Nobu has served in a wide range of senior functions within MIC-Japan since 1999, including the regulatory authority of telecommunications and broadcasting, as well as in the development of ICT strategies in Japan. Prior to the current appointment, Nobu served as the Secretariat for the Info-Communications Council within the Ministry and published recommendations for ICT policies toward 2030 and beyond (June 2022).

Summary of Attachment

Summary of Submission

MIC-Japan (Ministry of Internal affairs and Communications):

- Welcomes and highly evaluates the proposed amendment with clear stipulation of the additional obligations of Registries and Registrars,

- Requests that the ICANN org conduct periodical monitoring review on the implementation of the amendment and share the result within the community, which would help develop good practices against DNS Abuse,

- (Regarding the RA amendment) requests that the ICANN org or the responsible parties provide a good format of the report on malicious conduct to help Registries take actions when deemed necessary,

- (Regarding the RAA amendment) points out a remaining unsolved issue to prevent malicious registrants from “hopping” around the Internet - the way malicious registrants survive, and illegal activities prevail on the Internet. As stated in the ICANN75 GAC Communique, RAA 3.18.1 is not clear enough to present a case of ICANN compliance or to help Registrars appropriately handle the reports on illegal activities. MIC-Japan requests that ICANN org and the contracted parties continue the discussion to solve this issue.