Dear Jonathan, I am aware I am a newcomer to this work group. My apologies if my comments are already been discussed. I have a long time experience within the ICANN eco system, both as registrar and registry operator. Today I am working for a company offering DNS abuse monitoring service for a significant number of TLDs. ALAC/At-Large has proposed recommendations towards ICANN org, registries and registrars in how to act on DNS abuse. IMHO, I believe one "entity" is missing; the Reputation Block List providers. The RBLs are the present "tool box" for registries, registrars and the DAAR project. Based on my professional experience, we don't know the logic the RBLs use for identifying and categorisation of suspicious behaviour. I have multiple examples of domain names being categorised differently by the RBLs. I am ware of that some RBLs have tuned their business for a certain category (example ANTI-PHISHING WORKING GROUP focus on phishing), but would expect that other RBLs that investigate phishing should report this for the same domain name as APWG identify. IMO what the community need is a more information about how the RBLs work, more transparency in how they operate. If possible, common criteria for identifying the abuse categories would be preferred. Since the data from the RBLs are used by the entities that can act on abuse, the RBLs should include in their feed a much details as possible. Today the information given is (in general) the domain name and the abuse category (example.TLD: Phishing). Regards, Steinar Grøtterød From: CPWG <cpwg-bounces@icann.org> on behalf of Jonathan Zuck <JZuck@innovatorsnetwork.org> Date: Wednesday, 3 February 2021 at 15:50 To: "cpwg@icann.org" <cpwg@icann.org> Subject: [CPWG] FW: Engagement on DNS Abuse Evin has suggested that I had, perhaps, NOT forwarded this to the group. Here’s the discussion thread, initiated by Keith Drazek on the Contracted Party House DNS Abuse Work Group. This includes, Joanna’s expression of mission creep concern. Jonathan Jonathan Zuck Executive Director Innovators Network Foundation www.InnovatorsNetwork.org From: Joanna Kulesza Sent: Wednesday, January 27, 2021 2:12 AM To: Maureen Hilyard; Jonathan Zuck Subject: Re: Engagement on DNS Abuse Great stuff Jonathan, as always. Feel free to share. If I were to add my two cents, I'd put these in the "pain points" section while these are of a more general nature. "From the discussions we've had within At-Large it is clear that the very scope and definition of DNS Abuse is a "pain point". This was also the take away from the discussions we've had with the invited guests from within and beyond the ICANN community. "DNS Abuse" as it is now defined in the proposed Framework affects the entire internet community of end users while being already covered by existing national and international norms and standards. Keeping these in mind the proposed definition and scope of DNS Abuse strikes as arbitrary: what were the criteria set for selecting these specific categories as DNS Abuse while leaving other potential categories out? This is particularly relevant with regard to our second concern: the proposed scope of DNS Abuse clearly crosses the content "picket fence" that the ICANN community had set for itself. Including IP infringement on equal footing with CSAM raises serious concerns among At-Large members. We are concerned not only with the very fact of the picket fence being crossed but also by the way in which this is being done. Does this mean we should finally abandon the well established yet always controversial narrative of a strictly technical infrastructure management? Once content is concerned, the existing and proposed practice fails to recognize international legal safeguards when it comes to restrictions put on individual freedoms. Whenever an individual liberty is to be restricted, due process must be ensured. The procedures proposed by the DNS Abuse framework fail to ensure e.g. a right to an effective legal remedy. While we realize this argument brings us back tot he general discussion on limits of ICANN's contractual jurisdiction, that is an argument we would be interested to during any upcoming DNS Abuse work. Only once these concerns relating to the scope of the definition of DNS Abuse can be addressed, can we focus on metrics and effective enforcement that will provide a fair and operational framework protecting the rights of end users." By all means to feel free to rephrase!:) What I'm arguing for is that for us to be able to "measure" DNS Abuse we should first clearly and transparently decide what it means. The current framework means the contracted parties are indeed trying to play a self-proclaimed internet police (militia?). Why did we presume DNS Abuse is CSAM and (in the same breath) fake Gucci bags but not hate speech and inciting violence? While we clearly would not have the answer ready, that is definitely a discussion we should have. The GAC might be interested in this as well (see last update from Veni on the ITU processes). Thanks for considering team! Best, J. W dniu 27.01.2021 o 01:39, Maureen Hilyard pisze: In your inimitable style. Love it. Send it. M On Tue, Jan 26, 2021 at 12:34 PM Jonathan Zuck <JZuck@innovatorsnetwork.org> wrote: Ladies, Here’s my draft response. Let me know what you think! Jonathan ============================================================= Hey folks! Thanks for reaching out. Joanna and I, for sure, would be willing to join you and I suspect others, as well, once we know the timing. With respect to the questions below, I’ll do my best to provide some initial responses but I suspect the first question might be pivotal. There seems to be a lack of real data on the topic and perhaps some additional objective research is the answers. We endeavored to begin this process, during the CCTRT (sadag-final-09aug17-en.pdf (icann.org), but obviously barely scratched the surface. Perhaps a more comprehensive study, funded by ICANN rather than the CPH or CSG might be in order? I know DAAR provides some answers but it seems to be more of a survey than an example of rigorous research. Specifically to your questions. What information do you use and how do you use it to assess DNS Abuse levels? This is obviously where we are weak. There doesn’t appear to be a great source for DNS Abuse “levels,” particularly because of the short time period over which a particular initiative takes place. A snapshot analysis doesn’t seem to get the full picture. The ALAC relies on the concerned raised by the GAC and the SSAC to fuel our belief that there’s more we should be doing. A recent report from Microsoft suggests the problem is bigger than we realize and David Taylor’s analysis of “responsiveness,” even among those who have signed onto the framework, seems damning. What are the ALAC’s pain points regarding DNS Abuse? Not sure to answer this in terms of how it’s handled inside ICANN or more generally from where our interests stems. To the latter point, we’re tasked with advancing the interests of those not represented by a constituency in the GNSO, namely those engaged in everyday use of the internet, as opposed to registrants. As the user base continues to grow, as we all desire, so too will the numbers of less sophisticated users, more easily duped by a phishing, malware or fraudulent advertising attack. As for the situation inside ICANN, the At-Large community have attempted to engage constructively as opposed to “attacking” the CPH, focusing instead on so-called “bad actors.” The first session was an attempt to bring the CPH and Contract Compliance into the same room to figure out where the holes are. What exactly are the relevant limits on Contract Compliance? We feel this is a question which comes up constantly and is never successfully or consistently answered. It seems to be an area in which the ICANN community is constantly chasing it’s tail. It would seem that the only real enforced contract provision is payment. I’m sure this is an exaggeration but it seems to be a repeated situation where that is ultimately what foils a “ bad actor” after YEARS of neglect, if not outright facilitation of abuse. The answer to THIS question should be a HIGH priority. It might just be agreeing to an interpretation of the contracts or it might require an amendment to the contracts but this issue needs to stop being a merry go round. Insufficient Transparency from Contract Compliance Contract Compliance undocumented endeavors at soft touch diplomacy with bad actors seem to need some better limits or, at least, transparency. For “the market” to play a role in this, knowing about legitimate complaints for every contracted party could help customers make better decisions about which businesses to use and help us better understand where policy development needs to take place. Deflection and Minimization of the Problem I would say that one “pain point” is that our efforts have been largely “trolled” by certain members of the CPH, rather than engaging constructively. EVEN our effort to conceive of some sort of end user education campaign, to take the pressure off the CPH, was trolled. Jim, not to put you on the spot but, during one conversation, you said you didn’t even understand why this was being discussed because it affects such a small percentage of registered names. To date, we have proposed: i. Better contract enforcement ii. More tools for Contract Compliance iii. DNS Abuse “threshold,” an idea that found some support among the CPH at one point iv. Predictive Analytics platform, perhaps financed by ICANN The At-Large community has absolutely no desire to over regulate or over tax the CPH and we understand most of the contracted parties, particularly those showing up to meetings, are trying to do well and continuously improve. That said, this notion that it’s somehow not “our place,” to be trying to help is nothing short of offensive. It is the active participation of the ALAC and GAC that enable the ICANN to portray itself as something other than a trade association. The At-Large mandate is to advance the interests of those MOST impacted by DNS Abuse. That said, we WELCOME suggestions on how better to engage with the CPH for constructive outcomes. Are you seeing practices from registrars or registries you find helpful? If we haven’t said it enough, the At-Large appreciates the efforts of those behind the Framework for DNS Abuse and the huge efforts that went into cooperation with law enforcement to track down COVID related abuse. We’d love to see the framework evolve to include specific commitments and metrics, however, for it to be something on which the community could truly rely. We hope these answers are constructive and not inflammatory as it is our intention to find the most effective ways to proceed to further minimize the incidence of DNS Abuse , in all its forms. Thanks for the opportunity to be part of your conversation. Maureen, Joanna & Jonathan From: Keith Drazek <kdrazek@verisign.com> Date: Friday, January 22, 2021 at 12:00 PM To: "maureen.hilyard@gmail.com" <maureen.hilyard@gmail.com>, Jonathan Zuck <JZuck@innovatorsnetwork.org>, "jkuleszaicann@gmail.com" <jkuleszaicann@gmail.com> Cc: "Brian F. Cimbolic" <BCimbolic@pir.org>, Jim Galvin <jgalvin@afilias.info>, Graeme Bunton <gbunton@tucows.com> Subject: Engagement on DNS Abuse Hello Maureen, Jonathan and Joanna, I hope you’re all doing well and staying healthy and safe. I am reaching out to you on behalf of the Contracted Party House DNS Abuse Working Group as we look ahead to ICANN 70 and the rest of 2021. The Contracted Party House (CPH) DNS Abuse Group is conducting outreach to our friends in other SO/AC/SG/Cs regarding DNS Abuse. As previously noted by the CPH, DNS Abuse comprises five categories: phishing, pharming, malware, botnets, and spam when it acts as a delivery mechanism for one of the other forms of DNS Abuse. We want to open a more direct dialogue to understand pain points, hear suggestions and identify common ground where we can work together to mitigate DNS Abuse. Is there a subset of the At-Large focusing on DNS Abuse questions that would be able to join the CPH DNS Abuse group on a call to discuss this topic? We want to encourage frank and productive discussions on the topic that lead to really informing our dialogues and actions. As a starting point, we propose the following questions to guide our discussion. Are there any other questions ALAC would like discuss?: What information do you use and how do you use it to assess DNS Abuse levels? What are the ALAC’s pain points regarding DNS Abuse? Are you seeing practices from registrars or registries you find helpful? Please let us know if a subgroup of the ALAC would be willing to join us. Our group meets regularly on Tuesdays at 1500 UTC. If so, please propose a Tuesday when you are available. Best regards, Keith Keith Drazek Vice President, Public Policy & Government Relations Verisign, Inc. +1-571-377-9182 Kdrazek@verisign.com -- Kind regards, Joanna Kulesza ------------------- Joanna Kulesza, PhD University of Lodz, Poland ICANN ALAC Vice Chair SOI: https://community.icann.org/display/atlarge/Joanna+Kulesza+SOI TT: @KuleszaJ _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). 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