Volunteers to discuss Draft Registrar Stakeholder Group White Paper: Registrant Protections in DNS Abuse Mitigation

Paper available online in Raphael's email to NCUC of June 28, 2021

Any initial thoughts of comments.

See thoughts below.

Taiwo Peter Akinremi

Farzi posted to NCSG on 6/28/21

Here are some preliminary comments. We can work on them if you want to send something on behalf of NCSG:

1. Thank you for focussing on protecting registrants when fighting with DNS abuse. They are most of the time neglected.

2. They mention that the registrars are contributing to DNS abuse "community mechanisms".We should be clear that we are not sure how NCSG and noncommercials are included in these efforts. If they mean by community effort you as being a part of DNS abuse institute advisory council or Stephanie Perrin as the rep on the advisory council of PIR then I think they should be clear about that. If they mean "community efforts" at ICANN then I am not sure what they mean.

3. Under the Evidentiary section, this is not an appeals mechanism or a pre-appeal mechanism. What they are describing is the evidence that the DNS abuse complaints should include and is a part of the due process they need to provide for the registrants. That section needs to be much more detailed with a process on how the abuse reports are treated, what sort of evidence they need from the complainant etc.

4. I have not heard the term "ombud". It is either Ombuds or Ombuds Person or Ombuds Office. It's a good idea but they need to look into what they mean by "binding" outcomes because usually Ombuds outcomes are not legally binding - So the registrar binds itself by it?

5. Fundamental problem with this white paper is that it bases the protection of registrants from fraudulent and frivolous DNS abuse complaints (or just simply mistaken ones) by just considering ex post dispute resolution and appeals mechanism. It is a good step forward but that is not enough. Measures should be taken to reduce the number of unfairly impacted domains before they actually happen. People have businesses and websites and they rely on their domain name. A shut-down can cost them a lot and affects them financially as well as operationally and their activism and whatever service is time-sensitive.