[anti-abuse-wg] Report & Co-Chair's Decision on Proposal 2019-04

As abuse notices might have legal effect, a company could state they will only accept them by fax, or with registered mail. 

A webform, for a regulator, most likely will be seen as an 'upgrade'. Note that FB and Google also *only accept* complaints, notices etc via webforms. So one can argue a webform is abuse@ 2.0 :)​ So I do not share you view that a webform is a second rate instrument for accepting abuse notifications.

As for ECD/DSA that will most likely be subject to lobby forces beyond our imagination, so anything is possible there ... ​-- 
IDGARA | Alex de Joode | alex at idgara.nl | +31651108221 | Skype:adejoode


On Tue, 08-09-2020 15h 51min, Carlos Friaças <cfriacas at fccn.pt> wrote:
> 
On Tue, 8 Sep 2020, Alex de Joode wrote:
> 
> > There are a couple of things in play here.
> > Networks normally fall under the "mere conduit' provisions of the eCommerce Directive (ECD (EU law)), this
> > means they do not have a (legal) requirement to actively address abuse within their networks. They need to
> > forward the abuse to their customer, but basically that is it.
> 
> Before that, a webform may be in the way :-)
> 
> If the regulator understands that artificial 'requirement' to be a way of 
> avoiding that action of forwarding the abuse, then they might act. Or not.
> 
> 
> 
> > The up coming DSA (Digital Services Act, which
> > will supersede the ECD) (as it stand now) will retain this provision for networks. So the chance of regulation
> > (within the EU area) for networks with respect to 'abuse handling' is very low.
> 
> Unless there are some additional provisions...
> 
> 
> 
> > The proposal was flawed, no clear identifiable upside (except for a feel good factor) and a lot extra work for
> > no real gain.
> > 
> > If you want to fight the prevalence of internet abuse, ripe policy might not be your best avenue.
> 
> Clearly. But this comment is directly tied with the earlier suggestion of 
> renaming the WG...
> 
> 
> Regards,
> Carlos
> 
> 
> 
> 
> > Cheers,
> > Alex
> > 
> > ?-- IDGARA | Alex de Joode | alex at idgara.nl | +31651108221 | Skype:adejoode
> > 
> > On Tue, 08-09-2020 13h 33min, Suresh Ramasubramanian " target="_blank"><ops.lists at gmail.com> wrote:
> > Probably through regulation as you say. If ripe doesn?t want to be the Internet police they?ll suddenly find
> > that there actually is such a thing created and with oversight over them, sooner or later. Nobody is
> > going to like the result if that happens, neither the government nor ripe nor its membership.
> > 
> > --srs
> > 
> > ______________________________________________________________________________________________________________
> > From: anti-abuse-wg " target="_blank"><anti-abuse-wg-bounces at ripe.net> on behalf of Carlos Friaças via anti-abuse-wg
> > " target="_blank"><anti-abuse-wg at ripe.net>
> > Sent: Tuesday, September 8, 2020 4:44:26 PM
> > To: anti-abuse-wg at ripe.net " target="_blank"><anti-abuse-wg at ripe.net>
> > Subject: Re: [anti-abuse-wg] Report & Co-Chair's Decision on Proposal 2019-04  
> > 
> > Hi,
> > 
> > I would like to second Piotr's comment. Thank you for your hard work, and
> > for not quitting over anti-abuse.
> > 
> > As i read it consensus was not reached, and it's hard to dispute the
> > objections are not valid/admissible:
> > 
> > "
> > 1) Nick Hilliard and Erik Bais commented that the effort and cost to
> > implement this proposal are too great in relations to the benefits that
> > are alleged.
> > 
> > 2) Michele Neylon and Arash Naderpour commented that they oppose forcing
> > operators to use only email for
> > handling abuse reports and internal handling procedures should be solely
> > defined by the operator.
> > "
> > 
> > I just want to note that:
> > A) it's very hard to measure the benefits. some parties would see bigger
> > benefits than others.
> > B) converging abuse reports to email usage is a rule that is inexistent
> > *today*. people which are not worried about abuse, will likely want to
> > keep it that way... as a webform is an effective way of discouraging
> > reports.
> > 
> > 
> > At some point, people which discard abuse reports (or people which
> > simulate handling abuse reports) will not be able to run networks.
> > We're far from it, but if it gets to that point that will not be reached
> > through consensus, but probably through regulation.
> > 
> > 
> > Regards,
> > Carlos
> > 
> > 
> > 
> > 
> > On Mon, 7 Sep 2020, Piotr Strzyzewski via anti-abuse-wg wrote:
> > 
> > > On Mon, Sep 07, 2020 at 03:19:27PM +0000, Brian Nisbet wrote:
> > >
> > > Brian, Alireza, Tobias,
> > >
> > >> A few weeks ago we reached the end of the latest review phase for 2019-04. The Co-Chairs have worked
> > closely with the NCC Policy Development Office since then to try to make a decision on this policy. This
> > email contains a report on the Discussion Phase and Review Phase and then a final decision which, we
> > believe, is supported by the activity during those phases.
> > >>
> > >> As always, this is underpinned by the RIPE PDP - https://www.ripe.net/publications/docs/ripe-710
> > >
> > > [cut]
> > >
> > >> With all of this in mind, and with the continued failure of any kind of consensus from the working
> > group, the Co-Chairs have decided to withdraw this proposal. As always we would welcome proposals on
> > this and other matters, however we do not feel that there is any likelihood of 2019-04, regardless of
> > possible edits, reaching consensus in the short or medium term.
> > >
> > > Thank you for all your hard work here. It was not an easy task to
> > > fulfill. With this is mind, it is even more important that you have made
> > > this report. Thank you.
> > >
> > > Stay safe,
> > > Piotr
> > >
> > > --
> > > Piotr Strzy?ewski
> > >
> > 
> > 
> >

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