[council] Study on Whois Privacy & Proxy Service Abuse

[Glen de Saint Géry <Glen@xxxxxxxxx>]

https://www.icann.org/en/news/public-comment/whois-pp-abuse-study-24sep13-en.htm
Study on Whois Privacy & Proxy Service Abuse
Comment / Reply Periods (*)
Comment Open Date: 24 September 2013
Comment Close Date: 22 October 2013 - 23:59 UTC
Reply Open Date: 23 October 2013
Reply Close Date: 13 November 2013 - 23:59 UTC
Important Information Links
Public Comment 
Announcement<https://www.icann.org/en/news/announcements/announcement-24sep13-en.htm>
To Submit Your Comments 
(Forum)<mailto:comments-whois-pp-abuse-study-24sep13@xxxxxxxxx>
View Comments 
Submitted<http://forum.icann.org/lists/comments-whois-pp-abuse-study-24sep13/>
Brief Overview
Originating Organization:
GNSO
Categories/Tags:

 *   Policy Processes
Purpose (Brief):

This study, conducted by the National Physical Laboratory (NPL) in the United 
Kingdom, analyzes gTLD domain names to measure whether the percentage of 
privacy/proxy use among domains engaged in illegal or harmful Internet 
activities is significantly greater than among domain names used for lawful 
Internet activities. Furthermore, this study compares these privacy/proxy 
percentages to other methods used to obscure identity - notably, Whois phone 
numbers that are invalid.

These findings will help the community understand the role that privacy and 
proxy service abuse plays in obscuring the identities of parties engaged in 
illegal or harmful activities, including phishing, cybersquatting, hosting 
child abuse sexual images, advanced fee fraud, online sale of counterfeit 
pharmaceuticals, and more.
Current Status:

This Public Comment solicitation represents an opportunity for the community to 
consider the study results detailed in this report, provide feedback and 
request further clarifications. In parallel, ICANN and NPL will conduct 
Webinars to facilitate feedback by summarizing this study's purpose, 
methodology, key findings, and conclusions.
Next Steps:

NPL will consider all comments submitted to this Public Comment forum during 
the comment period, incorporate any needed clarifications, and then publish a 
final version of this Whois Privacy and Proxy Service Abuse study report. It is 
expected that this report will inform future GNSO policy development in 
relation to the Whois system.
Staff Contact:
Mary Wong
Email Staff 
Contact<mailto:policy-staff@xxxxxxxxx?subject=More%20information%20on%20the%20Study%20on%20Whois%20Privacy%20and%20Proxy%20Service%20Abuse%20public%20comment%20period>
Detailed Information
Section I: Description, Explanation, and Purpose:

At the request of the GNSO 
Council<https://community.icann.org/display/gnsocouncilmeetings/Motions+28+April+2011>,
 ICANN engaged the National Physical Laboratory (NPL) in the United Kingdom to 
test the hypothesis that "A significant percentage of the domain names used to 
conduct illegal or harmful Internet activities are registered via privacy or 
proxy services to obscure the perpetrator's identity."

To provide empirical data of use to Whois policy-making, NPL set out to measure 
whether the percentage of privacy/proxy use among domains engaged in various 
kinds of illegal or harmful Internet activities is greater than among domain 
names used for lawful Internet activities. Additionally, because privacy/proxy 
policy changes could prompt malicious registrants to elude contact in other 
ways, NPL also measured other methods used to obscure perpetrator identity - 
notably, invalid Whois phone numbers.

This study, led by Dr. Richard Clayton of the University of Cambridge, gathered 
large representative samples of domain names implicated in various illegal or 
harmful online activities, ranging from unsolicited phishing, typosquatting, 
and malware distribution to hosting child abuse sexual images, advanced fee 
fraud (also known as "419 scams"), and online sale of counterfeit 
pharmaceuticals. Key technical inputs were also provided by Professor Tyler 
Moore of Southern Methodist University and Dr Nicolas Christin of Carnegie 
Mellon University.

By examining sampled incidents and Whois data associated with domain names 
across the top five gTLDs - .biz, .com, .info, .net and .org - this study 
measured how often privacy or proxy services were abused by perpetrators 
(alleged and confirmed). Additionally, these results were compared to 
privacy/proxy use among domains engaged in lawful and harmless activities 
(e.g., banks and legal pharmacies), chosen to mirror studied illegal/harmful 
activities. Finally, researchers attempted to call registrants for a subset of 
these domain names not using privacy or proxy services, to determine whether 
they could in fact be contacted with only Whois data.

This draft report summarizes project activities, methodology, sampled data and 
findings, including statistical analysis of differences observed by the 
research team. These study findings will help the community understand the role 
that privacy and proxy service abuse plays in obscuring the identities of 
parties engaged in illegal or harmful Internet activities.

The GNSO Council is now seeking community review and feedback on the draft 
report. The purpose of this Public Comment period is to ensure that study 
results have been communicated clearly and to solicit feedback on desired 
clarifications (if any).
Section II: Background:

As part of its effort to develop a comprehensive understanding of the gTLD 
Whois system, the GNSO Council expressed an interest in conducting an in-depth 
study of privacy and proxy service abuse among gTLD domain names registrants 
engaged in illegal or harmful Internet activities. At the GNSO's request, ICANN 
issued a Request for Proposal (RFP) in May 2010 describing a study to 
methodically analyze a representative sample of gTLD domains associated with a 
variety of illegal or harmful Internet activities. By comparing how often these 
"bad actors" use privacy/proxy services with overall privacy/proxy use, the 
GNSO hoped to prove or disprove its hypothesis that a significant percentage of 
the domain names used to conduct illegal or harmful Internet activities are 
registered via privacy or proxy services in order to obscure the perpetrator's 
identity.

After considering RFP responses received from researchers willing to undertake 
this Privacy/Proxy Abuse study, as well as questions raised by both researchers 
and reviewers, the GNSO Council decided to fund a somewhat revised study 
proposed by NPL. Specifically, NPL proposed studying many but not all of the 
illegal/harmful activities enumerated by the RFP, using samples obtained 
largely from "live feeds" and authoritative sources. NPL declined to study DoS 
attacks, DNS poisoning, IP theft, and on-line stalking using incidents 
submitted by victims, questioning their relevance and/or the ability to gather 
reliably representative samples.

In April 2011, this revised study was approved by the GNSO Council and awarded 
to NPL. When initiating this study, the GNSO Council asked that the study 
report expressly note that this study's purpose is only to analyze "bad 
actors". Notwithstanding the legal or harmless domain names studied here for 
comparison purposes, many legitimate privacy/proxy customers are unaccounted 
for within the scope of this study. This study does not attempt to measure 
privacy/proxy use or Whois accuracy across all gTLDs, as did broader studies 
such as that performed by NORC at the University of Chicago in 2010.

The findings from this study are intended to provide empirical data needed to 
understand the role that privacy and proxy service abuse plays in obscuring the 
identities of parties engaged in illegal or harmful activities. This empirical 
data will create a baseline for evaluating potential Whois and Privacy/Proxy 
service policy changes.
Section III: Document and Resource Links:

Whois Privacy and Proxy Service Abuse Study Draft 
Report<http://gnso.icann.org/en/issues/whois/pp-abuse-study-20sep13-en.pdf> 
[PDF, 624 KB]
Section IV: Additional Information:

Whois Privacy/Proxy Abuse Study Terms of 
Reference<http://gnso.icann.org/issues/whois/whois-proxy-abuse-study-18may10-en.pdf>
 [PDF, 321 KB]

Whois Privacy/Proxy Abuse Study Staff 
Report<http://gnso.icann.org/issues/whois/gnso-whois-pp-abuse-studies-report-05oct10-en.pdf>
 [PDF, 437 KB]

GNSO Council Motion April 
2011<https://community.icann.org/display/gnsocouncilmeetings/Motions+28+April+2011>

NPL Selected to Conduct a gTLD Whois Privacy and Proxy Abuse 
Study<http://blog.icann.org/2012/04/national-physical-laboratory-of-the-uk-selected-to-conduct-a-gtld-whois-privacy-and-proxy-abuse-study/>

Additional Whois studies have also been conducted at the request of the GNSO 
Council, as summarized at: http://gnso.icann.org/issues/whois/

________________________________

(*) Comments submitted after the posted Close Date/Time are not guaranteed to 
be considered in any final summary, analysis, reporting, or decision-making 
that takes place once this period lapses.


Glen de Saint Géry
GNSO Secretariat
gnso.secretariat@xxxxxxxxxxxxxx
http://gnso.icann.org