Dear Marilia,
I have read the document for our work in the sub-group on consumer
trust, part of the Competition, Consumer Choice and Consumer Trust
Review, and I have to say that at least the title is not very accurate:
1. it is not a report on abuse (although it purposed some ideas on how
to set semantic boundaries to the issue)
2. it is a quite detailed methodological proposal to analyse the
effectiveness of the new Safeguards that where introduced in
Specification 11 of the RA for new gTLDs
3. I so far as it proposes a sophisticated statistical methodology for
testing any possible relations between safeguards + abuse, we probably
don´t have the numbers (time series) yet available for such a study,
and based on the experience with the other data we have been looking for
the Review, it will take quite some time and effort to get statistically
relevant results.
4. As far as registration abuse it avoids the discussion of WHOIS
altogether. It is strange to see how the WHOIS Review (9.3.1) was
previously listed in the AoC as a probable subset of the CCT review
(9.3), but now in the new by-laws draft WHOIS Review a life of its own,
fully independent of CCT Review. I still don´t know if they should
remain at least loos related. The proposal does not get into that.
5. Furthermore the narrow scope leave out possible abuse by users, as
opposed to abuse by registrants.
6. What I personally find surprising, is that the proposal is not based
on constructing some kind of index or analysis based on the metrics
recommended by the Implementation Advisory Group for the CCT. But
neither the IAG-CCT went on such details of the 9 safeguards of spec 11.
I feel myself a little bit confused between the IAG-CCT recommendations,
and the GDD initiatives like the recent Health Index and now this
proposal to measure abuse. Some other much more knowledgable colleagues
on the CCT Review team also wonder why the proposal takes such a narrow
approach on the Spec 11 safeguards only, but have had no time to discuss
it so far. It will be in the agenda of our next f2f meeting early in
June.
7. For those with a little time left for thinking about this and have
academical experience on such methodologies, I kindly ask them to take a
quick look on the last section on methodology and modelling and come
back to me so we can have a short discussion on how we can formulate
comments.
I really have a hard time commenting further, as in many sections the
proposal makes its future development (and financing) dependent on what
the CCT Review “decides”. I don´t see the review team deciding on
internal studies by GDD at such very specific and detailed level.
Carlos Raúl Gutiérrez
+506 8837 7176
Skype: carlos.raulg
Current UTC offset: -6.00 (Costa Rica)
On 15 May 2016, at 13:00, Marilia Maciel wrote:
> Hello everyone,
>
> The draft report on New gTLD Program Safeguards to Mitigate DNS Abuse
> is
> open for comments until the 20th of May. Time is very short, but maybe
> one
> of our members is already following the issue? It seems to me some of
> the
> measures proposed intersect with privacy and the law enforcement
> empowerment that we have been concerned with.
>
> Please see the full information here:
> https://www.icann.org/public-comments/new-gtld-safeguards-dns-abuse-2016-03-15-en
>
> Our colleague, Carlos Gutierrez, mentioned the importance of this
> topic in
> our last NCSG call. Maybe he can share his views on that.
>
> All the best wishes,
> Marília
>
> --
> *Marília Maciel*
> Pesquisadora Gestora - Centro de Tecnologia e Sociedade - FGV Direito
> Rio
> Researcher and Coordinator - Center for Technology & Society - FGV Law
> School
> http://direitorio.fgv.br/cts
> DiploFoundation associate - www.diplomacy.edu
> PoliTICs Magazine Advisory Committee - http://www.politics.org.br/
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