[At-Large] FW: Online sale of fake medicines and products targeted in INTERPOL operation

Mon Jun 13 16:37:52 UTC 2016

As John isn’t a member on the list forwarding his response

--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
http://www.blacknight.host/
http://blog.blacknight.com/
http://ceo.hosting/
Intl. +353 (0) 59  9183072
Direct Dial: +353 (0)59 9183090
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,R93 X265,
Ireland  Company No.: 370845

From: John Horton <john.horton at legitscript.com>
Date: Monday 13 June 2016 at 12:29
To: Michele Neylon <michele at blacknight.com>
Cc: Garth Bruen <gbruen at knujon.com>, Derek Smythe <derek at aa419.org>, At-Large Worldwide <at-large at atlarge-lists.icann.org>
Subject: Re: [At-Large] Online sale of fake medicines and products targeted in INTERPOL operation

Hi all. I'm not sure whether I'll get bounced back rom the at-large mailing list, so feel free to forward if so.

LegitScript's experience over the last several years has been that most registrars now voluntarily suspend domain names that we designate as rogue Internet pharmacies. The criteria there is that the domain name's sole or primary purpose is to illegally sell pharmaceuticals, nearly always without a prescription and also nearly always based on the drugs being falsified, unapproved or in some other way substandard. Rogues also lack valid pharmacy licensure as legally required. These are all public health threats. This includes not only most registrars in the US but worldwide. LegitScript has expressed our appreciation to the registrar and registry community -- more accurately, the majority of that community -- for their commitment to a safer Internet. There's a long list of these registrars, which includes the larger ones like GoDaddy, eNom/Rightside, Directi, Name.com and others, as well as smaller ones like Blacknight (huge in Ireland, though!), Dynadot, AlphaNames and most others. There are others about which we've expressed concerns in the past that are now very responsive and take a serious approach to abuse complaints involving rogue Internet pharmacies, and I think that the anti-abuse community does well to recognize and appreciate the evolution of those approaches. In direct answer, I would say that "a lot" means...I don't know. 80%? 90%? Not all registrars ever have a rogue Internet pharmacy, but there's probably well over 100 registrars that we have to notify from time to time and who act on those notifications.

However, most registrars is not all registrars. Criminals are rational economic actors, and it stands to reason that they will carefully select a registrar that they believe, rightly or wrongly, will protect them from LegitScript or law enforcement notifications. There's also an emerging business model here: charge more for protection. Although this is a small minority of registrars, in my view, it's a serious problem. In some cases, we're aware that the registrar has a special financial arrangement with the rogue Internet pharmacy network. In other cases, the rogue Internet pharmacy network is the registrar. For example, Nanjing Imperious, a registrar ostensibly based in China but operated by a German national, is operated by the rogue Internet pharmacy domain name registrant himself. AB Systems, now finally deaccredited, was the safe haven<https://mastermind.atavist.com/> for tens of thousands of rogue Internet pharmacies that financed arms smuggling, North Korean meth smuggling and assassinations. LegitScript has testified<https://judiciary.house.gov/hearing/hearing-stakeholder-perspectives-icann/> before Congress about our concerns with other registrars like Rebel. My personal view is that ICANN has abdicated its responsibility to exercise due diligence in the accreditation and re-accreditation process. However, I also believe that most registrars do not want companies like these in their community.

In summary, I think that a balanced view recognizes that the strong majority of the registrar community is appropriately responsive to abuse complaints involving criminal activity, specifically rogue Internet pharmacies. However, the same balanced view requires recognizing that there's a serious problem with a small number of rogue registrars who (at best) turn a blind eye to criminal activity or (in some cases) actively solicit it. We continue to urge the contract parties community and ICANN to consider what additional steps can be taken to remove these safe havens from the ecosystem. My personal opinion, which I know that some registrars may or may not share, is that stronger but fair and balanced enforcement of Section 3.18 by ICANN would, in the long run, help the legitimate registrar and registry community, not hurt it.

Thanks for the opportunity to respond. -- JCH

John Horton
President and CEO, LegitScript

Follow LegitScript: LinkedIn<http://www.linkedin.com/company/legitscript-com>  |  Facebook<https://www.facebook.com/LegitScript>  |  Twitter<https://twitter.com/legitscript>  |  Blog<http://blog.legitscript.com>  |  Google+<https://plus.google.com/112436813474708014933/posts>

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On Mon, Jun 13, 2016 at 8:23 AM, Michele Neylon - Blacknight <michele at blacknight.com<mailto:michele at blacknight.com>> wrote:
Garth

Have a look at the Legitscript blog. Most of the large registrars work with Legitscript.

I’m sure John can comment in more detail.

Regards

Michele

--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
http://www.blacknight.host/
http://blog.blacknight.com/
http://ceo.hosting/
Intl. +353 (0) 59 9183072<tel:%2B353%20%280%29%2059%20%209183072>
Direct Dial: +353 (0)59 9183090<tel:%2B353%20%280%2959%209183090>
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,R93 X265,
Ireland  Company No.: 370845

On 13/06/2016, 11:20, "gbruen at knujon.com<mailto:gbruen at knujon.com>" <gbruen at knujon.com<mailto:gbruen at knujon.com>> wrote:

>Michele,
>
>Which registrars and registries are the "a lot" you refer to?
>
>-Garth
>
>
>On 6/13/16 11:01 AM, Michele Neylon - Blacknight wrote:
>> Derek
>>
>> Hardly “of note”. They’re mentioned in passing without any details and in the same line as payment providers and delivery services. There’s also zero explanation as to what constitutes “rogue”.
>>
>> As Legitscript has noted multiple times in the past a lot of registrars and registries work with them and law enforcement.
>>
>> Regards
>>
>> Michele
>>
>>
>> --
>> Mr Michele Neylon
>> Blacknight Solutions
>> Hosting, Colocation & Domains
>> http://www.blacknight.host/
>> http://blog.blacknight.com/
>> http://ceo.hosting/
>> Intl. +353 (0) 59 9183072<tel:%2B353%20%280%29%2059%20%209183072>
>> Direct Dial: +353 (0)59 9183090<tel:%2B353%20%280%2959%209183090>
>> -------------------------------
>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>> Road,Graiguecullen,Carlow,R93 X265,
>> Ireland  Company No.: 370845
>>
>> On 11/06/2016, 17:05, "at-large-bounces at atlarge-lists.icann.org<mailto:at-large-bounces at atlarge-lists.icann.org> on behalf of Derek Smythe" <at-large-bounces at atlarge-lists.icann.org<mailto:at-large-bounces at atlarge-lists.icann.org> on behalf of derek at aa419.org<mailto:derek at aa419.org>> wrote:
>>
>>> http://www.interpol.int/News-and-media/News/2016/N2016-076
>>>
>>> Of note: "rogue domain name registrars"
>>>
>>>> The operation also targeted the main areas exploited by organized crime in the illegal online medicine trade: rogue domain name registrars, electronic payment systems and delivery services. A further 700 investigations have now also been launched by national authorities worldwide with at least 40 cases directly linked to organized crime.
>>>
>>> Derek Smythe
>>> Artists Against 419
>>> http://www.aa419.org
>>>
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>
>--
>Garth Bruen
>gbruen at knujon.com<mailto:gbruen at knujon.com>
>
>617-947-3805<tel:617-947-3805>
>http://www.knujon.com
>Fisher College, Criminal Justice Division
>ICANN At-Large Advisory Council
>Author: WHOIS Running the Internet
>http://www.wiley.com/WileyCDA/WileyTitle/productCd-1118679555.html
>

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