Dear all, I agree that CENTR is raising (very) valid points here. I also disagree with some of the definitions, arguments, and propositions made in the report from an academic angle. (e.g. as John mentioned, the lumping together of different TLD categories; the conflation of different classes of abuse — some are private disputes, some are not, etc.) However, we should also note that some of their observations have been made over and over again. Within ICANN: SSR1, SSR2, CCT, etc. as well as outside: academia, governments, etc. In short: there is a lack of controls in the system, there is too little oversight (that does anything), too few requirements for CPs, too many loopholes, lack of consistency, lack of due care and due diligence. All the best Laurin

On Mar 31, 2022, at 14:40, John McCormac via CPWG <cpwg@icann.org> wrote:

On 31/03/2022 19:29, Jonathan Zuck wrote:

...

Of course the CPH has criticized EVERY study that has been done. They believe we should just take their word for it.

CENTR not CPH, Jonathan, This is a complete demolition of some of the points made in the EC studay and it highlights the problems in methodology, analysis and repeatability/verifiability. It also points out the complete lack of a clue about the legal frameworks in the EU and also the one-size-fits all approach to lumping ccTLD and gTLD DA together.

It would be highly problematic, based on the comments of CENTR, to use the EC study in the ALAC/GNSO letter.

This is the full commentary: https://centr.org/library/library/download/10300/7262/41.html

These are the key points: https://centr.org/news/news/comment-dns-abuse-study.html

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