Thanks Volker. I understand all of this. But for clarity are you saying that there should only be an obligation to conduct an ADC when the registrar already believes that there may be associated domains?
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: Volker Greimann <volker.greimann@centralnic.com>
Sent: Wednesday, March 18, 2026 8:25 PM
To: Trachtenberg, Marc H. (Shld-ASP-IP-Tech) <trachtenbergm@gtlaw.com>; rlevy@tucows.com
Cc: gnso-dnsabuse-pdp@icann.org; brian@pir.org
Subject: Re: [Gnso-dnsabuse-pdp] Re: Straw Proposal
Hi Marc,
I am glad you asked because they touch upon actual abuse mitigation experience.
Such belief can and does arise from multiple sources. For example, the complainant could have reported 2+ domains in their report. Similarly, we could have received multiple different reports from 2+ reporters
that show the abuse mitigation agent that there is a pattern to these reported registrations even if the reporter may not be aware of them. In some cases, we also conduct such checks based on single reports with only one domain of the naming pattern of that
domain could reasonably indicate that more such domains exist. For example, the domain phishinglove-singapore.[tld] may indicate that other similarly named domains like lovephish-sydney.[tld] or similar could be found in the same account. Similarly, the domain
carding02.[tld] often leads to similar domains using the same string with a different number attached. Sometimes it is a question of "know your customer". Some resellers may have a different track record than others when it comes to the customer that abuse
their services.
In short, there are many different indicators (that will likely need to be adjusted over time) for a registrar to develop a reasonable belief that an ADC may be an effort worth the while it takes to complete it.
But the point is that an ADC will take extra time and effort and if we are forced to conduct one for every single domain where an action was warranted, it will slow our response times, leave bad domains online
longer than necessary and give threat actors and easier time.
I feel that our job should be to make it harder for threat actors, not easier.
Sincerely,
Volker Greimann
General Counsel & Head of Policy and Compliance - Online Division
volker.greimann@centralnic.com
Office: +49-172-6367025
Web:
www.teaminternet.com
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales
with the company number 8576358.
From:
trachtenbergm@gtlaw.com <trachtenbergm@gtlaw.com>
Sent: 19 March 2026 2:09 AM
To: rlevy@tucows.com <rlevy@tucows.com>; Volker Greimann <volker.greimann@centralnic.com>
Cc: gnso-dnsabuse-pdp@icann.org <gnso-dnsabuse-pdp@icann.org>;
brian@pir.org <brian@pir.org>
Subject: RE: [Gnso-dnsabuse-pdp] Re: Straw Proposal
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But how would a registrar reasonably believe that there may be other Registered Names associated to the Registered Name without the obligation to conduct an investigation? It would seem that for this to be
meaningful there must be both a trigger (i.e., at least one domain name where there is actionable evidence of DNS abuse) and then the obligation (i.e., to conduct a review or investigation to see if there are other associated domains).
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: Wednesday, March 18, 2026 8:02 PM
To: Volker Greimann <volker.greimann@centralnic.com>
Cc: anil Jain via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>; Brian F. Cimbolic <brian@pir.org>
Subject: [Gnso-dnsabuse-pdp] Re: Straw Proposal
*EXTERNAL TO GT*
Volker, Marc—
Thanks for your quick review! I agree something along the lines of “where a reasonable indication exists” is necessary.
I think Marc’s edits restated what Brian said just using more words (and I prefer succintity for clarity) except for adding in an immediacy (“When a Registrar has actionable evidence”) that is both unwarranted and unreasonable.
Perhaps:
When a registrar takes mitigation action(s) on a Registered Name under Section 3.18.2 of the Registrar Accreditation Agreement and reasonably believes there may be other Registered Names associated to the Registered Name, 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.
/R
--
Reg Levy | Associate General Counsel – Domains
+1 (323) 880-0831
Tucows #MakingTheInternetBetter
UTC -7
On Mar 18, 2026, at 17:55, Volker Greimann <volker.greimann@centralnic.com> wrote:
Hi Brian,
removing any requirement of there being any reasonable indication of there actually being further domains to look for is unreasonable and will ultimately achieve the opposite of our goal:
Instead of taking a targeted approach to likely occurrences of DNS abuse, this new language would require Registrars to go on wild goose chases for potentially existing affiliated domain names. So instead of actioning multiple abuse tickets received by a registrar, the abuse desk has to spend time doing a victory lap each time we take action on one ticket, greatly reducing the capacity to timely act upon incoming reports.
There must be an element in the ADC requirement that only triggers the requirement to do an ADC when it can be reasonably assumed that such ADs exist, instead of triggering the ADC every time an action is taken. This would be a gift to threat actors as it would force us to spend time engaging in Kabuki theatre rather than actioning actual reports of abuse.
Also, I am missing any hint of a suggestion of what Registries might be able to contribute. If we look at this solely from an individual registrars' perspective, we will not achieve anything. We are already seeing many abuse campaigns span that across multiple registrars and that can be detected on a registry level.
Sincerely,
Volker Greimann
General Counsel & Head of Policy and Compliance - Online Division
volker.greimann@centralnic.com
Office: +49-172-6367025
Web: www.teaminternet.com
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.
From: Brian F. Cimbolic via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: 18 March 2026 10:14 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:
<Screenshot 2026-03-18 at 4.09.42 PM.png>
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.
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