Name: Nick Wenban-Smith
Date: 7 Jul 2023
Affiliation: Nominet UK
Original Public Comment: Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations
Summary of Submission
As operator of the .cymru and .wales TLDs we wish to provide the following feedback in relation to the proposed contract amendments to the base gTLD registry and registrar accreditation agreements.
According to the DNS Abuse Institute Compass reporting on DNS Abuse, our TLDs currently have zero observed DNS Abuse. In cricketing terms we do not trouble the scorers. See: https://dnsabuseinstitute.org/dnsai-compass/.
These proposed contract amendments, if approved, would therefore not have any significant impact upon us.
Nonetheless we wish to express our support for this community led initiative to create a global standard for a minimum response level when registries and registrars are presented with compelling evidence of DNS Abuse. The multistakeholder community needs to demonstrate the capacity and willingness to act in the global public interest, in line with ICANN's core mission.