[RRA] [EXTERNAL] Re: [Ext] Re: RRA Amendment Notification for .ngo, .ong, .org, xn--c1avg, xn--i1b6b1a6a2e, and xn--nqv7f [ ref:_00D616tJk._5004MqEa5P:ref ]

Brian F. Cimbolic brian at pir.org
Wed Mar 23 14:50:05 UTC 2022

Dear Catherine and the RrSG Review Team:

First, thank you for the time you took to review the proposed revisions to PIR’s RRA. We appreciate your consideration and the questions you provided. We respond to the questions below.

(1) At the outset, please note this provision is not intended to substitute PIR for ICANN compliance; we fully recognize that we are not a party to the Registrar Accreditation Agreement and are not seeking to enforce that agreement.

Our intent with this provision is to have a contractual tool available to help PIR address the infamous and proverbial “Bad Actors not at the Table” on DNS Abuse. PIR has observed a few registrars (to our knowledge, none of which participate in the RrSG) that appear to believe they do not have any meaningful obligation on DNS Abuse mitigation even in the clearest “slam-dunk” instances of malicious registrations for phishing or malware. When we refer these slam-dunk instances of DNS Abuse to these registrars for reasonable response, we either do not receive a response at all or are told to address the abuse ourselves. This approach causes several problems:

  *   It puts the responsible actors in the RrSG at a competitive disadvantage because they bear the cost and burden of having processes, systems, and personnel in place to reasonably respond to DNS Abuse where these actors do not;
  *   It increases the time the maliciously registered domains are live and the harm caused by clear instances of DNS Abuse; and
  *   It harms the overall trust and reputation of .ORG and the other TLDs for which PIR serves as Registry Operator.

PIR takes DNS Abuse seriously. Without this provision (or something of the same force and effect), PIR has to rely on ICANN-compliance managed processes to investigate and respond to instances of these registrars failing to implement even minimal abuse processes. We don’t believe that situation is in the best interest of responsible registrars, PIR, registrants, or end-users of the TLDs for which PIR is the steward. With respect to the Registrars that participate in the RrSG, we do not believe we will ever have to act on this provision, but having it provides us with a tool to deal with this type of edge case with an isolated registrar that blatantly dismisses its DNS Abuse obligations.

As you know, similar provisions have been approved for other RRAs, including for Donuts very recently, covering over 240 TLDs.  We believe that Donuts’ rationale for its inclusion of a similar provision was the same as ours.

(2) We confirm that this was a typo and will insert a comma between “phishing” and “piracy.”

Again we thank you for your review and hope this explanation was helpful. As noted in our initial cover letter to ICANN transmitting the proposed changes to the RRA, we would appreciate it if the RrSG could conclude this review process not later than April 8, 2022 to accommodate timelines in the registrar onboarding process.

All the best,


Brian Cimbolic | Vice President, General Counsel
brian at pir.org<mailto:brian at pir.org> | 703.889.5752 | www.thenew.org<applewebdata://98ECC0AE-88EB-4427-B85E-6E9A6F544FBE/www.thenew.org> | Power your inspiration. Connect your world.

[cid:image002.png at 01D83EA2.D9459630]

Confidentiality Note:  Proprietary and confidential to Public Interest Registry.  If received in error, please inform sender and then delete.

From: Catherine Merdinger <catherine at donuts.email>
Date: March 22, 2022 at 4:51:06 PM EDT
To: Camia Frank <camia.frank at icann.org>
Cc: ICANN Global Support Center <globalsupport at icann.org>, secretariat at icannregistrars.org, rra at icann.org, Aheineman at godaddy.com, Andrew Dickson <andrew.dickson at icann.org>, Andee Hill <andee.hill at icann.org>, Amanda Fessenden <amanda.fessenden at icann.org>, Morgan Govaars <morgan.govaars at icann.org>, Jeanne Gregg <jeanne.gregg at icann.org>, Alina King <Alina at pir.org>
Subject: [EXTERNAL] Re: [Ext] Re: RRA Amendment Notification for .ngo, .ong, .org, xn--c1avg, xn--i1b6b1a6a2e, and xn--nqv7f [ ref:_00D616tJk._5004MqEa5P:ref ]

CAUTION: This email came from outside your organization. Don’t trust emails, links, or attachments from senders that seem suspicious or you are not expecting.

The Registrar Stakeholder Group has reviewed the proposed changes to the PIR RRAs and has two questions that may require follow up from PIR.

1. Members had concerns about the obligation contained in Section 3.2.3 of the revised RRA that "Registrar shall have processes in place to appropriately address reports of abusive activities as defined by ICANN" specifically because registrars are already required to do this under our agreements with ICANN.  We would appreciate a brief explanation from PIR as to why registrars need to be separately obligated to PIR to comply with the terms of the RAA.
2. We also think there may be a typo in section 3.6.7. of the revised RRA.  Specifically, there is no comma between "phishing" and "piracy."  If that is not a typo, we'd like to better understand exactly what "phishing piracy" would be.  If it is a typo, we just ask that you fix it by adding a comma between the two words.  I don't believe we need to see an additional redline of this change, just confirmation that it will be changed in the final version.

Catherine Merdinger | Corporate Counsel | Donuts Inc. | +1.319.541.9416 | she/her

On Tue, Mar 1, 2022 at 3:19 PM Camia Frank <camia.frank at icann.org<mailto:camia.frank at icann.org>> wrote:
Dear Catherine,

Thank you for the follow-up message to inform us that you require additional review time. We approve your request for an extension.
We look forward to hearing back from you by 22 March 2022.
Warm Regards,
Camia Frank
GDS Service Delivery

From: Catherine Merdinger <catherine at donuts.email>
Date: Friday, February 25, 2022 at 1:07 PM
To: ICANN Global Support Center <globalsupport at icann.org<mailto:globalsupport at icann.org>>
Cc: "secretariat at icannregistrars.org<mailto:secretariat at icannregistrars.org>" <secretariat at icannregistrars.org<mailto:secretariat at icannregistrars.org>>, "rra at icann.org<mailto:rra at icann.org>" <rra at icann.org<mailto:rra at icann.org>>, "aheineman at godaddy.com<mailto:aheineman at godaddy.com>" <aheineman at godaddy.com<mailto:aheineman at godaddy.com>>, Andrew Dickson <andrew.dickson at icann.org<mailto:andrew.dickson at icann.org>>, Andee Hill <andee.hill at icann.org<mailto:andee.hill at icann.org>>, Amanda Fessenden <amanda.fessenden at icann.org<mailto:amanda.fessenden at icann.org>>, Morgan Govaars <morgan.govaars at icann.org<mailto:morgan.govaars at icann.org>>, Camia Frank <camia.frank at icann.org<mailto:camia.frank at icann.org>>, Jeanne Gregg <jeanne.gregg at icann.org<mailto:jeanne.gregg at icann.org>>, "alina at pir.org<mailto:alina at pir.org>" <alina at pir.org<mailto:alina at pir.org>>
Subject: [Ext] Re: RRA Amendment Notification for .ngo, .ong, .org, xn--c1avg, xn--i1b6b1a6a2e, and xn--nqv7f [ ref:_00D616tJk._5004MqEa5P:ref ]


After discussion with the RrSG RRA Review Team and given the ICANN meeting scheduled in the coming weeks, we would like to request a one-week extension to our review period, such that the new deadline would be March 22, 2022.  Please let me know if that is acceptable as soon as possible.

Catherine Merdinger| Associate Corporate Counsel |Donuts Inc. | +1.319.541.9416

On Tue, Feb 22, 2022 at 5:22 PM Catherine Merdinger <catherine at donuts.email> wrote:
Thank you Camia.

I am confirming receipt on behalf of the RrSG's RRA Review Team.  We will review the documents and respond by the noted deadline.

Catherine Merdinger| Associate Corporate Counsel |Donuts Inc. | +1.319.541.9416

On Tue, Feb 22, 2022 at 5:09 PM ICANN Global Support Center <globalsupport at icann.org<mailto:globalsupport at icann.org>> wrote:
Hello Ashley,

Attached, please find the cover letter and the red-lined RRA Amendment for the following TLDs submitted by Public Interest Registry to be shared with your Stakeholder Group:

  *   .ngo,
  *   .ong,
  *   .org
  *   xn--c1avg
  *   xn--i1b6b1a6a2e
  *   xn--nqv7f
Please note that in the cover letter and the proposed amendment there is reference to 4 TLDs (.gives, .giving, .charity, .foundation) for which Public Interest Registry is not the registry operator. This RRA Amendment review does not apply to such TLDs. A future RRA Amendment request will be submitted for each of those TLDs if and when Public Interest Registry becomes the registry operator for those TLDs.

We are requesting a response by 23:59 UTC on Tuesday, 15 March 2022 to let us know if your Stakeholder Group has concerns, does not have concerns, or if additional review time is required. If the Stakeholder Group has concerns, ICANN org will continue with the next step of the RRA Amendment Procedure, which is to consult with the RrSG and the Registry Operator to attempt to resolve any such concerns.

Warm Regards,

Camia Frank
GDS Service DeliveryError! Filename not specified.

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