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CleanDNS Editorials: Don’t Rain on Their Parade

Don’t Rain on Their Parade!

CleanDNS Editorials: measuring the impact of DNS Abuse management efforts through remediation and disruption, not just volume of reports

By Alan Woods, CleanDNS Chief Legal Officer | Article publication date: 3 February 2025.

Did you know that almost 10 quintillion raindrops (9.72×1018) likely falls on planet Earth every year? That’s about 486,000,000,000,000 litres of water. Think of the floods, drowning, property damage, cold, sickness, death, destruction etc. that amount of water causes – we should stop rain altogether – right?

“Ah!” you might exclaim, “there is a huge flaw in your argument! Volume of rainfall isn’t bad. Rainfall usually gets dealt with – mostly by nature’s own processes and even some human intervention (be that bad or good). So, your argument is too simplistic!”

Of course that is right. We are not doomed by the sheer volume of the 10 quintillion raindrops. To measure the impact of raindrops, you don’t just consider the volume, but the means by which such volume is dealt with. Nobody is calling for the elimination of ALL rain. That would be impossible, not to mention the untold collateral damage that would cause. The point is, absolute volume as a metric is far easier to measure than the impact caused by that volume. We need to understand the full picture of what happened from the beginning of the process, right to the end to measure the actual impact – that’s just common sense.

So if this is common sense, why do we still pay any attention to those in the DNS Abuse conversation who insist on measuring impact by only counting the number of raindrops – or in this case- reports of abuse?

Volume of reports as a measurement is one-dimensional. It serves only to prove one thing: DNS Abuse happens. We already know this. Consistently ignored, however, and in particular by those tending to be the loudest or most vocal in the room, are any real considerations of how those reports are being handled. Minimal heed is being paid to an entire end-to-end process that should kick into action upon the report of abuse from ingest to disruption or mitigation. When those ‘loud’ commentators remain fixated on just considering the volume of reports received alone, this actively blocks the conversation from moving beyond the “DNS Abuse happens” stage. This is not a solution-focused use of our time and effort, and we need to finally move on.

Appropriate Actions, by the Appropriate Parties

The fact of the matter is, disruption and mitigation of abuse happens every day. Some entities do the minimum, some do FAR more than others, and some do little or nothing at all. With this single statement, the conversation changes from ‘is there a problem?’ to ‘what action is necessary to address the problem?’. Volume does not paint the picture of impact. Similarly, measuring only takedowns is not a measure of impact, but merely one potential outcome of process that seeks to identify the appropriate intervention at an appropriate time. Simplistic assessments of impact that rely on absolutes of volume and resultant takedowns of domains, simply does not reflect the levels of effort being undertaken to address abuse. It also doesn’t reflect the fact that an appropriate action may require escalation to a third party, such as a hosting provider, or a potentially exploited platform such as file shares and social media platforms. The DNS Abuse amendments were drafted to provide impetus on the efforts undertaken to address abuse across the internet infrastructure stack, not only by a registry or registrar. They seek to consider nuance – circumstances of the case, readily available evidence, appropriateness of action, and the appropriateness of the party to take that action.

Twisted statistics – What to watch for at ICANN82

Consider how many reports and papers you have seen that seek to address and include mitigation and disruption? Of those that do, how is mitigation being measured beyond merely measuring takedowns? CleanDNS, of course, talks about the spectrum of disruption at every opportunity we get . The folks at the Netbeacon Institute make efforts to show mitigation “at registrar, registry, a hosting provider, or another relevant actor” as an important aspect of their Netbeacon Map[1] reports. What about others? Critical assessment should seek to understand mitigation and disruption beyond the imprecision of just counting the takedowns. Registries and registrars are not the one stop shop to fix abuse online. Just because a domain remains up, does not mean that a mitigation has not occurred, nor does it mean that an action of disruption was not taken – and any claiming otherwise, is misunderstanding the task. We are hopeful that ICANN, both the Community and Org, will continue to seek to understand and measure compliance with the amendments based not on number of reports and the number of takedowns alone, but on the assessment of the real efforts to mitigate or disrupt. That is where the true impact lies.  

Going into this ICANN meeting, we would ask you to listen and critically assess the language being used in DNS Abuse conversations (as there are many on our dance cards). In referring to ‘statistics’ on abuse, consider these important questions …

Who will focus on just the number of reports?

Who will actually addresses mitigation?

How is that ‘mitigation’ being defined?

Does this ‘mitigation’ include actions other than mere takedown?  

Completely incidentally, CleanDNS is also very much looking forward to supporting further discussions on the conflicts of interest and the Statement Of Interests (SOI) topic that will be raised at many ICANN tables.

For us, It’s time to cut straight to the point, draw the line, and actually focus on elevating those parties who are making efforts for real practical change (cross-stack appropriate collaboration and interoperability in approach etc.) – stagnant and outdated arguments are getting in the way of true innovation and action – and as always we continue to support  “appropriate action, by the appropriate parties, at the appropriate time.”

In 2024, CleanDNS mitigated 98% of domains escalated for remediation.

These actions (taken by the appropriate party at the appropriate time) are all part of the constantly evolving fight against DNS Abuse and online harms. Want to learn more about our mission of evidenced, actionable reporting and streamlined escalation? Reach out to our team or meet with us at the ICANN82 Community Forum in Seattle. We hope to see you there, and we hope you’ll join us in Cleaning Up the Internet for Good.

– Written by Alan Woods, CleanDNS Chief Legal Officer

1 https://netbeacon.org/how-have-the-gtld-contractual-amendments-impacted-dns-abuse/

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CleanDNS Editorials: Insights from the people on the front lines of the fight against DNS Abuse. CleanDNS Editorials offer a look into our mission of detecting, evidencing, escalating, and mitigating, DNS Abuse and online harms through actionable reports and streamlined processes. Take an inside view at what’s being done to reduce victimization across the Internet, straight from the people who know it best.

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