One of the primary goals for ADC should be to provide better consumer protection and reduce economic harm to businesses. Currently, it is far too easy for bad-faith actors (human, or human + bot) to create large volumes of associated domains -- as shown in the Interisle report, and it is increasingly difficult for third parties to perform effective ADC, even with AI / ML .

We must remember that registrars are in a much better position to perform ADC than external parties. Let's not deviate from such goal. 

Best regards,

Ching



On Sat, Jun 6, 2026 at 6:08 PM Eberhard W Lisse via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org> wrote:
I also find that paper unhelpful.
 
But in some jurisdictions, for example Germany, transporting burglary equipment can be a crime in itself, and carrying tools or specialized equipment to overcome security measures significantly increases potential penalties during a theft conviction.
 
In other words registration of names like govnaa.TOP AND using them or a subdomain like nampol.govnaa.TOP for pharming already requires mitigation under current RAA. 
 
Registering additionally govbw.TOP would in itself not require ADV. 
 
But if govNAA.TOP were mitigated (for actionable evidence of malicious abuse) THEN the ADC MUST be conducted. 
 
The ADC should catch (the (malicious) registrations of govbw.TOP and similar like gobbr.TOP gouvfr.TOP.
 
Now how to automate the search is a matter for Claude and Levenshstein but doable, and so the subsequent decision by a human should not take that long.
 
While I do not want to mansplain Human Rights, I HAVE lived under occupation myself (before Namibian Independence), and HAVE in my day job had some experience with the combatting of Child Abuse and Gender Based Violence, but I think our Human Rights considerations should not go overboard.
 
el


--
Dr. Eberhard W. Lisse \ / Obstetrician & Gynaecologist (retired)
el@lisse.NA / * | Telephone: +264 81 124 6733 (cell)
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On Jun 5, 2026 at 22:21 +0200, farzaneh badii via Gnso-dnsabuse-pdp <gnso-dnsabuse-pdp@icann.org>, wrote:
 
[…]
The Interisle report says this (on page 35):
How does Interisle determine if a domain has been “maliciously registered?”
We consider domains blocklisted within 90 days of registration to be malicious.
I note that Interisle seems to distinguish between malicious *registration* and malicious *use*.  There us a vast gap there - the same as the difference between a) buying a glass cutter and b) using that glass cutter in a crime (such as cutting through a window pane in order to commit a burglary.)
In other words in the minds of Interisle, a domain that somebody puts onto some block lists within three months is adjudged, usually without further inquiry, as "malicious".
[…]
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