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Name: Fabien Betremieux
Date: 18 Jul 2023
Affiliation: Governmental Advisory Committee (GAC)
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
Summary of Submission
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 timely and relevant and, when adopted, will represent an important first step forward to combat DNS Abuse. The GAC supports the proposed amendments as a general matter, though invites ICANN org and the CPH NT to consider some specific issues related to the text of the amendments. In light of the ongoing threat that DNS Abuse poses to consumers and the public and private sectors, it is imperative that the improved contracts are swiftly adopted following the completion of the Public Comment process. The GAC looks forward to engaging in subsequent work with the multistakeholder community on DNS Abuse after the amendments are adopted. This work should include Policy Development Processes (PDPs) to further inform the updated RA and RAA, as well as other work on outstanding issues to address prior to the next application round for New gTLDs.
The GAC offers these comments as a contribution to the Public Comment process. We would be happy to have further dialogue with ICANN org and the Contracted Parties to elaborate on any of the above points.