Let's say bulk means 50 registrations before alarms start to sound.

Then the criminals will simply start pulling data from fake ID generator APIs and connect those to the registrar/reseller APIs and generate new unique RNH data/contacts.  If that sounds out of the realm of possibilities, consider I have already seen criminals doing this to avoid detection in 2018. Every BEC fraud domain had a unique registrant and they had registered 200 domains total. Their OPSEC was pretty good on the registrant side of things, on the technical infrastructure side, it was an absolute mess and very easy to track down and shut down such domain names.

Best,
Theo

On Tue, Apr 5, 2022, at 12:40 PM, John McCormac via CPWG wrote:
On 05/04/2022 12:25, Michele Neylon - Blacknight wrote:
> John

> But what is your definition of “bulk”?


It is a very tricky question, Michele,
I don't have an exact definition yet.

There can be a lot of activity going on with a gTLD that might appear to 
be bulk registrations but without WHOIS data to measure the 
concentration of registrations, a spike due to a registry or registrar 
promotion might be considered "bulk". The concentration (new domain 
names to registrants) might help.

> How many domains registered at once constitute “bulk”?

> 10?

I've definitely registered this many at a time across TLDs for brand 
protection purposes.


> 100?

> 1000?

> Over what period of time?

> Minutes?

> Hours?

> Days?

It would have to be over a few months at least. Otherwise celebrity and 
event driven registrations and speculative bubbles will get lumped into 
the set.

> Can the “definition” be applied to all TLDs?

Not unless there is a data element. It would be better to approach it on 
a TLD-specific basis that takes the performance of the TLD into account. 
Some TLDs may not have bulk registration issues.

> I’d argue that there’s a massive difference between say 100 domains 
> being registered in .bank vs in .store (as a silly example)

Agreed. Heavy discounting is now an established feature of many gTLDs. 
The problem is that the absence of WHOIS data and registration patterns 
makes it a lot more difficult to identify abusive registrations. Without 
heavy discounting, some new gTLDs would have to spend a lot more money 
on marketing their gTLD in a highly competitive market and would end up 
with far fewer registrations than they have now.

There was a recommendation in the CCT report that ICANN track pricing 
data. If ICANN had this kind of data to hand then it would be very 
helpful in defining bulk registrations and identifying trends that are 
direct results of heavy discounting. It still gets back to the problem 
of identifying what registrations are registered for malicious purposes 
and that's getting into Precog/Minority Report territory where the 
software and technology is just not good enough to guess the intent of 
all registrants.

Regards...jmcc


> Regards

> Michele

> --

> Mr Michele Neylon

> Blacknight Solutions

> Hosting, Colocation & Domains

https://www.blacknight.com/ <https://www.blacknight.com/>

https://blacknight.blog/ <https://blacknight.blog/>

> Intl. +353 (0) 59  9183072

> Direct Dial: +353 (0)59 9183090

> Personal blog: https://michele.blog/ <https://michele.blog/>

> Some thoughts: https://ceo.hosting/ <https://ceo.hosting/>

> -------------------------------

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