[Comments-sadag-final-09aug17] Google Registry Comment on SADAG Report

Ben McIlwain mcilwain at google.com
Tue Sep 26 19:59:47 UTC 2017

*Please see attached for fully formatted version.  Plaintext version

September 22, 2017

Google applauds Competition and Consumer Trust Review Team (CCT-RT) for
commissioning and supporting the Statistical Analysis of DNS Abuse in gTLDs
Final Report (“Report”). Empirical research on the occurrence of abuse in
the Domain Name System (DNS) as found in the Report is an important first
step to effectively handling it, whether through the development of
policies or implementation of tools by individual registries and

We observed the following from the research put forth in the Report:


   Patterns of abuse occurrence vary according to the type of abuse, with
   some forms more reliant on the reputation and visibility of a particular
   domain name and others with the ability to register domains en masse;

   Similarly, practices by registrars and new and legacy gTLD operators are
   not homogenous leading to uneven distributions of abuse across registries
   and registrars;

   The introduction of new gTLDs changed the distribution of abuse for
   forms that rely upon low-cost or high-volume registrations, but left the
   overall amount of DNS abuse largely unchanged;

   The occurrence of DNS abuse appears to be linked to both price and
   registry policies/procedures for monitoring for and handling these types of
   abuse; and, relatedly,

   Unless compensatory mechanisms are in place, abuse requiring high
   volumes of registrations is likely to be attracted to whatever TLDs are

We strongly urge the CCT-RT and ICANN community to apply the findings of
the report in further research and efforts to address DNS abuse. This may
include further segmentation of the existing findings, or additional
research into price sensitivity of registrants engaged in various forms of
DNS abuse. In order to succeed in reducing the aggregate occurrence of
abuse, it may be necessary or more effective to bring additional Internet
infrastructure players into the conversation and move beyond a contractual
compliance based solution for addressing DNS abuse toward one that is more
holistic. The alternative is likely to only perpetuate the current observed
tendency for abuse to move between TLDs and registrars while leaving the
aggregate occurrence of abuse constant.

We appreciate the research carried out by Delft University of Technology
and SIDN Labs and hope for additional constructive research and effort in
the space.


Ben McIlwain

Registry Tech Lead
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