[Gnso-epdp-team] "Abusive" use of SSAD
vgreimann at key-systems.net
Wed Oct 9 15:44:59 UTC 2019
one per minute still sounds reasonable to me as it allows you 1440
queries per day, which should be sufficient for most legitimate purposes
(with most registrars), especially given that each request will have to
be reviewed. I can tell you right now that if our registrars would get
the full quota of such a rate limit, requests would get backed up pretty
And I guess no one will want a response like this:
"Thank you for sending a disclosure request. Your request is currently
number 356.152.425 in the queue, which means you can expect a response
on or before December 21, 2119. "
So setting realistic limitations will be essential for this system to work.
Harvesting and mining to me is any activity that is designed to
indiscriminately access registration records either with the purpose of
finding records that match a specific search parameters (mining) or is
designed to create a duplicate copy of the registration base (or parts
So harvesting is basically the preparatory activity of actors such as
spear phishers, spammers, DomainTools, autocrat governments, etc, e.g.
everyone who has an interest in obtaining a (partial) copy of the
database for whatever purpose.
And mining is digging in the database with the hope of finding specific
Others may have other or broader definitions, and these definitions may
need more work, but these are my assiociations with these terms.
Am 09.10.2019 um 17:31 schrieb Mark Svancarek (CELA):
> As we have not defined high volume, I think it is premature to say
> that its utility has passed. Recall, a few days ago you said that 1
> request per minute would be an acceptable rate limit. That tells me
> we have a long way to go.
> Harvesting and mining are similarly undefined. What detectible
> behavior would you prohibit?
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> *On Behalf Of
> *Volker Greimann
> *Sent:* Wednesday, October 9, 2019 1:53 AM
> *To:* gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] "Abusive" use of SSAD
> Hi Mark,
> I think the times of legitimate high volume requests have passed.
> There are now less invasive methods of confirming domain ownership -
> such as modifications to the DNS records - that do not require knowing
> the personal data whom the domain belongs to. High volume requests are
> almost always an indicator for abuse.
> You have a point about request formats and we should allow some leeway
> for formats that have been accurate recently.
> If the data has actually changed, then that would not be a request for
> the same data anymore. But I I think we need to have some form of cap
> for requests for the dame domain by the same requestor. Two to three
> requests over the course of as many months probably would not count as
> Circumventing legitimate rate limits is abusive use of the system as
> those limits are there for a reason. If multiple vendors are used that
> access the data, each of those vendors would have to be accredited
> seperately and therefore not fall under the circumvention rule. If
> those vendors are however affiliated entities, this would be
> different. Which brings me to another affiliation requirement: Provide
> list of all affiliated entities that are already accredited, or have
> applied for accreditetion, similar to the obligation of registrars to
> provide lists of all affiliated registrars to ICANN.
> I think the terms harvesting and mining speak for themselves but I
> assume we can find a commonly acceptable definition.
> Am 09.10.2019 um 04:25 schrieb Mark Svancarek (CELA) via Gnso-epdp-team:
> Thanks, James. Here are my concerns:
> * Some abuse may be high-volume, but high volume is not
> inherently abusive. If there are industry-standard methods
> for distinguishing denial-of-service attacks from other
> high-volume activity, we should adopt them here.
> * Request formats may change over time. Use of outdated formats
> during a transition period is not abusive.
> * Subsequent requests for data where the format has been
> improved (e.g. missing fields have been populated; more
> appropriate basis has been submitted; more information that
> has been discovered during an ongoing investigation is added;
> etc.) is acceptable.
> * Repeated requests for a domain name record over are
> justifiable when it is reasonable to assume that domain name
> registration data is likely to have changed during an
> * In the Port 43 public WhoIs system some requestors used
> multiple and/or spoofed IP addresses to avoid rate limits
> imposed by registrars. Until issues of SLAs and funding are
> resolved, we cannot assume that rate limiting, or quota
> systems, will apply to SSAD. Whatever systems are ultimately
> put in place, the following observations about IP addresses
> and distributed requests should be considered:
> o It is not unusual to have a case worked on by multiple
> vendors/attorneys/platforms (e.g. one organization for
> initial take down requests, another to handle escalations,
> outside counsel for follow-up and/or suit).
> o It is not unusual to have a case worked on from multiple
> o It is not unusual for a requestor to use a VPN.
> o Credentialed access should be based on credentials and be
> neutral to IP addresses - so mitigations based on IP
> addresses are only applicable for the noncredentialled
> users of SSAD, if at all.
> * I am very concerned about the undefined terms “harvesting” and
> “mining”, which seem to me to be more about intent than any
> specific activity. Until we specifically describe the
> behavior to be blocked, we should remove the last bullet.
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org>
> <mailto:gnso-epdp-team-bounces at icann.org> *On Behalf Of *James M.
> *Sent:* Tuesday, October 8, 2019 7:15 PM
> *To:* gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>
> *Subject:* [Gnso-epdp-team] "Abusive" use of SSAD
> Colleagues –
> Following up with my homework from last Thursday, here is the
> non-exhaustive list of “abusive” SSAD behaviors.
> I’ve been in discussions with Mark SV, and note that he has some
> concerns. Expect his comments/edits in a separate message that
> will be a fast-follow to this post.
> *James Bladel*
> “Abusive” use of SSAD may include (but is not limited to) the
> following behaviors/practices:
> 1. High volume submissions of malformed or incomplete requests.
> 2. Frequent duplicate requests that were previously fulfilled
> or denied.
> 3. Use of distributed or spoofed source addresses or platforms
> to circumvent quotas or rate limits.
> 4. Use of false or counterfeit credentials to access the system.
> 5. Storing/delaying and sending high volume requests with the
> intention of causing SSAD or other parties to fail SLA performance.
> 6. Attempts or efforts to mine or harvest the data protected
> by SSAD.
> As with other access policy violations, abusive behavior can
> result in suspension or termination of access to the SSAD.
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> Volker A. Greimann
> General Counsel and Policy Manager
> *KEY-SYSTEMS GMBH*
> T: +49 6894 9396901
> M: +49 6894 9396851
> F: +49 6894 9396851
> W: www.key-systems.net
> Key-Systems GmbH is a company registered at the local court of
> Saarbruecken, Germany with the registration no. HR B 18835
> CEO: Alexander Siffrin
> Part of the CentralNic Group PLC (LON: CNIC) a company registered in
> England and Wales with company number 8576358.
Volker A. Greimann
General Counsel and Policy Manager
T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
Key-Systems GmbH is a company registered at the local court of
Saarbruecken, Germany with the registration no. HR B 18835
CEO: Alexander Siffrin
Part of the CentralNic Group PLC (LON: CNIC) a company registered in
England and Wales with company number 8576358.
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