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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