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Name: Brian King
Date: 20 Jul 2023
Affiliation: Intellectual Property Constituency
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
Submitted by Brian King (IPC VP) on behalf of the IPC.
Summary of Attachment
The IPC appreciates the opportunity to submit: a) constructive comments on the proposed amendments; b) redlines to the RA and RAA for consideration; and c) redlines to the Advisory for consideration.
Summary of Submission
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 (“DNS”) abuse mitigation. These amendments generally represent progress from requirements in the existing contracts.
Without taking away from the above sincere expression of appreciation for these efforts, and the IPC’s support for ratifying the proposed amendments, the IPC does wish to outline some areas where it believes additional improvements could be considered. These are discussed below and are reflected in the attached “cumulative redline” that contains additional suggested amendments integrated with the existing proposed amendments.