What you’re basically saying makes a lot of sense.

Without proper logs, it’s really hard, like almost impossible, for ICANN Compliance to confirm whether registrars actually followed the policy, especially when things are reviewed much later or when there’s no external complaint to trigger an investigation.

At the same time, I also understand the concern that too much logging could become heavy and slow down normal abuse handling work.

So a fair middle ground would be to keep logging simple and focused on only the key steps—like when the complaint came in, whether ADC was done, when it started and ended, what was checked, what was found, and what action was taken.

If this is captured in a lightweight way (even a simple form or spreadsheet), it should give Compliance enough visibility without creating too much extra burden on registrars.

On Tue, Jun 2, 2026 at 10:26 PM Eberhard W Lisse via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> wrote:

Find my responses in line.

On 2026-06-01 20:02, trachtenbergm@gtlaw.com wrote:
> It is the cost of doing business, which always increases over time
> in every industry.

I hesitated to reply, at first, because I was disturbed by the sheer
audacity of the above sentence, but in the end decided to point this
out.

> Just like it is the cost of doing business for brand owners to
> submit an increasing number of abuse reports and follow up
> complaints to ICANN.

Besides that we are not looking at Abuse Reports but at ADC (which is a
mechanism (at the Registrar level) triggered by an Abuse Report (and
hence does not affect the cost of Brand Owners at all), would you be in
a position to provide some figures?

Just for the sake of Data Driven Decision Making it would be very
helpful to know the scale of the problem per Brand Owner on average,
Employee Time spent per complaint, and success rates.

Would be even more interesting to compare to the Registrars'.

> But the goal is to make it as inexpensive as possible for registrars
> and while settling on some reasonable things that can be captured
> such that the policy has some hope of being monitored and enforced
> and thus to be meaningful.

Have we considered whether the log information would fall under the GDPR
and similar legislation?

[...]
> Marc H. Trachtenberg
[...]

--
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