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

*EXTERNAL TO GT*

Hi Gabe,

thank you for your comment. That is exactly what we already do when we "outsource" some of our duty to investigate and mitigate to our resellers.

Where we act as wholesale registrar, we are basically in the same position as a registry operator. We have no insight into the actual operations of our resellers, how they engage with their customers, what data they collect and what tools they may have available. But we do trust them to have better and more information than we do. 

That is why whenever we forward an abuse complaint, we will request that the reseller also look at the customer account through which the registration occurred if they determine that the complaint is valid, just like a registry would when they forward abuse complaint to their registrars. We will never have the level of insight and data that comes with having the direct customer relationship with the registrants.

We will never know if a bulk of registration requests originated from a certain global region or even IP range. But our reseller may. 

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: Gabriel Andrews via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: 13 April 2026 2:29 PM
To: Reg Levy <rlevy@tucows.com>
Cc: Naoum MENGOUDIS <n.mengoudis@cybercrimeunit.gov.gr>; Feodora Hamza via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [Gnso-dnsabuse-pdp] Re: [EXTERNAL EMAIL] - Re: Another numbers request.

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

UTC -7

On Apr 13, 2026, at 04:59, Gabriel Andrews via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> wrote:

 

Reg -

 

Your input on differing business models is important. 

 

Given that your customers are resellers, would you view it as reasonable - when your team judges it cannot "simply look at all domains in an account" - that the obligation to perform the ADC be passed from you as Rr to your Reseller customer, so that they might perform the ADC using information available to them as the customer-facing entity? 

 

Gabriel

 

 

 

 

---

From: Reg Levy via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Sent: Monday, April 13, 2026 1:35 PM
To: Naoum MENGOUDIS <n.mengoudis@cybercrimeunit.gov.gr>
Cc: Feodora Hamza via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>
Subject: [EXTERNAL EMAIL] - [Gnso-dnsabuse-pdp] Re: Another numbers request.

 

Naoum:

 

The mean number of domains in a reseller account for my company is going to be probably in the high hundred thousands. We have customers with millions of domains and customers with single-digits. Themode is probably closer to tens of thousands. It is not usually the case that my team can simply look at all domains in an account.

 

Servus,

Reg

 

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

UTC -7

 

On Apr 12, 2026, at 04:32, Naoum MENGOUDIS via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> wrote:

 

Dear all,

 

Following the numbers being thrown around in the recent emails, It would be of interest to know the average number of domains an end customer holds. And maybe also the maximum number of domains an end customer holds, to have an idea of the extreme case scenario. This would give us a better estimate of the work needed to be done when doing ADC. [End customer means actual registrants, excluding Resellers and Privacy & Proxy Services]

 

Having 100.000 abusive reports in total says nothing about the overhead of a possible ADC. Maybe ADC would actually help because the reports would be handled in groups instead of one by one (because, as you know, when you are "in the zone" you get more work done compared to starting and stopping and constantly switching contexts).

 

For example, if the average ownership is 100 domains per end customer, you would have to check an additional 99 domains of that customer when one of his domains is reported. Better do it as a group, instead of waiting to do it 100 times in total at some point. PLUS, you can use heuristics, like, if you verify that 20 of the 100 domains of the customer are abusive, and using other available information and indicators (e.g. everything being registered via API and on the same day), you can just deactivate all 100 of the domains and nobody will complain about it (without even having to check further, saving lots and lots of resources). On the contrary, acting on each of the reports that will come in the future is way more resource intensive.

 

And can we have some examples of real scenarios when an ADC would be detrimental to the resource use of the Registrar? So we can validate or not this argument, or any other related argument, or plan appropriate safeguards, instead of dismissing a good practice (i.e. the ADC triggered every time).

 

Regards,

Naoum

 

ΜΕΓΓΟΥΔΗΣ Ναούμ

Αστυνόμος Α'

Διεύθυνση Δίωξης Κυβερνοεγκλήματος

Τμήμα  Διαδικτυακής  Προστασίας  Ανηλίκων 

Λ. Αλεξάνδρας 173, 115 22, Αθήνα

 

MENGOUDIS Naoum

Police Major

Cyber  Crime  Directorate

Online Child Protection Department

Alexandras Avenue 173, 115 22, Athens

T: (+30) 2106476475

E: n.mengoudis@cybercrimeunit.gov.gr
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