In this example of the customer that has 20 out of 100 domains which are deemed to be abusive, then I disagree that suspending all of the domain names in the account would constitute a disproportionate or unjustified impacts on the registrant or end user. In the example, this customer is clearly a serial abuser of domain names and this would justify shutting down the entire customer account. Furthermore, if you look at the terms of use of almost all registrars, even one incident of a domain being used for DNS Abuse (or any other violations of the terms) is sufficient to permit the registrar to suspend or terminate all services provided to the customer, which includes all of their domains. So, to the extent that there is any risk of overreach create by the ADC itself – which I disagree exists at all - it is no greater than what already exists. 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<mailto:trachtenbergm@gtlaw.com> | www.gtlaw.com<http://www.gtlaw.com/> | View GT Biography <https://www.gtlaw.com/en/professionals/t/trachtenberg-marc-h> [Greenberg Traurig Logo] [Greenberg Traurig Logo] From: farzaneh badii via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> Sent: Sunday, April 12, 2026 8:31 AM To: Naoum MENGOUDIS <n.mengoudis@cybercrimeunit.gov.gr> Cc: Feodora Hamza via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> Subject: [Gnso-dnsabuse-pdp] Re: Another numbers request. *EXTERNAL TO GT* Hi Naoum, You mentioned earlier that ADC would have no adverse effect on rights (I include access in it too). I did not respond at the time because I think that conclusion is premature and needs to be assessed in context. First, when we talk about human rights in this setting, we are not only concerned with established violations but with risk, that is, the likelihood that certain practices could lead to disproportionate or unjustified impacts on registrants and end users. In your example, you effectively illustrate how that risk can increase with ADC check: “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)” This approach introduces a clear risk of overbroad action, where domains that have not been individually assessed are nevertheless subject to the same outcome. Even if some domains are abusive, extending action to the entire portfolio without further verification raises questions of proportionality, accuracy, and potential impact on legitimate uses. Best regards Farzaneh On Sun, Apr 12, 2026 at 7:33 AM Naoum MENGOUDIS via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org<mailto: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. 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