I would note that this appears to be just phishing domains and to not include domain names reported for other types of DNS Abuse (i.e., malware, botnets, pharming, and spam).

Additionally, while the number of domains reported for phishing is low as a percentage of total DUMS, 116,871 being used for phishing is high as an absolute number, and this is just one registrar and only phishing domains and not all types of DNS Abuse at this registrar. Doing some quick “back of the napkin” math and extracting those numbers out to the rest of the registrars based the percentage of DUMS under management vs total DUMS across registrars, this means that there are likely of 1,000,000 valid phishing reports submitted.

This is a staggering number and keep in mind that it only includes one type of DNS Abuse and only includes DNS Abuse actually reported! Do we think that this is a million separate bad actors? It is much more likely that this speaks to organized networks and reiterates the need for a meaningful ADC framework to tackle this abuse proactively.

Best regards,

Marc H. Trachtenberg
Shareholder

Chair, Internet, Domain Name, e-Commerce and Social Media Practice
Greenberg Traurig, LLP

Aspen Chicago

411 E. Main Street 360 North Green Street

Suite 207 | Aspen, CO 81611 Suite 1300 | Chicago, IL 60607

T +1.970.300.5313 T +1.312.456.1020

M +1.773.677.3305 M +1.773.677.3305
trac@gtlaw.com | www.gtlaw.com | View GT Biography

From: Vivek Goyal <vivekg@ldotr.red>
Sent: Friday, April 10, 2026 12:19 AM
To: Trachtenberg, Marc H. (Shld-ASP-IP-Tech) <trachtenbergm@gtlaw.com>; rlevy@tucows.com; gnso-dnsabuse-pdp@icann.org
Subject: Re: [Gnso-dnsabuse-pdp] Re: Fwd: Namecheap phishing report data for 2025

Thank you Reg and Owen.

At 116,871 phishing domains over 27mn DUM, that about 0.43% abusive domains. Is that percentage a good reflection of the overall industry?

Agree with Marc that the trigger for ADC will be the 116,871 domains found to be phishing and NOT the other 73%.

Regards,

Vivek

From: trachtenbergm--- via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Date: Friday, 10 April 2026 at 2:06 AM
To: rlevy@tucows.com <rlevy@tucows.com>, gnso-dnsabuse-pdp@icann.org <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] Re: Fwd: Namecheap phishing report data for 2025

Thans Reg (and Owen). This is interesting information. I note that there is no information regarding why phishing was not found in the relevant 73% of such complaints. Also, I would note that the number or percentage of complaints where phishing (or DNS Abuse generally) is not found is not really relevant here as those complaints would not trigger an ADC. Only the complaints where there was actionable evidence of DNS Abuse (phishing or otherwise) would trigger the ADC.

Best regards,

Marc H. Trachtenberg
Shareholder

Chair, Internet, Domain Name, e-Commerce and Social Media Practice
Greenberg Traurig, LLP

Aspen Chicago

411 E. Main Street 360 North Green Street

Suite 207 | Aspen, CO 81611 Suite 1300 | Chicago, IL 60607

T +1.970.300.5313 T +1.312.456.1020

M +1.773.677.3305 M +1.773.677.3305
trac@gtlaw.com | www.gtlaw.com | View GT Biography

From: Reg Levy via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: Thursday, April 9, 2026 2:25 PM
To: Feodora Hamza via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] Fwd: Namecheap phishing report data for 2025

*EXTERNAL TO GT*

All—

The below comes from an observer with more data about reported vs. actual to help get a sense of scale.

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

UTC -7

Begin forwarded message:

From: Owen Smigelski <owen.smigelski@namecheap.com>

Subject: Namecheap phishing report data for 2025

Date: April 9, 2026 at 10:08:39 PDT

To: Reg Levy <rlevy@tucows.com>

Hi Reg,

I saw your email on the list for the ADC PDP regarding phishing reports at Tucows. I reached out to my abuse team, and obtained data for Namecheap and Spaceship for 2025 (which have over 27 million domains under management). The stats are:

Total reports: 432,796
Phishing confirmed: 116,871 (27%)
Phishing not confirmed: 315,925 (73%)

Note: this counts tickets in our system, and some tickets may cover more than one domain name

Can you please share this with the PDP as another data point regarding the volume of abuse complaints that are not actionable? Thanks!

Regards,

Owen

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