Thanks EL. We made our way through Charter Q1 in Mumbai so we are ideating over Strawperson 1 whilst moving on to discussing Charter Q2. Best, Paul Paul McGrady Partner Elster & McGrady 434 Houston St, Suite 261 Nashville, TN 37203 3847 N. Lincoln Avenue Second Floor Chicago, IL 60613 Office Direct: +1 (312) 515-4422 paul@elstermcgrady.com www.elstermcgrady.com -----Original Message----- From: Eberhard W Lisse via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> Sent: Wednesday, March 18, 2026 5:35 PM To: anil Jain via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> Subject: [Gnso-dnsabuse-pdp] Re: Straw Proposal The technical changes (domain -> Registered Name and the like) are in line with what I suggested previously and make sense. Since we are developing Policy and not writing the actual RAA, I would suggest we'll leave the (or include a) requirement to take action, which makes it clearer. That said, would it not be better to work off the Charter Questions first? On a technical point, please do not email images, because they are difficult to include in replies. el On 2026-03-18 15:14, Brian F. Cimbolic via Gnso-dnsabuse-pdp wrote: [...]
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. [...] *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. [...]
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