[council] FW: Proposed Amendments to the Fast Flux Motion

Gomes, Chuck cgomes at verisign.com
Wed Sep 2 16:48:32 UTC 2009

On behalf of the RyC, I would like to propose the following amendments
to Mike Rodenbaugh's Fast Flux motion.  We hope they would be considered
friendly but that is Mike's call.  Note that the current wording of the
motion is in italic font below and that I attached a red line version of
the resolution part of the motion..
Chuck Gomes
(A) "To encourage ongoing discussions within the community regarding the
development of best practices and/or policy changes to identify and
mitigate the illicit uses of Fast Flux"
Make a friendly amendment to change to: "...the development of best
practices and/or Internet industry solutions to identify and
* The WG did not recommend any policy changes specific to fast-flux.
The issue of domain name abuse in general is a completely separate and
more complicated matter -- see (B) below.
* The phrase "Industry solutions" were included in the relevant Final
Report's Recommendations section -- but was dropped in the Resolution
language for some reason.  See (C) below for why Internet industry is a
preferred option.
* The creation of non-binding best practices is a good idea;
awareness-raising and education are needed and in keeping with the RyC
position.  Such efforts could include the ccNSO or other relevant
* The RyC supports best practices and encourages industry solutions by
the wider Internet community, rather than further policy change
(B) "To examine whether existing policy sufficiently empowers Registries
and Registrars to mitigate illicit uses of Fast Flux, as a component of
any future Registration Abuse PDP(s)"
Make friendly amendment so as to read: "The Registration Abuse Policy
Working Group (RAPWG) should examine whether existing policy may empower
Registries and Registrars, including consideration for adequate
indemnification, to mitigate illicit uses of Fast Flux."
* Make the referral explicit.  The Registration Abuse Policies Working
Group (RAPWG) was specifically created to examine such abuse issues, and
was an explicit outgrowth of the learning done in the FFWG.  Core issues
are now being examined in the RAPWG.  
* It is not agreed that GNSO policy can or should "empower" registries
and registrars to mitigate illicit FF.  
* "of any future Registration Abuse PDP(s)" is poor wording.  The GNSO
has had several PDPs related to registration abuses -- such as domain
tasting.  FF is not related to any and all registration issues.
* The current wording of the resolution implies that registries should
be responsible for mitigating fast-flux (and by extension other abusive
uses of domain names). 
(C) "To encourage staff, interested stakeholders, and subject matter
experts to analyze the feasibility of a Fast Flux Data Reporting System
to collect data on the prevalence of illicit use, as a tool to inform
future discussions and/or policy work"
Suggest friendly amendment to remove the words "staff" and "and/or
policy work."  ICANN should not devote resources to the creation or
maintenance of a fast-flux reporting tool.  
* FF is an issue that ICANN is not well-suited to deal with on a
practical level, FF is really outside of GNSO policy-making scope, and
FF is not a core DNS security and stability issue within ICANN's
* Therefore spending ICANN funds is not relevant.
* The Final Report points out that similar security issues are dealt
with by interested parties outside of ICANN -- such as for phishing
(APWG and PhishTank), botnets (ShadowServer and Conficker WG), and spam
(Spamhaus and the SURBLs).   
* NOTE:  Discussion about a "Fast Flux Data Reporting System" should be
clear -- participation in such a tool was never discussed as something
that should be mandated by policy.  A Fast Flux Data Reporting System
should not be equated with ICANN's WHOIS WDPRS reporting tool
[http://wdprs.internic.net/ ] -- the WDPRS is a compliance tool related
to existing contractual obligations that registrars and registrants must
adhere to. 
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