Although I served as a member, I am not speaking for the CCT Review Team. So what was my thinking in supporting these recommendations?

ICANN committed to engender competition, consumer choice and consumer trust in the DNS; check the AOC. The review team was chartered to see how well competition, choice, and trust are holding up and what to do if threats to conservation are uncovered. 

We are clear the product of the concession is complicit in doing harm to end users.  Defrauded end users lose trust. Abnormal extraction of value from end users causes them to think there is a breakdown in the security of the DNS.  Taken together, this development devalues competition objectives, undermines consumer trust and suppresses consumer choice.  

Mitigating systemic harms require systemic action. How we address harm at source when the harm, on its face, is an extension of an ordinary business process?  Some of us thought a product liability framework may not be the right approach but certainly elements of that thinking could be useful for mitigation.  

We could avoid capricious compliance action, systematically privilege registrants who rent for non-fraudulent use and incentivize contracted parties to go beyond current commercial practice to winnon out registrant fraudsters. 

The CCT outlined a very modest framework proposal. Rejected. Let's see a better mousetrap then. 

Carlton 

==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Process, Governance, Assessment & Turnaround

=============================


On Fri, 15 Sept 2023 at 17:20, Karl Auerbach <karl@cavebear.com> wrote:

In order to avoid reading the actual text (yes, I am lazy) what is the definition of "DNS security abuse"?

The reason I ask is that I've seen the phrase "DNS abuse" (absent the word "security") tossed about to whine (yes I am being hyperbolic and pejorative) about things such as "this or that practice annoys my cat" or "go to website abc.def.tld and buy solid gold 1kg bars for $1 each."  The first is simply out of ICANN's scope and the second probably violates fraud/misrepresentation laws in pretty much every country and ought to be beyond ICANN's scope.  I would put anything that is covered by national and international trademark law outside the umbra or penumbra of the word "security".

On the other hand it would, to my mind, be quite within ICANN's scope to knock registr* bodies and TLD server operators if they do bad things, like leaving logins open via telnet (clear text passwords) or are running on easily penetrated foundations such as (let me pick a crazy example) Windows 95.

    --karl--

On 9/15/23 10:58 AM, Carlton Samuels via At-Large wrote:
If you missed it, after a year in pending status, the ICANN Board just voted to reject Recs 14 & 15 from the CCT Review.  These were offered for mitigating systemic DNS security abuse. 
 
#14 recommends amendments offering incentives - inclusive of financial ones - in the [RA/RAA] Agreements for the contracted parties adopting proactive anti-abuse measures. Nothing too heretical. 

#15 recommends amendments to [RA/RAA] Agreements that establish thresholds of abuse at which compliance inquiries are automatically triggered and a higher one at which registrars and registries are presumed to be in default of their agreements. 

We went on to recommend a community-developed DNS Abuse Dispute Resolution Policy (DADRP) if ICANN Compliance falls asleep on the enforcement job. [The text delicately eased into that like only "...if the community determines that ICANN org itself is ill-suited or unable to enforce such provisions."] 

In my own view #14 is something regulators do with concessionaires time and again. Even the "light touch and by suasion" telecoms ones I know well in my home region. 

Our ICANN don't play that!

Carlton   
==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Process, Governance, Assessment & Turnaround

=============================


On Thu, 14 Sept 2023 at 20:33, Barry Shein via At-Large <at-large@atlarge-lists.icann.org> wrote:

As a company which provides email and other internet services maybe if
the new gTLDs agreements included some serious commitment to avoid
allowing the use of these gTLDs for massive spamming and phishing etc
maybe the service providers would have been more enthusiastic about
acceptance.

Unfortunately the opposite is true and many of these new gTlDs can
safely be blocked in entirety, they just spew spam etc, with no
customer complaints.

I'll guess these new gTLD registrars/registries would complain that's
not equitable since it's not required of other TLDs.

Which is all a very nice argument to make sitting in an airless room
somewhere.

So instead they tend to get blocked and ignored, or at least marked
"suspicious" by spam filters, but equitably!

If I had a nickel for every ISP who said or recommended "oh just block
all .pick-a-nGTLD, you and your customers will be happier"...

--
        -Barry Shein

Software Tool & Die    | bzs@TheWorld.com             | http://www.TheWorld.com
Purveyors to the Trade | Voice: +1 617-STD-WRLD       | 800-THE-WRLD
The World: Since 1989  | A Public Information Utility | *oo*
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