[CPWG] Engagement on DNS Abuse

Thu Feb 11 00:21:22 UTC 2021

Sure, our advice is not limited in scope but, at some point, we ARE limited by what ICANN can do something about

Jonathan Zuck |  Executive Director  |  Innovators Network

jzuck at innovatorsnetwork.org<mailto:jzuck at innovatorsnetwork.org> | O 202.827.7594 | D 202.420.7483

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________________________________
From: CPWG <cpwg-bounces at icann.org> on behalf of Roberto Gaetano <roberto_gaetano at hotmail.com>
Sent: Wednesday, February 10, 2021 3:10 PM
To: Laurin B Weissinger <Laurin-lists at pm.me>
Cc: CPWG <cpwg at icann.org>
Subject: Re: [CPWG] Engagement on DNS Abuse

I understand that also Göran, in the call a few hours ago, agrees that ALAC’s advice is not limited in scope.
R

On 10.02.2021, at 19:52, Laurin B Weissinger via CPWG <cpwg at icann.org<mailto:cpwg at icann.org>> wrote:

Dear all,

I will respond to different messages here, hope I can get this to make sense:

> If the ALAC is currently structured in a way that it cannot fulfill its by-law duties, because the DNS Abuse issue "might not be best addressed by a small body of volunteers", I'd like to suggest that maybe the entire ICANN organization has a problem meeting its mission as stated in our bylaws. It may be wise to address any perceived capability problems with ALAC directly, rather than bypassing ICANN's bylaws for the sake of expediency. However, I do agree it's best to look for consensus within the current context, since the question about the capability of "a small body of volunteers" won't be solved quickly.

David, ALAC’s mission in particular is a very hard one indeed, as Evan put into words below — but I was referring not just to ALAC here but rather the ICANN ecosystem more generally. ICANN is in some ways what was said about democracy “The worst systems except for all the others”. What mattered to me here is really the focus on where we might find consensus within ICANN, beyond ALAC and also something that will be acceptable beyond the community if possible.

> About ALAC, what I am saying is that we should not be shy of providing our opinion and/or advice - that is, we should not self-impose limits accepting comments by others (e.g. SOs).

Roberto, agreed. I think we need to absolutely do so, keeping end user interests in mind. What I feel might be important however is to focus our efforts on where we might get somewhere. If we can help sort out some of the problem, we can focus on the rest later — if that makes sense.

> Since leaving heavy-duty ALAC work I observe that ALAC in its current state is indeed not fit to serve its bylaw duties, but through no fault of its own or its people. Without the ability to do global surveys of public opinion, ALAC is really not capable of knowing what end-users want from ICANN. The best we can do are educated guesses -- which, to be honest, are usually pretty well-thought despite the lack of grounding. And statistical inputs such as John's strengthen our case. But we're still guessing at what the world wants.

Evan, I agree, essentially the task at hand is one that can only be aspired to, hardly ever fully realized (depending on one’s definition).
>
> After reading all of the comments. When it comes to defining DNS abuse in order to determine the metrics based on which we can address the issue, we cannot afford to wait till we reach a definition which the whole ICANN community agrees to (maybe this will never happen). In order to move forward we need to start with the basic technical definition that strictly falls within ICANN realm, in addition to what could be defined as cybercrime – the Budapest convention could be our guide in this regard.

Hadia, agreed! ICANN has to reach some consensus here if you ask me, in order to not being regulated by others if you will. My feel is that technical definitions are important but I fear it will be different to work only based on that, unfortunately. As stated above, I totally agree with you that cybercrime “proper” (as defined by Budapest) is a good framework to get started, where we (as I tried to mention) could also get other parts of the community to agree with what we come up with. I personally think that from an end-user perspective and the Budapest convention (section 1), we have to work something out that distinguishes between such crimes and private disputes.

All the best
Laurin

On Mon, Feb 8, 2021 at 17:46, Hadia Abdelsalam Mokhtar EL miniawi <Hadia at tra.gov.eg<mailto:Hadia at tra.gov.eg>> wrote:

Hi All,

After reading all of the comments. When it comes to defining DNS abuse in order to determine the metrics based on which we can address the issue, we cannot afford to wait till we reach a definition which the whole ICANN community agrees to (maybe this will never happen). In order to move forward we need to start with the basic technical definition that strictly falls within ICANN realm,  in addition to what could be defined as cybercrime – the Budapest convention could be our guide in this regard.

Best

Hadia

From: CPWG [mailto:cpwg-bounces at icann.org] On Behalf Of David Mackey
Sent: Thursday, February 04, 2021 8:09 PM
To: Laurin B Weissinger
Cc: CPWG
Subject: Re: [CPWG] Engagement on DNS Abuse

Laurin,

It's my understanding the ICANN by-laws give voting power to the ALAC in a way that balances the interests of different stakeholders as originally intended when ICANN was created.

If the ALAC is currently structured in a way that it cannot fulfill its by-law duties, because the DNS Abuse issue "might not be best addressed by a small body of volunteers", I'd like to suggest that maybe the entire ICANN organization has a problem meeting its mission as stated in our bylaws. It may be wise to address any perceived capability problems with ALAC directly, rather than bypassing ICANN's bylaws for the sake of expediency.

However, I do agree it's best to look for consensus within the current context, since the question about the capability of "a small body of volunteers" won't be solved quickly.

Cheers!

David

On Thu, Feb 4, 2021 at 12:50 PM Laurin B Weissinger via CPWG <cpwg at icann.org<mailto:cpwg at icann.org>> wrote:

Dear Roberto, Evan, Carlton, and all,

Thank you — in my humble opinion, the essential problem here is that ICANN is filling roles that are problematic to fill for an organization like ICANN, all advisory committees and so on considered. (Not that other approaches would be better)

Nevertheless, there are many decisions that must be made by someone (not blaming anyone here) that simply are purely policy and extremely value-based. Therefore, these questions are linked to normative and fundamental legal questions that might not be best addressed by a small body of volunteers in a system marked by overly strong industry presence (again no blame here, statement of fact).

I can definitely tell you from experience that the differences between Europe and US on some of these matters are stark, not even zooming out to the world. (We are seeing similar issues with the tech giants, making unilateral global decisions from a private company and US perspective—things could be worse. ;) )

This is why I fear we will struggle to find consensus here that will be acceptable to everyone. That is why, in a previous email, I was proposing that we might want to be thinking about where at least some consensus could be reached, where we have a chance to get somewhere. To me, this will likely be in the area of cybercrime and what is covered by criminal law. Yes, there will be differences between what is perceived as crime in different countries/regions but there is likely more there that consensus can be reached about. (And where legal requirements will already require some action).

Hope this makes sense.

All the best
Laurin

On Thu, Feb 4, 2021 at 17:57, Roberto Gaetano <mail.roberto.gaetano at gmail.com<mailto:mail.roberto.gaetano at gmail.com>> wrote:

Hi all

I agree with Evan on both points.

Indeed the scope of the advice of ALAC does not have the limits that are imposed on other bodies, like the SOs. This because it is advice, and not a binding decision.

And agree as well about the strictly technical mandate of ICANN. Quoting one of Evan’s examples, the new gTLDs, there were just a couple of things that were within that remit, like the study on how many TLDs could be introduced with no risk for the root - and how fast this could be done - or issues about collision with widely used keywords. All the rest has nothing to do with technical issues. If somebody can explain to me what is technical about, for instance, whether large non-capital cities should have their name reserved or not, I might change my mind - but until then I remain convinced that the footprint of ICANN expands well beyond a coordination of technical issues.

Cheers,

Roberto

PS: since Evan mentions it, my opinion about .XXX is that it should not have been delegated for the simple reason that it violated one key condition for sponsored TLDs: evidence of consensus of the served community - and we have received, as Board, many statements from parts of the adult industry who disagreed (for a number of reasons) with the delegation of .XXX. Initially the Board denied delegation, but later (but I was already off the Board) changed the opinion - some folks hinted that it was for fear of lawsuits. But the question is: what was the impact of that decision on the technical infrastructure management? Who is ICANN to have the power to decide yes or no?

On 03.02.2021, at 19:01, Evan Leibovitch <evan at telly.org<mailto:evan at telly.org>> wrote:

Hi Jonathan and Joanna,

A few comments on scope:

  *   I feel the need to periodically remind my colleagues that ALAC's scope is whatever it deems to be in scope. The ICANN bylaws explicitly do not limit the subject matter on which we can comment in the manner that SOs are. We are able to advise the Board on policy, on operations, on core values, on budget, and indeed on scope. I reject the arbitrary imposition of limitations upon what we can comment based on the limitations placed on (or assumed by) other ICANN sub-communities. If there is something that ALAC deems is (a) important to end users and (b) addressable by ICANN then it's in-scope. We are the sole arbitrators of what is important to us, and I find it intensely frustrating when ALAC muzzles itself in order to be synchronized with the self-imposed limits of others.
  *   In response to the question:

"Does this mean we should finally abandon the well established yet always controversial narrative of a strictly technical infrastructure management?"

I answer: That ship sailed long ago and is now on the ocean floor. Anyone who believes that ICANN adheres to a strictly technical mandate -- or even pretends to -- has not been following its history very deeply. From the money-driven decisions on expanding the number of gTLDs, to the utterly political decisions about the "appropriateness" of artifacts such as .XXX or vertical integration or closed generics, to philosophical issues such as the balance between registrant privacy versus accountability, ICANN long ago shed any pretense of purely technical function. Most recently, the admonishment of ICANN on the issue of the .ORG transfer by its overseer (the California Attorney General) demonstrates beyond doubt that societal expectations of ICANN's function go WELL beyond the purely technical.

By all means let's be clear on what we mean by "DNS Abuse"; without clarity we won't have the necessary focus and our resulting advice will be easily ignored. But let's not artificially constrain ourselves in advance.

Cheers,

Evan Leibovitch, Toronto Canada

@evanleibovitch / @el56

On Wed, 3 Feb 2021 at 09:50, Jonathan Zuck <JZuck at innovatorsnetwork.org<mailto:JZuck at innovatorsnetwork.org>> wrote:

Evin has suggested that I had, perhaps, NOT forwarded this to the group. Here’s the discussion thread, initiated by Keith Drazek on the Contracted Party House DNS Abuse Work Group. This includes, Joanna’s expression of mission creep concern.

Jonathan

Jonathan Zuck

Executive Director

Innovators Network Foundation

www.InnovatorsNetwork.org<http://www.innovatorsnetwork.org/>

From: Joanna Kulesza<mailto:jkuleszaicann at gmail.com>
Sent: Wednesday, January 27, 2021 2:12 AM
To: Maureen Hilyard<mailto:maureen.hilyard at gmail.com>; Jonathan Zuck<mailto:JZuck at innovatorsnetwork.org>
Subject: Re: Engagement on DNS Abuse

Great stuff Jonathan, as always. Feel free to share. If I were to add my two cents, I'd put these in the "pain points" section while these are of a more general nature.

"From the discussions we've had within At-Large it is clear that the very scope and definition of DNS Abuse is a "pain point". This was also the take away from the discussions we've had with the invited guests from within and beyond the ICANN community. "DNS Abuse" as it is now defined in the proposed Framework affects the entire internet community of end users while being already covered by existing national and international norms and standards. Keeping these in mind the proposed definition and scope of DNS Abuse strikes as arbitrary: what were the criteria set for selecting these specific categories as DNS Abuse while leaving other potential categories out?

This is particularly relevant with regard to our second concern: the proposed scope of DNS Abuse clearly crosses the content "picket fence" that the ICANN community had set for itself. Including IP infringement on equal footing with CSAM raises serious concerns among At-Large members. We are concerned not only with the very fact of the picket fence being crossed but also by the way in which this is being done. Does this mean we should finally abandon the well established yet always controversial narrative of a strictly technical infrastructure management?

Once content is concerned, the existing and proposed  practice fails to recognize international legal safeguards when it comes to restrictions put on individual freedoms. Whenever an individual liberty is to be restricted, due process must be ensured. The procedures proposed by the DNS Abuse framework fail to ensure e.g. a right to an effective legal remedy. While we realize this argument brings us back tot he general discussion on limits of ICANN's contractual jurisdiction, that is an argument we would be interested to during any upcoming DNS Abuse work.

Only once these concerns relating to the scope of the definition of DNS Abuse can be addressed, can we focus on metrics and effective enforcement that will provide a fair and operational framework protecting the rights of end users."

By all means to feel free to rephrase!:) What I'm arguing for is that for us to be able to "measure" DNS Abuse we should first clearly and transparently decide what it means. The current framework means the contracted parties are indeed trying to play a self-proclaimed internet police (militia?). Why did we presume DNS Abuse is CSAM and (in the same breath) fake Gucci bags but not hate speech and inciting violence? While we clearly would not have the answer ready, that is definitely a discussion we should have. The GAC might be interested in this as well (see last update from Veni on the ITU processes).

Thanks for considering team!

Best,

J.

W dniu 27.01.2021 o 01:39, Maureen Hilyard pisze:

In your inimitable style. Love it. Send it.

M

On Tue, Jan 26, 2021 at 12:34 PM Jonathan Zuck <JZuck at innovatorsnetwork.org<mailto:JZuck at innovatorsnetwork.org>> wrote:

Ladies,

Here’s my draft response. Let me know what you think!

Jonathan

=============================================================

Hey folks! Thanks for reaching out. Joanna and I, for sure, would be willing to join you and I suspect others, as well, once we know the timing. With respect to the questions below, I’ll do my best to provide some initial responses but I suspect the first question might be pivotal. There seems to be a lack of real data on the topic and perhaps some additional objective research is the answers. We endeavored to begin this process, during the CCTRT (sadag-final-09aug17-en.pdf (icann.org)<https://www.icann.org/en/system/files/files/sadag-final-09aug17-en.pdf>, but obviously barely scratched the surface. Perhaps a more comprehensive study, funded by ICANN rather than the CPH or CSG might be in order? I know DAAR provides some answers but it seems to be more of a survey than an example of rigorous research. Specifically to your questions.

  1.  What information do you use and how do you use it to assess DNS Abuse levels?
This is obviously where we are weak. There doesn’t appear to be a great source for DNS Abuse “levels,” particularly because of the short time period over which a particular initiative takes place. A snapshot analysis doesn’t seem to get the full picture. The ALAC relies on the concerned raised by the GAC and the SSAC to fuel our belief that there’s more we should be doing. A recent report from Microsoft suggests the problem is bigger than we realize and David Taylor’s analysis of “responsiveness,” even among those who have signed onto the framework, seems damning.
  2.  What are the ALAC’s pain points regarding DNS Abuse?
Not sure to answer this in terms of how it’s handled inside ICANN or more generally from where our interests stems. To the latter point, we’re tasked with advancing the interests of those not represented by a constituency in the GNSO, namely those engaged in everyday use of the internet, as opposed to registrants. As the user base continues to grow, as we all desire, so too will the numbers of less sophisticated users, more easily duped by a phishing, malware or fraudulent advertising attack.
As for the situation inside ICANN, the At-Large community have attempted to engage constructively as opposed to “attacking” the CPH, focusing instead on so-called “bad actors.” The first session<https://community.icann.org/display/atlarge/At-Large+Meetings+-+Monday%2C+09+March+2020?preview=/124847126/126428447/CCWholistic02.pdf> was an attempt to bring the CPH and Contract Compliance into the same room to figure out where the holes are.

     *   What exactly are the relevant limits on Contract Compliance?
We feel this is a question which comes up constantly and is never successfully or consistently answered. It seems to be an area in which the ICANN community is constantly chasing it’s tail. It would seem that the only real enforced contract provision is payment. I’m sure this is an exaggeration but it seems to be a repeated situation where that is ultimately what foils a “ bad actor” after YEARS of neglect, if not outright facilitation of abuse. The answer to THIS question should be a HIGH priority. It might just be agreeing to an interpretation of the contracts or it might require an amendment to the contracts but this issue needs to stop being a merry go round.
     *   Insufficient Transparency from Contract Compliance
Contract Compliance undocumented endeavors at soft touch diplomacy with bad actors seem to need some better limits or, at least, transparency. For “the market” to play a role in this, knowing about legitimate complaints for every contracted party could help customers make better decisions about which businesses to use and help us better understand where policy development needs to take place.
     *   Deflection and Minimization of the Problem
I would say that one “pain point” is that our efforts have been largely “trolled” by certain members of the CPH, rather than engaging constructively. EVEN our effort to conceive of some sort of end user education campaign, to take the pressure off the CPH, was trolled. Jim, not to put you on the spot but, during one conversation, you said you didn’t even understand why this was being discussed because it affects such a small percentage of registered names. To date, we have proposed:

                                                              i.      Better contract enforcement

                                                             ii.      More tools for Contract Compliance

                                                           iii.      DNS Abuse “threshold,” an idea that found some support among the CPH at one point

                                                           iv.      Predictive Analytics platform, perhaps financed by ICANN

The At-Large community has absolutely no desire to over regulate or over tax the CPH and we understand most of the contracted parties, particularly those showing up to meetings, are trying to do well and continuously improve. That said, this notion that it’s somehow not “our place,” to be trying to help is nothing short of offensive. It is the active participation of the ALAC and GAC that enable the ICANN to portray itself as something other than a trade association. The At-Large mandate is to advance the interests of those MOST impacted by DNS Abuse. That said, we WELCOME suggestions on how better to engage with the CPH for constructive outcomes.

  1.  Are you seeing practices from registrars or registries you find helpful?
If we haven’t said it enough, the At-Large appreciates the efforts of those behind the Framework for DNS Abuse and the huge efforts that went into cooperation with law enforcement to track down COVID related abuse. We’d love to see the framework evolve to include specific commitments and metrics, however, for it to be something on which the community could truly rely.

We hope these answers are constructive and not inflammatory as it is our intention to find the most effective ways to proceed to further minimize the incidence of DNS Abuse , in all its forms. Thanks for the opportunity to be part of your conversation.

Maureen, Joanna & Jonathan

From: Keith Drazek <kdrazek at verisign.com<mailto:kdrazek at verisign.com>>
Date: Friday, January 22, 2021 at 12:00 PM
To: "maureen.hilyard at gmail.com<mailto:maureen.hilyard at gmail.com>" <maureen.hilyard at gmail.com<mailto:maureen.hilyard at gmail.com>>, Jonathan Zuck <JZuck at innovatorsnetwork.org<mailto:JZuck at innovatorsnetwork.org>>, "jkuleszaicann at gmail.com<mailto:jkuleszaicann at gmail.com>" <jkuleszaicann at gmail.com<mailto:jkuleszaicann at gmail.com>>
Cc: "Brian F. Cimbolic" <BCimbolic at pir.org<mailto:BCimbolic at pir.org>>, Jim Galvin <jgalvin at afilias.info<mailto:jgalvin at afilias.info>>, Graeme Bunton <gbunton at tucows.com<mailto:gbunton at tucows.com>>
Subject: Engagement on DNS Abuse

Hello Maureen, Jonathan and Joanna,

I hope you’re all doing well and staying healthy and safe. I am reaching out to you on behalf of the Contracted Party House DNS Abuse Working Group as we look ahead to ICANN 70 and the rest of 2021.

The Contracted Party House (CPH) DNS Abuse Group is conducting outreach to our friends in other SO/AC/SG/Cs regarding DNS Abuse. As previously noted by the CPH, DNS Abuse<https://rrsg.org/wp-content/uploads/2020/10/CPH-Definition-of-DNS-Abuse.pdf> comprises five categories: phishing, pharming, malware, botnets, and spam when it acts as a delivery mechanism for one of the other forms of DNS Abuse.

We want to open a more direct dialogue to understand pain points, hear suggestions and identify common ground where we can work together to mitigate DNS Abuse.  Is there a subset of the At-Large focusing on DNS Abuse questions that would be able to join the CPH DNS Abuse group on a call to discuss this topic? We want to encourage frank and productive discussions  on the topic that lead to really informing our dialogues and actions.

As a starting point, we propose the following questions to guide our discussion.  Are there any other questions ALAC would like discuss?:

What information do you use and how do you use it to assess DNS Abuse levels?

What are the ALAC’s pain points regarding DNS Abuse?

Are you seeing practices from registrars or registries you find helpful?

Please let us know if a subgroup of the ALAC would be willing to join us.  Our group meets regularly on Tuesdays at 1500 UTC.  If so, please propose a Tuesday when you are available.

Best regards,

Keith

Keith Drazek

Vice President, Public Policy & Government Relations

Verisign, Inc.

+1-571-377-9182

Kdrazek at verisign.com<mailto:Kdrazek at verisign.com>

--

Kind regards,

Joanna Kulesza

-------------------

Joanna Kulesza, PhD

University of Lodz, Poland

ICANN ALAC Vice Chair

SOI: https://community.icann.org/display/atlarge/Joanna+Kulesza+SOI

TT: @KuleszaJ

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