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The file is our Public Comment to the proposed amendments.
We welcome the Amendments draft to the gTLD RA and 2013 RAA. Overall, we highly appreciate the draft but find it inadequate in some respects. We would like to make our comments from the position of engineers who support the internet infrastructure in Japan, including DNS and domain name resources, also in the position of engineers who voluntarily work with the Manga piracy site countermeasure team in Japan (i.e. as a pro-bono activity).
The Amendments define DNS Abuse as “malware, botnets, phishing, pharming, and spam”. It is a practical definition and we appreciate it. However, such definition does not fully cover all types of possible DNS and domain name resources abuses by Registered Name Holder. We also agree with proposed RAA Article 3.18 Amendments. However, we point out that Article 3.18 of the RAA has no deterrent effect against DNS abuse and that deterrence can only be achieved if Articles 3.7.7.2 and 3.7.8 are complied with, and therefore Article 3.18 has very strong links with Articles 3.7.7.2 and 3.7.8.
We further note that it is important that the Registered Name Holder verification program in the "RDDS ACCURACY PROGRAM SPECIFICATION" is implemented by each Registrar in accordance with RAA 3.7.8, in order to prevent DNS abuse.
We understand that the purpose of the proposed Amendments of RA and RAA is to strengthen the governance of domain name resources, and agree with it. As a complement, we also request that a clause on the number of DNS abuse incidents per-registry and per-registrar be added to the Domain Abuse Activity Reporting, and that revisions to ccTLD also be considered in the same way to strengthen governance.