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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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 that some contracted parties will simply find it expedient to respond harshly to DNS abuse reports (i.e. by simply disabling the domain).
Finally, we are generally concerned with the direction that ICANN and the contracted parties are going in doing bilateral negotiations to resolve very thorny policy issues. It could set a bad precedent.