Thanks Brian. I am meeting with Staff today and I hope we can get this Strawperson language into a Google Doc for folks to comment on. Keeping track of this via email string is going to be impossible with a group this size. Please stay tuned and do add your suggestions to Q1 Strawperson as soon as we get that Google Doc live.

Best,

Paul

Paul McGrady Partner Elster & McGrady 434 Houston St, Suite 261 Nashville, TN 37203 3847 N. Lincoln Avenue Second Floor Chicago, IL 60613 Office Direct: +1 (312) 515-4422 paul@elstermcgrady.com www.elstermcgrady.com

From: Brian F. Cimbolic via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: Wednesday, March 18, 2026 4:14 PM
To: Reg Levy <rlevy@tucows.com>; anil Jain via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] Re: Straw Proposal

Hi all - First, thank you all for some great sessions to kick this work off in Mumbai. I thought we already made a lot of progress in our first working session. 

In advance of Monday’s call, I wanted to float a slightly modified version of the Strawman that Reg (very helpfully!) provided below. I provide a clean version, as well as a screenshot of Redlines so we can all see exactly what I’m proposing we change. 

Summary of proposed tweaks: 

• The actual obligation to mitigate DNS Abuse in the RAA is found in 3.18.2, rather than the broader 3.18, which includes other unrelated provisions. Tightening that subsection reference should make it clearer where an Associated Domain Check comes into play. 

• I tried to harmonize the language from Reg’s version with the terms and definitions set forth in the RAA already. So rather than “domains,” it’s “Registered Name” (again, simply to match the RAA defined terms). 3.18.2 also references “mitigation action(s)” so I incorporated that verbiage rather than the more generic “action." 

• 3.18.2 already requires that Registrars take mitigation action(s) when they have actionable evidence of DNS Abuse. If the Associated Domain Check is fruitful and the Registrar finds such actionable evidence of abuse, it is similarly obligated to take mitigation action(s). So, I suggest striking the “and take action against those domains where appropriate” as redundant. 

REDLINE: 

CLEAN:

When a registrar takes mitigation action(s) on a Registered Name under Section 3.18.2 of the Registrar Accreditation Agreement, the registrar shall promptly review other reasonably associated Registered Name(s) to determine whether such Registered Name(s) may be involved in DNS Abuse using information reasonably available to the registrar at the time of review.

Looking forward to the call on Monday. Please let me know if you have any questions. 

Thanks,

Brian

Brian Cimbolic | Chief Legal and Policy Officer brian@pir.org | www.thenew.org | Power your inspiration. Connect your world.

Confidentiality Note:  Proprietary and confidential to Public Interest Registry.  If received in error, please inform sender and then delete.

From: Reg Levy via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Date: Monday, March 9, 2026 at 6:19 AM
To: anil Jain via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] Straw Proposal

All—

As noted in the chat in the session today, this is the straw proposal a number of us have been working on for the last few days and we’d love additional input:

When a registrar takes action under Section 3.18 of the Registrar Accreditation Agreement, the registrar shall promptly review other domains that are reasonably associated with that domain when there are clear indicators that other domains registered by the same customer may be involved in the same abusive activity, using information reasonably available to the registrar at the time of review, and take action against those domains where appropriate.

Servus,

Reg

--
Reg Levy | Associate General Counsel – Domains
+1 (323) 880-0831
Tucows #MakingTheInternetBetter

UTC +5:30

This email originated from outside the firm. Please use caution.