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.

Контент доступен только на следующих языках

  • English

Name: Tatsuo Ninoseki
Date: 12 Jul 2023
Affiliation: Japan Publisher’s Manga Anti-Piracy Conference (“JPMAC”)
Email: Redacted
Summary of Attachment

- The 1st file is JPMAC's Public Comment, summary of which is described in "Summary of Submission"

- The 2nd file is a chart indicating examples of domain hopping, which is referred to in the column 5 of the Public Comment.

- The 3rd file is additional feedback on verification of the identity of domain registrants.

Summary of Submission

We welcome this revision of the RAA and RA to require registrars and registries to promptly take the action reasonably necessary to (or contribute to) stop or disrupt DNS abuse by registered domain names in the event of DNS abuse. This is an important first step by ICANN to improve the Internet environment.

In this revision, the definition of DNS abuse is limited to security-related matters. However, as stated by a speaker at the ICANN 77 Prep week, this revision should be the first step and it is necessary for the ICANN community to discuss content related abuse going forward.

Legal assessment of content related abuse may vary based upon jurisdiction. However, the act of dead copy and wide distribution of commercial copyrighted works of others without the right holder's permission is illegal in any jurisdiction. Internet piracy, which makes large numbers of dead copies of manga available for free on the Internet, is malicious, while the damage it causes to rights holders is serious and difficult to remedy. It is estimated that the annual damage caused by Internet piracy in Japan alone exceeds approx. US$36.4 billion in 2022, and the number of accesses from Japan to the top 10 Japanese-language pirate sites (mainly located abroad) in December of the same year was approximately 200 million (The number of accesses worldwide is far more than this.).

Internet piracy operators need assistance of third-party intermediaries such as hosting servers, registrars, ad-serving companies, and CDNs to make a profit on the Internet. Although many of these third-parties are gradually taking steps to cooperate with right holders, some intermediaries are still providing loopholes for pirate sites. In this context, the role that can be played by registries and registrars, who are required to sign contracts with ICANN, is critical. We strongly hope that the discussion will continue to include internet piracy as a case in which registries and registrars are required to take action.