Michaela,
When you say “enforcement” below do you mean mitigation? If so, my understanding is that this PDP only covers the associated domain check. Any mitigation obligations would already be addressed in the RAA and would be out of scope here.
Best regards,
Marc H. Trachtenberg
Shareholder
Chair, Internet, Domain Name, e-Commerce and Social Media Practice
Greenberg Traurig, LLP
Aspen Chicago
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Suite 207 | Aspen, CO 81611 Suite 1300 | Chicago, IL 60607
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From: Michaela Nakayama Shapiro via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: Monday, May 11, 2026 1:55 PM
To: Julie Bisland via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] NCSG Q5 Proposed Language
*EXTERNAL TO GT*
INTERNAL
Dear all,
Ahead of today's meeting, the NCSG has prepared draft language for charter question 5. We look forward to further discussion, and are more than happy to answer any questions.
Best,
NCSG/NCUC
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Where enforcement actions affect multiple domains based on an association determination, appropriate safeguards must be available to protect registrants from unintended harm. Registrants and end-users have the
right to mechanisms for remedy related to DNS abuse mitigation action(s).
Registrars must ensure that mitigation measures are proportionate, transparent, and supported by well-evidenced DNS Abuse. Affected registrants should be provided an appeal process.
This includes, but is not limited to:
- providing avenues for impacted registrants to seek clarification or review through dispute or support channels;
- clear procedures for the registrant to appeal the mitigation action(s)
- where relevant, for the reversal of any mitigation action(s), where applicable
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