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 - Intellectual Property Constituency
20 July 2023

Submission Summary:

These comments are submitted by the Intellectual Property Constituency (“IPC”), whose membership includes and represents trade associations, large multinational corporations, as well as small businesses and individuals.

The IPC applauds the efforts of ICANN and Contracted Parties to negotiate the proposed amendments to the Registrar Accreditation Agreement (“RAA”) and Base gTLD Registry Agreement (“RA”) to enhance Domain Name System (“D...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - International Trademark Association (INTA)
20 July 2023

Submission Summary:

INTA supports the passage of the Amendments. We understand that they are an important step in clarifying the obligations of contracted parties to act upon credible reports of domain name abuse. We also understand that there is much more work to be done by the Community. We have concerns that some of the language in the Amendments is too vague and may cause serious problems of interpretation. To the extent that more precision could be ...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - ICANN Business Constituency (BC)
20 July 2023

Submission Summary:

The BC greatly appreciates the efforts of contracted parties and ICANN Org for their good-faith negotiations on amendments to the Registrar Accreditation Agreement (RAA) and base gTLD Registry Agreement (RA) on the important issue of DNS Abuse. These proposed amendments are a good first step, represent meaningful progress, and will serve as a solid foundation for what we hope will be a long-term effort by industry to address this persistent an...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Cross-Community Working Party on ICANN and Human Rights (CCWP-HR)
20 July 2023

Submission Summary:

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 (...


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

Submission Summary:

The DNS Abuse Institute (DNSAI) appreciates the chance to comment on DNS Abuse contractual changes and commends ICANN and parties for their swift action. DNSAI fully supports the amendments, particularly the requirement to mitigate malicious domain registrations. They value the flexible approach to abuse mitigation and the ability for ICANN to enforce actions against non-compliant parties. DNSAI welcomes the use of web-form based reporting and...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - eco – Association of the Internet Industry
20 July 2023

Submission Summary:

The members of eco – Association of the Internet Industry and its topDNS initiative express their full support for the proposed amendments, emphasising the need for a clear definition of DNS abuse and the importance of confirming abuse reports. They appreciate the threshold of "meaningful evidence" for taking appropriate mitigation action, given the limited scope for action at the DN level. Adoption of these amendments will send a strong signa...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Nishigata, Nobuhisa
20 July 2023

Submission Summary:

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 am...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Technology Verification Team, Working-Level Forum for Anti-Piracy of Japan
20 July 2023

Submission Summary:

We welcome the Amendments draft to the gTLD RA and 2013 RAA. Overall, we highly appreciate the draft but find it inadequate in some respects. We would like to make our comments from the position of engineers who support the internet infrastructure in Japan, including DNS and domain name resources, also in the position of engineers who voluntarily work with the Manga piracy site countermeasure team in Japan (i.e. as a pro-bono activity).&n...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Safer Internet Asossiation(SIA)
20 July 2023

Submission Summary:

We, the volunteers from the private sector who are working to solve various problems on the Internet for its continuous and healthy growth, know that it is difficult to solve problems on the internet in a specific industry alone. From the perspective that all companies involved in the Internet should contribute their wisdom and efforts to solve the problems, rather than leaving them to other levels, we believe that the revision of the RAA and ...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Policy staff in support of the At-Large Community, At-Large Advisory Committee (ALAC)
19 July 2023

Submission Summary:

DNS Abuse has been discussed and debated within ICANN for well over a decade. The ALAC has repeatedly heard registrars say that ICANN Contractual Compliance should take action against “bad actors” and ICANN Contractual Compliance saying that they did not have the tools to enforce compliance by such “bad actors”.

It was evident that the only way to address this stalemate was for the Contracted Parties and ICANN Org to sit down and ensure ...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Namecheap, Inc.
19 July 2023

Submission Summary:

Namecheap provides this comment in support of the amended RAA, RA, and draft advisory, and encourages that they be adopted in their current form. Any significant changes to the amendments, and importantly the advisory, could jeopardize the chances of approval through the complicated voting processes for the RrSG and the RySG. Any proposed changes to the advisory would best serve as the basis for future policy work.


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Forum of Incident Response and Security Teams (FIRST)
19 July 2023

Submission Summary:

Statement from the Forum of Incident Response and Security Teams (FIRST).


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - AKAMATSU, KEN
19 July 2023

Submission Summary:

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...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Security and Stability Advisory Committee (SSAC)
18 July 2023

Submission Summary:

The SSAC wishes to thank and commend the contracted parties and ICANN org staff for their initiative and efforts to address DNS Abuse by updating relevant contracts to include enforceable provisions and obligations for contracted parties. We look forward to seeing them implemented and further evolved over time. The SSAC provides three comments to the proposed amendments:

1) The SSAC strongly supports the goal to enhance obligations again...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Brazilian Association of Software Companies (ABES), AR-TARC, Governance Primer
18 July 2023

Submission Summary:

The Brazilian Association of Software Companies (ABES), AR-TARC, and Governance Primer, would like to signal support to the amendments being carried out by ICANN org. and the ICANN Contracted Parties. We understand these amendments to consist of targeted and reasonable modifications that will provide additional clarity on how abuse is to be dealt with moving forward. This is a strong first step towards making the Internet safer and adequately ...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Governmental Advisory Committee (GAC)
18 July 2023

Submission Summary:

The Governmental Advisory Committee (GAC) welcomes the proposed amendments to the generic Top-Level Domain (gTLD) Registry Agreement (RA) and 2013 Registrar Accreditation Agreement (RAA) (collectively, the “Agreements”) to address Domain Name System Abuse (DNS Abuse).


The GAC views the amendments as a significant achievement by ICANN org and the Contracted Parties House Negotiating Team (CPH NT). The proposed amendments are ti...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Bedser, Jeffrey
18 July 2023

Submission Summary:

CleanDNS would like to thank ICANN and the contracted parties for the opportunity to provide feedback on the proposed amendments and we congratulate all parties on the exceptional speed and commitment to anti-DNS Abuse efforts that has been shown so far in this process. CleanDNS welcomes the proposed amendments to both the base Registry Agreement (RA) and the Registrar Accreditation Agreement (RRA). We believe that the agreed upon wording stri...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - iQ Global AS (iQ)
18 July 2023

Submission Summary:

iQ is a Norwegian registered company that specializes in domain abuse and reputation management services.

IQ’s client base includes Registry Operators, Registrars, Hosting providers and entities in the domain name and internet infrastructure industries seeking to monitor and manage their namespace for suspicious behavior including DNS Abuse.

iQ welcomes the proposed amendments for the RA and RAA. In our view, in addition to the wor...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - Non-Commercial Stakeholder Group (NCSG)
14 July 2023

Submission Summary:

The NCSG believes “DNS abuse” is an ambiguous term and should not replace "security threat". The current term “Security threat” amply defines the issue, which is the threat to the DNS

We do not believe spam should be included in the definition of security threat as Email protocols are used to deliver spam, not the DNS.

We are concerned about the open-ended nature of the mitigation measures included in the revisions. There is a risk...


Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations Submission - i2C, Internet Infrastructure Coalition
14 July 2023

Submission Summary:

i2Coalition is in full support of the proposed amendments presented as a welcome and important step in the ongoing fight against DNS Abuse. We urge their adoption as written. They provide important clarifications on definitions, scope, and responsibilities as well as on implementation.