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.

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Name: Sarah Wyld
Date: 13 Jul 2023
Affiliation: Tucows
Other Comments

Tucows appreciates the hard work of the Contracted Party House and ICANN Org negotiating teams in drafting amendments to the gTLD base Registry Agreement and 2013 Registrar Accreditation Agreement that define DNS Abuse and set requirements for Contracted Parties when presented with actionable evidence that a domain name is being used for DNS Abuse. We believe that these amendments will benefit the whole Internet.

Combatting DNS Abuse is essential to the health of the global Internet. Tucows is committed to mitigating DNS Abuse in our namespace and is proud to have co-authored the Framework on DNS Abuse and participated in the Negotiating Team for these amendments. We have published our own commitment to combatting DNS Abuse at Making the Internet Better.

We are pleased that the draft amendments formalize appropriate obligations and that ICANN Contractual Compliance confirms it now has the additional tools it has said it needs in order to enforce the contracts against Contracted Parties that refuse to take action to curtail DNS Abuse in their namespace.


Adding the term “DNS Abuse” with its definition  

It is crucial that Contracted Parties, ICANN, and other readers of the RAA and RA have a common understanding of the scope of the problem to be addressed. This is achieved in these amendments with the definition of DNS Abuse as “malware, botnets, phishing, pharming, and spam (when spam serves as a delivery mechanism for the other forms of DNS Abuse listed in this Section)” along with a reference to the further definitions of each of those terms in SAC115. 

Tucows supports this definition of DNS Abuse; its inclusion in the amended RA and RAA provides necessary clarity.


Updated methods to receive requests 

Each individual registrar and registry is best suited to determine the most effective method for it to receive reports of DNS Abuse. While some Contracted Parties may prefer to receive reports via direct email, others find webforms more helpful, as they can request specific pieces of information to be included in the submission (such as the reporter’s affiliation and contact details, or the specific URL where the DNS Abuse being reported is found), can require specific fields to be completed before the form can be submitted, can route different types of reports to different teams or support queues, and can easily provide a copy of the submitted form to the user. 

Tucows supports the inclusion of webforms as a report submission method in the amended contracts.


Expectation of action following report submission

One of the primary gaps raised by ICANN Compliance in the existing RA and RAA obligations relating to DNS Abuse was requirements for what action(s) the Registrar or Registry Operator must take upon receipt of a report. Prior to these changes, the RAA included only that the “Registrar shall take reasonable and prompt steps to investigate and respond appropriately to any reports of abuse,” and the RA required registries to assess if domains were being used for specific kinds of security threat and maintain reports on the number of such threats and actions taken as a result of those security checks. 

The amendment text requiring appropriate mitigation actions provides the tools which ICANN Compliance requested to enforce these obligations. The changes are correctly focused on disrupting or mitigating the DNS Abuse with an understanding that different types of DNS Abuse may require different types of responses. The changes also respect the different positions of the Registrar and Registry Operator, requiring the Registrar to take action while allowing the Registry to either act directly or refer the issue, along with the evidence, to the Registrar for action. 

Tucows supports the added requirement that, upon receipt of a report, the Registrar or Registry Operator must provide confirmation of receipt of the report to the reporter; this can help the reporter understand the status of their request and be assured that the request was successfully submitted. 



These amendments are an important step forward, demonstrating that Contracted Parties are committed to fighting DNS Abuse and being contractually obligated to take appropriate action when such DNS Abuse is found. Tucows believes that the changes will improve the health of the Internet overall and we look forward to voting in favour of these amendments. Tucows supports these Amendments, and the RrSG comment on these Amendments. Tucows will vote in favour of the Amendments, and looks forward to “get out the vote” efforts to ensure that these Amendments are incorporated to the base RA and 2013 RAA.

Summary of Submission

Tucows appreciates the hard work of the Contracted Party House and ICANN Org negotiating teams in drafting amendments to the gTLD base Registry Agreement and 2013 Registrar Accreditation Agreement that define DNS Abuse and set requirements for Contracted Parties when presented with actionable evidence that a domain name is being used for DNS Abuse. We believe that these amendments will benefit the whole Internet.

We are pleased that the draft amendments formalize appropriate obligations and that ICANN Contractual Compliance confirms it now has the additional tools it has said it needs in order to enforce the contracts against Contracted Parties that refuse to take action to curtail DNS Abuse in their namespace.

These amendments are an important step forward, demonstrating that Contracted Parties are committed to fighting DNS Abuse and being contractually obligated to take appropriate action when such DNS Abuse is found. Tucows believes that the changes will improve the health of the Internet overall and we look forward to voting in favour of these amendments. Tucows supports these Amendments, and the RrSG comment on these Amendments. Tucows will vote in favour of the Amendments, and looks forward to “get out the vote” efforts to ensure that these Amendments are incorporated to the base RA and 2013 RAA.