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.


  • English

Name: Ephraim Percy Kenyanito
Date:20 Jul 2023
Affiliation: Cross-Community Working Party on ICANN and Human Rights (CCWP-HR)
Other Comments

Summary of Submission

In June 2023, ICANN published the Amendments to the Base gTLD Registry Agreement (RA) and Registrar Accreditation Agreement (RAA) to Modify Domain Name System (DNS) Abuse Contract Obligations.

We welcome ICANN’s decision to release the document in its entirety, in line with Workstream 2 Recommendations on ICANN Transparency.  This statement is made on our own behalf. We also endorse comments by the Non-Commercial Stakeholder Group (NCSG) and Non-Commercial Users Constituency (NCUC).

We urge for amendments within the definitions to make it clear that this will not be a slippery slope to allow for ICANN Contracted Parties to use the tool to address matters outside of ICANN’s remit. We also urge procedural safeguards that will allow registrants to have their rights respected and protected.