<html><head><style id="axi-htmleditor-style" type="text/css">p { margin: 0px; }</style></head><body dir="" style="font-size: 10pt; font-family: "Source Sans Pro", sans-serif; background-image: none; background-repeat: repeat; background-attachment: fixed;">As abuse notices might have legal effect, a company could state they will only accept them by fax, or with registered mail. <div><br></div><div>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.</div><div><br></div><div>As for ECD/DSA that will most likely be subject to lobby forces beyond our imagination, so anything is possible there ... <br><div class="x-axi-signature"><br><div class="x-axi-signature" style="; font-size: 10pt; font-family: " source="" sans="" pro",="" sans-serif;"="">-- <div>IDGARA | Alex de Joode | alex@idgara.nl | +31651108221 | Skype:adejoode</div></div></div><br>On Tue, 08-09-2020 15h 51min, Carlos Friaças <cfriacas@fccn.pt> wrote:<br><blockquote style="margin-left: 10px; padding-left: 10px; border-left: 1px solid #ccc;"><div style="font-family: " source="" sans="" pro",="" sans-serif;="" font-size:="" 10pt;"="">On Tue, 8 Sep 2020, Alex de Joode wrote:<br><br>> There are a couple of things in play here.<br>> Networks normally fall under the "mere conduit' provisions of the eCommerce Directive (ECD (EU law)), this<br>> means they do not have a (legal) requirement to actively address abuse within their networks. They need to<br>> forward the abuse to their customer, but basically that is it.<br><br>Before that, a webform may be in the way :-)<br><br>If the regulator understands that artificial 'requirement' to be a way of <br>avoiding that action of forwarding the abuse, then they might act. Or not.<br><br><br><br>> The up coming DSA (Digital Services Act, which<br>> will supersede the ECD) (as it stand now) will retain this provision for networks. So the chance of regulation<br>> (within the EU area) for networks with respect to 'abuse handling' is very low.<br><br>Unless there are some additional provisions...<br><br><br><br>> The proposal was flawed, no clear identifiable upside (except for a feel good factor) and a lot extra work for<br>> no real gain.<br>> <br>> If you want to fight the prevalence of internet abuse, ripe policy might not be your best avenue.<br><br>Clearly. But this comment is directly tied with the earlier suggestion of <br>renaming the WG...<br><br><br>Regards,<br>Carlos<br><br><br><br><br>> Cheers,<br>> Alex<br>> <br>> ?-- IDGARA | Alex de Joode | <a href="mailto:alex@idgara.nl" target="_blank">alex@idgara.nl</a> | +31651108221 | Skype:adejoode<br>> <br>> On Tue, 08-09-2020 13h 33min, Suresh Ramasubramanian <a href="mailto:<ops.lists@gmail.com>" target="_blank"><ops.lists@gmail.com></a> wrote:<br>> Probably through regulation as you say. If ripe doesn?t want to be the Internet police they?ll suddenly find<br>> that there actually is such a thing created and with oversight over them, sooner or later. Nobody is<br>> going to like the result if that happens, neither the government nor ripe nor its membership.<br>> <br>> --srs<br>> <br>> ______________________________________________________________________________________________________________<br>> From: anti-abuse-wg <a href="mailto:<anti-abuse-wg-bounces@ripe.net>" target="_blank"><anti-abuse-wg-bounces@ripe.net></a> on behalf of Carlos Friaças via anti-abuse-wg<br>> <a href="mailto:<anti-abuse-wg@ripe.net>" target="_blank"><anti-abuse-wg@ripe.net></a><br>> Sent: Tuesday, September 8, 2020 4:44:26 PM<br>> To: <a href="mailto:anti-abuse-wg@ripe.net" target="_blank">anti-abuse-wg@ripe.net</a> <a href="mailto:<anti-abuse-wg@ripe.net>" target="_blank"><anti-abuse-wg@ripe.net></a><br>> Subject: Re: [anti-abuse-wg] Report & Co-Chair's Decision on Proposal 2019-04 <br>> <br>> Hi,<br>> <br>> I would like to second Piotr's comment. Thank you for your hard work, and<br>> for not quitting over anti-abuse.<br>> <br>> As i read it consensus was not reached, and it's hard to dispute the<br>> objections are not valid/admissible:<br>> <br>> "<br>> 1) Nick Hilliard and Erik Bais commented that the effort and cost to<br>> implement this proposal are too great in relations to the benefits that<br>> are alleged.<br>> <br>> 2) Michele Neylon and Arash Naderpour commented that they oppose forcing<br>> operators to use only email for<br>> handling abuse reports and internal handling procedures should be solely<br>> defined by the operator.<br>> "<br>> <br>> I just want to note that:<br>> A) it's very hard to measure the benefits. some parties would see bigger<br>> benefits than others.<br>> B) converging abuse reports to email usage is a rule that is inexistent<br>> *today*. people which are not worried about abuse, will likely want to<br>> keep it that way... as a webform is an effective way of discouraging<br>> reports.<br>> <br>> <br>> At some point, people which discard abuse reports (or people which<br>> simulate handling abuse reports) will not be able to run networks.<br>> We're far from it, but if it gets to that point that will not be reached<br>> through consensus, but probably through regulation.<br>> <br>> <br>> Regards,<br>> Carlos<br>> <br>> <br>> <br>> <br>> On Mon, 7 Sep 2020, Piotr Strzyzewski via anti-abuse-wg wrote:<br>> <br>> > On Mon, Sep 07, 2020 at 03:19:27PM +0000, Brian Nisbet wrote:<br>> ><br>> > Brian, Alireza, Tobias,<br>> ><br>> >> A few weeks ago we reached the end of the latest review phase for 2019-04. The Co-Chairs have worked<br>> closely with the NCC Policy Development Office since then to try to make a decision on this policy. This<br>> email contains a report on the Discussion Phase and Review Phase and then a final decision which, we<br>> believe, is supported by the activity during those phases.<br>> >><br>> >> As always, this is underpinned by the RIPE PDP - <a href="https://www.ripe.net/publications/docs/ripe-710" data-saferedirecturl="redir.hsp?url=%68%74%74%70%73%3A%2F%2F%77%77%77%2E%72%69%70%65%2E%6E%65%74%2F%70%75%62%6C%69%63%61%74%69%6F%6E%73%2F%64%6F%63%73%2F%72%69%70%65%2D%37%31%30" target="_blank">https://www.ripe.net/publications/docs/ripe-710</a><br>> ><br>> > [cut]<br>> ><br>> >> With all of this in mind, and with the continued failure of any kind of consensus from the working<br>> group, the Co-Chairs have decided to withdraw this proposal. As always we would welcome proposals on<br>> this and other matters, however we do not feel that there is any likelihood of 2019-04, regardless of<br>> possible edits, reaching consensus in the short or medium term.<br>> ><br>> > Thank you for all your hard work here. It was not an easy task to<br>> > fulfill. With this is mind, it is even more important that you have made<br>> > this report. Thank you.<br>> ><br>> > Stay safe,<br>> > Piotr<br>> ><br>> > --<br>> > Piotr Strzy?ewski<br>> ><br>> <br>> <br>></div></blockquote></div></body></html>