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MAAWG Public Policy Comments

M3AAWG actively seeks to provide the necessary technical and strategic guidance to protect end-users’ online experience as government, Internet and public policy agencies worldwide develop new Internet policies and legislation. Working to reduce the spread of spam, bots and malware, M3AAWG has submitted comments on these proposals:

2014 Comments
M3AAWG Comments on ICANN Misue Report
Submitted to the U.S. State Department in January 2014, responding to its request for Stakeholder Input on the Role of Governments, International Telecommunication Union Council Working Group on Internetprelated Public Policy Issues.
 
2013 Comments
Submitted to ICANN in December 2013
In response to ICANN's misue survey.
 
Submitted to ICANN in August 2013
In response to ICANN's Expert Working Group report.
 
M3AAWG Response to CWG-Internet Request for Online Consultation-Combatting Spam
Submitted to the ITU Council Working Group on International Internet–Related Public Policy Issues (CWG–Internet) in July 2013
In response to a request for comments on effectively countering and combatting spam.
 
M3AAWG Comments on Thick Whois Initial Report
Submitted to ICANN in July 2013

Comments on this report can also be viewed at the ICANN site
 
Submitted to the NIST in April 2013
Response to two questions in the National Institute of Standards and Technology Request for Information is also posted at the NIST site with comments from other organizations.
 
Submitted to Industry Canada in February 2013
Letter submitted in response to request for comments on the draft Electronic Commerce Protection Regulations related to CASL.
 
2012 Comments
 
Submitted to ICANN in September 2012
View the preliminiary report or all submitted comments at the ICANN site.
 
Submitted to RIPE in August 2012
Response to  RIPE’s proposal to introduce a new contact attribute named "abuse-c:"
 
Comments on ICANN WHOIS Policy Review Team Final Report
Submitted to ICANN in May 2012

Response to the final WHOIS Policy Review Team Report
 
Submitted to ICANN in March 2012
Responses to the WHOIS Review Team (WRT) draft report with M3AAWG recommendations.
 
2011 Comments
 
MAAWG Comments on Protect IP and SOPA
Submitted to U.S. Congress committees on the judiciary in December 2011
MAAWG outlined technical issues with S.968, Preventing Real Online Threats to Economic Creativity and Theft of Intellectual Property Act, and H.R.3261, Stop Online Piracy Act, in a letter to the judiciary committees of the U.S. Senate and U.S. House of Representatives. 
 
Responses to ICANN on issues in the draft report covering the intrnationalization of domains can be read at draft report comment site.
 
Responding to a Request for Information from the U.S. Department of Commerce (DoC) and U.S. Department of Homeland Security (DHS), the comments are also available on the NIST site.
 
MAAWG Comments on National Initiative for Cybersecurity Education (NICE) Draft Strategic Plan
MAAWG submitted comments in September 2011
The comments were submitted to the National Institute of Standards and Technologyon its draft NICE plan.
 
MAAWG Comments on CRTC's Draft Electronic Commerce Protection Regulations
A response from MAAWG to the Canadian commission were submitted in September 2011.
Submitted comments on the regulations to the Canadian Radio-television and Telecommunications Commission (CRTC) draft regulations are available online
 
MAAWG Comments to UK House of Commons Inquiry into Malware and Cyber-crime
MAAWG submitted a response in September 2011 to the Science and Technology Committee, UK House of Commons
The committee's inquiry covered a variety of questions related to malware and cyber-crime.
 
Comments on Dept. of Commerce Task Force's Green Paper
MAAWG comments were posted August 2011 on the Internet Task Force Cybersecurity Green Paper site in response to the DOC report.
MAAWG responded to the Department of Commerce (DOC) Internet Policy Task Force's seventy-seven page green paper on "Cybersecurity, Innovation and the Internet Economy."
 
Comments on ICANN's Draft FY2012 Budget
MAAWG comments were posted June 2011 on the ICANN site in response to ICANN's proposed budget.
MAAWG members, and our members' customers, like all Internet users, rely daily on Internet names. MAAWG commented on the proposed budget from the perspective of encouraging ICANN to continue to offer a reliable, high performance, cost effective, scalable and trustworthy system of domain names.
 
Comments on ICANN WHOIS Review Team
MAAWG Comments were submitted in April 2011 on the ICANN site in response to the ICANN Call for Public Comment
Responding to the ICANN WHOIS Review Team, MAAWG submitted comments on the useablity, access, accuracy and reliability of WHOIS and on the improvement of WDPRS.
 
Comments on UK BIS Consultation on Implementing the Revised EU Electronic Communications Framework
MAAWG comments were submitted December 2010 in response to the BIS proposal.
The UK Department for Business Innovation and Skills launched its proposals for implementing the revised EU Electronic Communications Framework. The BIS document set out their preferred approach to implementation and asked questions on a limited number of specific issues.
 
2010 Comments
 
MAAWG Response to U.S. Department of Commerce’s Internet Policy Task Force on the Global Free Flow of Information on the Internet
MAAWG comments were submitted November 2010 in response to the DoC request.
The U.S. Department of Commerce’s Internet Policy Task Force requested comments on government policies that restrict Internet information flow, seeking to understand why these restrictions have been instituted; what, if any, impact they have, and how to address negative impacts. The DoC will publish a report contributing to the Administration’s domestic policy and international engagement on these issues.
 
MAAWG Comments on ICANN FY 11 Update to Plan for Enhancing Internet Security, Stability & Resiliency
MAAWG comments were submitted November 2010 in response to ICANN’s Plan.
ICANN requested comments on an update to its initial plan that will be implemented in the 2010-2011 operational year. The updated plan is intended as a baseline document for ICANN and its community for organizing its security, stability and resiliency efforts.
 
MAAWG Comments on ICANN Study on the Prevalence of Domain Names Registered Using a Privacy or Proxy Registration Service
MAAWG comments were submitted October 2010 based on the ICANN request
ICANN conducted an exploratory study in 2009 to assess an approximate percentage of domain names (through a statistical sampling plan) contained in the top 5 gTLD registries that used privacy or proxy registration services. The study indicated that at least 18% (and probably not much more than 20%) of the domain names contained in the top 5 gTLD registries used privacy or proxy registration services.
 
MAAWG Letter Regarding Canadian Fighting Internet and Wireless Spam Act (FISA)
The MAAWG letter supporting elements of FISA was submitted September 2010.
MAAWG submitted a letter supporting the global sharing of abuse-fighting information between law enforcement that is included in Canadian Bill C-28 establishing the federal Fighting Internet and Wireless Spam Act (“FISA”).
 
MAAWG Comments on National Broadband Plan Recommendation to Create a Cybersecurity Roadmap
MAAWG comments were submitted in response to U.S. Federal Communications Commission recommendations in September 2010.
The U.S. FCC’s Public Safety and Homeland Security Bureau (PSHSB) requested comment on the creation of a Cybersecurity Roadmap. The plan would identify vulnerabilities to communications networks or end-users and develop countermeasures and solutions in preparation for, and response to, cyber threats and attacks in coordination with federal partners.
 
MAAWG Comments on Department of Commerce Cybersecurity, Innovation and the Internet Economy
MAAWG comments were submitted to the Department of Commerce’s request in September 2010. The DoC site has all submitted comments
The Department of Commerce’s Internet Policy Task Force undertook a comprehensive review of the nexus between cybersecurity challenges in the commercial sector and innovation in the Internet economy. The Department was seeking comments on measures to improve cybersecurity while sustaining innovation.
 
MAAWG Response to ICANN's Initial Report on Proposals for Improvements to the Registrar Accreditation Agreement (RAA)
The MAAWG response was submitted July 2010 in response to ICANN’s initial report for RAA improvements
The ICANN report describes recommendations on the proposed form of a Registrant Rights and Responsibilities Charter, and describing the potential topics for additional amendments to the RAA. It also includes a proposal for next steps the GNSO Council should consider in determining whether to recommend the ICANN Board adopt a new form RAA.
 
MAAWG Response to National Strategy for Trusted Identities in Cyberspace
MAAWG offered comments on the U.S. Department of Homeland Security’s strategy in July 2010 
The U.S. Department of Homeland Security’s draft plan is focused on maintaining a secure cyberspace, which is critical to the health of the economy and national security. It outlines how the federal government might address the recent and alarming rise in online fraud, identity theft, and misuse of information online.
 
MAAWG Comments on ARIN Draft Policy 2010-3 “Customer Confidentiality”
MAAWG submitted comments in March 2010. As recommended by MAAWG and others, ARIN changed course on this topic
The initial draft policy would have allowed ISPs to hide the true customer of a domain name. The revised Version 2 policy that was implemented recognized the need for the customer name to remain in the SWIP and RWHOIS information.
 
MAAWG Comments, FCC’s In the Matter of Preserving the Open Internet, GN Docket No. 09-191, WC Docket No. 07-52, Notice of Proposed Rulemaking, FCC 09-93 (Rel. Oct. 22, 2009)
MAAWG submitted these comments in January 2010 to the U.S. Federal Communications Commission on its open Internet proposal
The FCC requested public input on draft rules to preserve an open Internet. The FCC is seeking to preserve a platform based on a historically open architecture that has been accessible to anyone with a basic knowledge of its protocols.