I don’t think this is correct, at least not for google, amazon, and other big providers, which I send email with abuses every other day and they react to it and resolve them.

 

 

El 8/9/20 16:33, "anti-abuse-wg en nombre de Alex de Joode" <anti-abuse-wg-bounces@ripe.net en nombre de alex@idgara.nl> escribió:

 

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@idgara.nl | +31651108221 | Skype:adejoode


On Tue, 08-09-2020 15h 51min, Carlos Friaças <cfriacas@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@idgara.nl | +31651108221 | Skype:adejoode
>
> On Tue, 08-09-2020 13h 33min, Suresh Ramasubramanian <ops.lists@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 <anti-abuse-wg-bounces@ripe.net> on behalf of Carlos Friaças via anti-abuse-wg
> <anti-abuse-wg@ripe.net>
> Sent: Tuesday, September 8, 2020 4:44:26 PM
> To: anti-abuse-wg@ripe.net <anti-abuse-wg@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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