Hello, On behalf of the Registrar Stakeholder Group (RrSG), please find below a comment on the Competition, Consumer Trust, and Consumer Choice Review Team – New Sections to Draft Report of Recommendations: The Registrars (RrSG) have taken notice of the proposals contained in the document entitled Competition, Consumer Trust and Consumer Choice (CCT): New Sections, of November 27, 2017 (the New Sections document). The RrSG is concerned about the proposal to create a special DNS Abuse Dispute Resolution Procedure (DADRP). The RrSG members agree with the objections raised in section 6.1 in the New Sections document to this proposal. The Stakeholder Group agrees that the factual basis used to justify the recommendation is missing. Seeking to mitigate DNS abuses through registry-registrar relationships is ineffective, and from a standpoint of causal responsibility, morally objectionable. The RrSG agrees that the solution should be to improve ICANN Compliance rather than creating a new dispute resolution procedure. The RrSG observes moreover that the invention of new accountability mechanisms to police DNS abuse is outside of the mandate of the Review team. The RrSG urges the ICANN community to frame the issue of the causal agents of DNS abuse properly, to collect relevant data, and to consider the problems associated with DNS abuse in a more deliberate and focused fashion. Kind regards, Zoe Bonython RrSG Secretariat