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INFORMATIONAL
Errata Exist
Internet Engineering Task Force (IETF) J. Livingood
Request for Comments: 6561 N. Mody
Category: Informational M. O'Reirdan
ISSN: 2070-1721 Comcast
March 2012
Recommendations for the Remediation of Bots in ISP Networks
Abstract
This document contains recommendations on how Internet Service
Providers can use various remediation techniques to manage the
effects of malicious bot infestations on computers used by their
subscribers. Internet users with infected computers are exposed to
risks such as loss of personal data and increased susceptibility to
online fraud. Such computers can also become inadvertent
participants in or components of an online crime network, spam
network, and/or phishing network as well as be used as a part of a
distributed denial-of-service attack. Mitigating the effects of and
remediating the installations of malicious bots will make it more
difficult for botnets to operate and could reduce the level of online
crime on the Internet in general and/or on a particular Internet
Service Provider's network.
Status of This Memo
This document is not an Internet Standards Track specification; it is
published for informational purposes.
This document is a product of the Internet Engineering Task Force
(IETF). It represents the consensus of the IETF community. It has
received public review and has been approved for publication by the
Internet Engineering Steering Group (IESG). Not all documents
approved by the IESG are a candidate for any level of Internet
Standard; see Section 2 of RFC 5741.
Information about the current status of this document, any errata,
and how to provide feedback on it may be obtained at
http://www.rfc-editor.org/info/rfc6561.
Copyright Notice
Copyright (c) 2012 IETF Trust and the persons identified as the
document authors. All rights reserved.
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This document is subject to BCP 78 and the IETF Trust's Legal
Provisions Relating to IETF Documents
(http://trustee.ietf.org/license-info) in effect on the date of
publication of this document. Please review these documents
carefully, as they describe your rights and restrictions with respect
to this document. Code Components extracted from this document must
include Simplified BSD License text as described in Section 4.e of
the Trust Legal Provisions and are provided without warranty as
described in the Simplified BSD License.
Table of Contents
1. Introduction ....................................................3
1.1. Key Terminology ............................................3
1.1.1. Malicious Bots, or Bots .............................3
1.1.2. Bot Networks, or Botnets ............................4
1.1.3. Host ................................................5
1.1.4. Malware .............................................5
1.1.5. Fast Flux ...........................................5
2. Problem Statement ...............................................6
3. Important Notice of Limitations and Scope .......................7
4. Detection of Bots ...............................................8
5. Notification to Internet Users .................................12
5.1. Email Notification ........................................13
5.2. Telephone Call Notification ...............................13
5.3. Postal Mail Notification ..................................14
5.4. Walled Garden Notification ................................14
5.5. Instant Message Notification ..............................16
5.6. Short Message Service (SMS) Notification ..................16
5.7. Web Browser Notification ..................................17
5.8. Considerations for Notification to Public Network
Locations .................................................18
5.9. Considerations for Notification to Network
Locations Using a Shared IP Address .......................18
5.10. Notification and End User Expertise ......................19
6. Remediation of Hosts Infected with a Bot .......................19
6.1. Guided Remediation Process ................................21
6.2. Professionally Assisted Remediation Process ...............22
7. Failure or Refusal to Remediate ................................23
8. Sharing of Data from the User to the ISP .......................23
9. Security Considerations ........................................23
10. Privacy Considerations ........................................24
11. Acknowledgements ..............................................24
12. Informative References ........................................26
Appendix A. Examples of Third-Party Malware Lists ................28
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1. Introduction
This document contains recommendations on how Internet Service
Providers can use various remediation techniques to manage the
effects of malicious bot infestations on computers used by their
subscribers. Internet users with infected computers are exposed to
risks such as loss of personal data and increased susceptibility to
online fraud. Such computers can also become inadvertent
participants in or components of an online crime network, spam
network, and/or phishing network as well as be used as a part of a
distributed denial-of-service attack. Mitigating the effects of and
remediating the installations of malicious bots will make it more
difficult for botnets to operate and could reduce the level of online
crime on the Internet in general and/or on a particular Internet
Service Provider's network.
1.1. Key Terminology
This section defines the key terms used in this document.
1.1.1. Malicious Bots, or Bots
A malicious or potentially malicious bot (derived from the word
"robot", hereafter simply referred to as a "bot") refers to a program
that is installed on a system in order to enable that system to
automatically (or semi-automatically) perform a task or set of tasks
typically under the command and control of a remote administrator, or
"bot master". Bots are also known as "zombies". Such bots may have
been installed surreptitiously, without the user's full understanding
of what the bot will do once installed, unknowingly as part of
another software installation, under false pretenses, and/or in a
variety of other possible ways.
It is important to note that there are "good" bots. Such good bots
are often found interacting with a computing resource in environments
such as gaming and Internet Relay Chat (IRC) [RFC1459], where a
continual, interactive presence can be a requirement for
participating in the games. Since such good bots are performing
useful, lawful, and non-disruptive functions, there is no reason for
a provider to monitor for their presence and/or alert users to their
presence.
While there may be good, or harmless bots, for the purposes of this
document, all mention of bots shall assume that the bots involved are
malicious or potentially malicious in nature. Such malicious bots
shall generally be assumed to have been deployed without the
permission or conscious understanding of a particular Internet user.
Thus, without a user's knowledge, bots may transform the user's
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computing device into a platform from which malicious activities can
be conducted. In addition, included explicitly in this category are
potentially malicious bots, which may initially appear neutral but
may simply be waiting for remote instructions to transform and/or
otherwise begin engaging in malicious behavior. In general,
installation of a malicious bot without user knowledge and consent is
considered in most regions to be unlawful, and the activities of
malicious bots typically involve unlawful or other maliciously
disruptive activities.
1.1.2. Bot Networks, or Botnets
A "bot network", or "botnet", is defined as a concerted network of
bots capable of acting on instructions generated remotely. The
malicious activities are either focused on the information on the
local machine or acting to provide services for remote machines.
Bots are highly customizable so they can be programmed to do many
things. The major malicious activities include but are not limited
to identity theft, spam, spim (spam over Instant Messaging (IM)),
spit (spam over Internet telephony), email address harvesting,
distributed denial-of-service (DDoS) attacks, key-logging, fraudulent
DNS pharming (redirection), hosting proxy services, fast flux (see
Section 1.1.5) hosting, hosting of illegal content, use in man-in-
the-middle attacks, and click fraud.
Infection vectors (infection pathways) include un-patched operating
systems, software vulnerabilities (which include so-called zero-day
vulnerabilities where no patch yet exists), weak/non-existent
passwords, malicious web sites, un-patched browsers, malware,
vulnerable helper applications, inherently insecure protocols,
protocols implemented without security features switched on, and
social engineering techniques to gain access to the user's computer.
The detection and destruction of bots is an ongoing issue and also a
constant battle between the Internet security community and network
security engineers on the one hand and bot developers on the other.
Initially, some bots used IRC to communicate but were easy to shut
down if the command and control server was identified and
deactivated. Newer command and control methods have evolved, such
that those currently employed by bot masters make them much more
resistant to deactivation. With the introduction of peer-to-peer
(P2P) architectures and associated protocols, the use of HTTP and
other resilient communication protocols, and the widespread adoption
of encryption, bots are considerably more difficult to identify and
isolate from typical network usage. As a result, increased reliance
is being placed on anomaly detection and behavioral analysis, both
locally and remotely, to identify bots.
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1.1.3. Host
As used in the context of this document, the host or computer of an
end user is intended to refer to a computing device that connects to
the Internet. This encompasses devices used by Internet users such
as personal computers (including laptops, desktops, and netbooks),
mobile phones, smart phones, home gateway devices, and other end user
computing devices that are connected or can connect to the public
Internet and/or private IP networks.
Increasingly, other household systems and devices contain embedded
hosts that are connected to or can connect to the public Internet
and/or private IP networks. However, these devices may not be under
interactive control of the Internet user, such as may be the case
with various smart home and smart grid devices.
1.1.4. Malware
Malware is short for "malicious software". In this case, malicious
bots are considered a subset of malware. Other forms of malware
could include viruses and other similar types of software. Internet
users can sometimes cause their hosts to be infected with malware,
which may include a bot or cause a bot to install itself, via
inadvertently accessing a specific web site, downloading a file, or
other activities.
In other cases, Internet-connected hosts may become infected with
malware through externally initiated malicious activities such as the
exploitation of vulnerabilities or the brute force guessing of access
credentials.
1.1.5. Fast Flux
Domain Name System (DNS) fast fluxing occurs when a domain is bound
in DNS using A records to multiple IP addresses, each of which has a
very short Time-to-Live (TTL) value associated with it. This means
that the domain resolves to varying IP addresses over a short period
of time.
DNS fast flux is typically used in conjunction with proxies that are
normally run on compromised user hosts. These proxies route the web
requests to the real host, which serves the data being sought. The
effect of this is to make the detection of the real host much more
difficult and to ensure that the backend or hidden site remains up
for as long as possible.
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2. Problem Statement
Hosts used by Internet users, which in this case are customers of an
Internet Service Provider (ISP), can be infected with malware that
may contain and/or install one or more bots on a host. They can
present a major problem for an ISP for a number of reasons (not to
mention, of course, the problems created for users). First, these
bots can be used to send spam, in some cases very large volumes of
spam [Spamalytics]. This spam can result in extra cost for the ISPs
in terms of wasted network, server, and/or personnel resources, among
many other potential costs and side effects. Such spam can also
negatively affect the reputation of the ISP, their customers, and the
email reputation of the IP address space used by the ISP (often
referred to simply as "IP reputation"). A further potential
complication is that IP space compromised by bad reputation may
continue to carry this bad reputation even when used for entirely
innocent purposes following reassignment of that IP space.
In addition, these bots can act as platforms for directing,
participating in, or otherwise conducting attacks on critical
Internet infrastructure [Threat-Report]. Bots are frequently used as
part of coordinated DDoS attacks for criminal, political, or other
motivations [Gh0st][Dragon][DDoS]. For example, bots have been used
to attack Internet resources and infrastructure ranging from web
sites to email servers and DNS servers, as well as the critical
Internet infrastructure of entire countries [Estonia][Combat-Zone].
Motivations for such coordinated DDoS attacks can range from criminal
extortion attempts through to online protesting and nationalistic
fervor [Whiz-Kid]. DDoS attacks may also be motivated by simple
personal vendettas or by persons simply seeking a cheap thrill at the
expense of others.
There is good evidence to suggest that bots are being used in the
corporate environment for purposes of corporate espionage including
the exfiltration of corporate financial data and intellectual
property. This also extends to the possibility of bots being used
for state-sponsored purposes such as espionage.
While any computing device can be infected with bots, the majority of
bot infections affect the personal computers used by Internet end
users. As a result of the role of ISPs in providing IP connectivity,
among many other services, to Internet users, these ISPs are in a
unique position to be able to attempt to detect and observe botnets
operating in their networks. Furthermore, ISPs may also be in a
unique position to be able to notify their customers of actual,
potential, or likely infection by bots or other infection.
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From the perspective of end users, being notified that they may have
an infected computer on their network is important information. Once
they know this, they can take steps to remove the bots, resolve any
problems that may stem from the bot infection, and protect themselves
against future threats. It is important to notify users that they
may be infected with a bot because bots can consume vast amounts of
local computing and network resources, enable theft of personal
information (including personal financial information), enable the
host to be used for criminal activities (that may result in the
Internet user being legally culpable), and destroy or leave the host
in an unrecoverable state via "kill switch" bot technologies.
As a result, the intent of this document is to provide guidance to
ISPs and other organizations for the remediation of hosts infected
with bots, so as to reduce the size of botnets and minimize the
potential harm that bots can inflict upon Internet infrastructure in
general as well as on individual Internet users. Efforts by ISPs and
other organizations can, over time, reduce the pool of hosts infected
with bots on the Internet, which in turn could result in smaller
botnets with less capability for disruption.
The potential mitigation of bots is accomplished through a process of
detection, notification to Internet users, and remediation of bot
infections with a variety of tools, as described later in this
document.
3. Important Notice of Limitations and Scope
The techniques described in this document in no way guarantee the
remediation of all bots. Bot removal is potentially a task requiring
specialized knowledge, skills, and tools; it may be beyond the
ability of average users. Attempts at bot removal may frequently be
unsuccessful, or only partially successful, leaving the user's system
in an unstable and unsatisfactory state or even in a state where it
is still infected. Attempts at bot removal can result in side
effects ranging from a loss of data to partial or complete loss of
system usability.
In general, the only way a user can be sure they have removed some of
today's increasingly sophisticated malware is by "nuking-and-paving"
the system: reformatting the drive, reinstalling the operating system
and applications (including all patches) from scratch, and then
restoring user files from a known clean backup. However, the
introduction of persistent memory-based malware may mean that, in
some cases, this may not be enough and may prove to be more than any
end user can be reasonably expected to resolve [BIOS]. Experienced
users would have to re-flash or re-image persistent memory sections
or components of their hosts in order to remove persistent memory-
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based malware. However, in some cases, not even nuking-and-paving
the system will solve the problem, which calls for hard drive
replacement and/or complete replacement of the host.
Devices with embedded operating systems, such as video gaming
consoles and smart home appliances, will most likely be beyond a
user's capability to remediate by themselves and could therefore
require the aid of vendor-specific advice, updates, and tools.
However, in some cases, such devices will have a function or switch
to enable the user to reset that device to a factory default
configuration, which may sometimes enable the user to remediate the
infection. Care should be taken when imparting remediation advice to
Internet users given the increasingly wide array of computing devices
that can be, or could be, infected by bots in the future.
This document is not intended to address the issues relating to the
prevention of bots on an end user device. This is out of the scope
of this document.
4. Detection of Bots
An ISP must first identify that an Internet user is infected or
likely to have been infected with a bot (a user is assumed to be
their customer or otherwise connected to the ISP's network). The ISP
should attempt to detect the presence of bots using methods,
processes, and tools that maintain the privacy of the personally
identifiable information (PII) of their customers. The ISP should
not block legitimate traffic in the course of bot detection and
should instead employ detection methods, tools, and processes that
seek to be non-disruptive and transparent to Internet users and end
user applications.
Detection methods, tools, and processes may include analysis of
specific network and/or application traffic flows (such as traffic to
an email server), analysis of aggregate network and/or application
traffic data, data feeds received from other ISPs and organizations
(such as lists of the ISP's IP addresses that have been reported to
have sent spam), feedback from the ISP's customers or other Internet
users, as well as a wide variety of other possibilities. In
practice, it has proven effective to confirm a bot infection through
the use of a combination of multiple bot detection data points. This
can help to corroborate information of varying dependability or
consistency, as well as to avoid or minimize the possibility of false
positive identification of hosts. Detection should also, where
possible and feasible, attempt to classify the specific bot infection
type in order to confirm that it is malicious in nature, estimate the
variety and severity of threats it may pose (such as spam bot, key-
logging bot, file distribution bot, etc.), and determine potential
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methods for eventual remediation. However, given the dynamic nature
of botnet management and the criminal incentives to seek quick
financial rewards, botnets frequently update or change their core
capabilities. As a consequence, botnets that are initially detected
and classified by the ISP as made up of one particular type of bot
need to be continuously monitored and tracked in order to correctly
identify the threat the botnet poses at any particular point in time.
Detection is also time sensitive. If complex analysis is required
and multiple confirmations are needed to verify a bot is indeed
present, then it is possible that the bot may cause some damage (to
either the infected host or a remotely targeted system) before it can
be stopped. This means that an ISP needs to balance the desire or
need to definitively classify and/or confirm the presence of a bot,
which may take an extended period of time, with the ability to
predict the likelihood of a bot in a very short period of time. Such
determinations must have a relatively low false positive rate in
order to maintain the trust of users. This "definitive-versus-
likely" challenge is difficult and, when in doubt, ISPs should err on
the side of caution by communicating that a bot infection has taken
place. This also means that Internet users may benefit from the
installation of client-based security software on their host. This
can enable rapid heuristically based detection of bot activity, such
as the detection of a bot as it starts to communicate with other
botnets and execute commands. Any bot detection system should also
be capable of adapting, either via manual intervention or
automatically, in order to cope with a rapidly evolving threat.
As noted above, detection methods, tools, and processes should ensure
that privacy of customers' personally identifiable information (PII)
is maintained. This protection afforded to PII should also extend to
third parties processing data on behalf of ISPs. While bot detection
methods, tools, and processes are similar to spam and virus defenses
deployed by the ISP for the benefit of their customers (and may be
directly related to those defenses), attempts to detect bots should
take into account the need of an ISP to take care to ensure any PII
collected or incidentally detected is properly protected. This is
important because just as spam defenses may involve scanning the
content of email messages, which may contain PII, then so too may bot
defenses similarly come into incidental contact with PII. The
definition of PII varies from one jurisdiction to the next so proper
care should be taken to ensure that any actions taken comply with
legislation and good practice in the jurisdiction in which the PII is
gathered. Finally, depending upon the geographic region within which
an ISP operates, certain methods relating to bot detection may need
to be included in relevant terms of service documents or other
documents that are available to the customers of a particular ISP.
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There are several bot detection methods, tools, and processes that an
ISP may choose to utilize, as noted in the list below. It is
important to note that the technical solutions available are
relatively immature and are likely to change over time, evolving
rapidly in the coming years. While these items are described in
relation to ISPs, they may also be applicable to organizations
operating other networks, such as campus networks and enterprise
networks.
a. Where it is not legally proscribed and an accepted industry
practice in a particular market region, an ISP may in some manner
"scan" its IP space in order to detect un-patched or otherwise
vulnerable hosts or to detect the signs of infection. This may
provide the ISP with the opportunity to easily identify Internet
users who appear already to be infected or are at great risk of
being infected with a bot. ISPs should note that some types of
port scanning may leave network services in a hung state or
render them unusable due to common frailties and that many modern
firewall and host-based intrusion detection implementations may
alert the Internet user to the scan. As a result, the scan may
be interpreted as a malicious attack against the host.
Vulnerability scanning has a higher probability of leaving
accessible network services and applications in a damaged state
and will often result in a higher probability of detection by the
Internet user and subsequent interpretation as a targeted attack.
Depending upon the vulnerability for which an ISP may be
scanning, some automated methods of vulnerability checking may
result in data being altered or created afresh on the Internet
user's host, which can be a problem in many legal environments.
It should also be noted that due to the prevalence of Network
Address Translation devices, Port Address Translation devices,
and/or firewall devices in user networks, network-based
vulnerability scanning may be of limited value. Thus, while we
note that this is one technique that may be utilized, it is
unlikely to be particularly effective and has problematic side
effects, which leads the authors to recommend against the use of
this particular method.
b. An ISP may also communicate and share selected data, via feedback
loops or other mechanisms, with various third parties. Feedback
loops are consistently formatted feeds of real-time (or nearly
real-time) abuse reports offered by threat data clearinghouses,
security alert organizations, other ISPs, and other
organizations. The formats for feedback loops include those
defined in both the Abuse Reporting Format (ARF) [RFC5965] and
the Incident Object Description Exchange Format (IODEF)
[RFC5070]. The data may include, but is not limited to, IP
addresses of hosts that appear to be either definitely or
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probably infected, IP addresses, domain names or fully qualified
domain names (FQDNs) known to host malware and/or be involved in
the command and control of botnets, recently tested or discovered
techniques for detecting or remediating bot infections, new
threat vectors, and other relevant information. A few good
examples of data sharing are noted in Appendix A.
c. An ISP may use Netflow [RFC3954] or other similar passive network
monitoring to identify network anomalies that may be indicative
of botnet attacks or bot communications. For example, an ISP may
be able to identify compromised hosts by identifying traffic
destined to IP addresses associated with the command and control
of botnets or destined to the combination of an IP address and
control port associated with a command and control network
(sometimes command and control traffic comes from a host that has
legitimate traffic). In addition, bots may be identified when a
remote host is under a DDoS attack, because hosts participating
in the attack will likely be infected by a bot. This can often
be observed at network borders although ISPs should beware of
source IP address spoofing techniques that may be employed to
avoid or confuse detection.
d. An ISP may use DNS-based techniques to perform detection. For
example, a given classified bot may be known to query a specific
list of domain names at specific times or on specific dates (in
the example of the so-called "Conficker" bot (see [Conficker]),
often by matching DNS queries to a well-known list of domains
associated with malware. In many cases, such lists are
distributed by or shared using third parties, such as threat data
clearinghouses.
e. Because hosts infected by bots are frequently used to send spam
or participate in DDoS attacks, the ISP servicing those hosts
will normally receive complaints about the malicious network
traffic. Those complaints may be sent to role accounts specified
in RFC 2142 [RFC2142], such as abuse@, or to other relevant
addresses such as to abuse or security addresses specified by the
site as part of its WHOIS (or other) contact data.
f. ISPs may also discover likely bot-infected hosts located on other
networks. Thus, when legally permissible in a particular market
region, it may be worthwhile for ISPs to share information
relating to those compromised hosts with the relevant remote
network operator, security researchers, and blocklist operators.
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g. ISPs may operate or subscribe to services that provide
"sinkholing" or "honeynet" capabilities. This may enable the ISP
to obtain near-real-time lists of bot-infected hosts as they
attempt to join a larger botnet or propagate to other hosts on a
network.
h. ISP industry associations should examine the possibility of
collating statistics from ISP members in order to provide good
statistics about bot infections based on real ISP data.
i. An Intrusion Detection System (IDS) can be a useful tool to
actually help identify the malware. An IDS tool such as Snort
(open source IDS platform; see [Snort]) can be placed in a walled
garden and used to analyze end user traffic to confirm malware
type. This will help with remediation of the infected device.
5. Notification to Internet Users
Once an ISP has detected a bot, or the strong likelihood of a bot,
steps should be undertaken to inform the Internet user that they may
have a bot-related problem. An ISP should decide the most
appropriate method or methods for providing notification to one or
more of their customers or Internet users, depending upon a range of
factors including the technical capabilities of the ISP, the
technical attributes of its network, financial considerations,
available server resources, available organizational resources, the
number of likely infected hosts detected at any given time, and the
severity of any possible threats. Such notification methods may
include one or more of the methods described in the following
subsections, as well as other possible methods not described below.
It is important to note that none of these methods are guaranteed to
be one hundred percent successful and that each has its own set of
limitations. In addition, in some cases, an ISP may determine that a
combination of two or more methods is most appropriate and effective
and reduces the chance that malware may block a notification. As
such, the authors recommend the use of multiple notification methods.
Finally, notification is also considered time sensitive; if the user
does not receive or view the notification in a timely fashion, then a
particular bot could launch an attack, exploit the user, or cause
other harm. If possible, an ISP should establish a preferred means
of communication when the subscriber first signs up for service. As
a part of the notification process, ISPs should maintain a record of
the allocation of IP addresses to subscribers for a period long
enough to allow any commonly used bot detection technology to be able
to accurately link an infected IP address to a subscriber. This
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record should only be maintained for a period of time that is
necessary to support bot detection, but no longer, in order to
protect the privacy of the individual subscriber.
One important factor to bear in mind is that notification to end
users needs to be resistant to potential spoofing. This should be
done to protect, as reasonably as possible, against the potential of
legitimate notifications being spoofed and/or used by parties with
intent to perform additional malicious attacks against victims of
malware or even to deliver additional malware.
It should be possible for the end user to indicate the preferred
means of notification on an opt-in basis for that notification
method. It is recommended that the end user should not be allowed to
opt out of notification entirely.
When users are notified, an ISP should endeavor to give as much
information as possible to the end user regarding which bot detection
methods are employed at the ISP, consonant with not providing
information to those creating or deploying the bots so that they
would be able to avoid detection.
5.1. Email Notification
This is a common form of notification used by ISPs. One drawback of
using email is that it is not guaranteed to be viewed within a
reasonable time frame, if at all. The user may be using a different
primary email address than the one they provided to the ISP. In
addition, some ISPs do not provide an email account at all as part of
a bundle of Internet services and/or do not have a need for or method
by which to request or retain the primary email addresses of Internet
users of their networks. Another possibility is that the user, their
email client, and/or their email servers could determine or classify
such a notification as spam, which could delete the message or
otherwise file it in an email folder that the user may not check on a
regular and/or timely basis. Bot masters have also been known to
impersonate the ISP or trusted sender and send fraudulent emails to
the users. This technique of social engineering often leads to new
bot infestations. Finally, if the user's email credentials are
compromised, then a hacker and/or a bot could simply access the
user's email account and delete the email before it is read by the
user.
5.2. Telephone Call Notification
A telephone call may be an effective means of communication in
particularly high-risk situations. However, telephone calls may not
be feasible due to the cost of making a large number of calls, as
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measured in either time, money, organizational resources, server
resources, or some other means. In addition, there is no guarantee
that the user will answer their phone. To the extent that the
telephone number called by the ISP can be answered by the infected
computing device, the bot on that host may be able to disconnect,
divert, or otherwise interfere with an incoming call. Users may also
interpret such a telephone notification as a telemarketing call and
therefore not welcome it or not accept the call at all. Finally,
even if a representative of the ISP is able to connect with and speak
to a user, that user is very likely to lack the necessary technical
expertise to understand or be able to effectively deal with the
threat.
5.3. Postal Mail Notification
This form of notification is probably the least popular and effective
means of communication, due to preparation time, delivery time, the
cost of printing and paper, and the cost of postage.
5.4. Walled Garden Notification
Placing a user in a walled garden is another approach that ISPs may
take to notify users. A "walled garden" refers to an environment
that controls the information and services that a subscriber is
allowed to utilize and what network access permissions are granted.
A walled garden implementation can range from strict to leaky. In a
strict walled garden environment, access to most Internet resources
is typically limited by the ISP. In contrast, a leaky walled garden
environment permits access to all Internet resources, except those
deemed malicious, and ensures access to those that can be used to
notify users of infections.
Walled gardens are effective because it is possible to notify the
user and simultaneously block all communication between the bot and
the command and control channel. While in many cases the user is
almost guaranteed to view the notification message and take any
appropriate remediation actions, this approach can pose other
challenges. For example, it is not always the case that a user is
actively utilizing a host that implements a web browser, has a web
browser actively running on it, or operates another application that
uses ports that are redirected to the walled garden. In one example,
a user could be playing a game online, via the use of a dedicated,
Internet-connected game console. In another example, the user may
not be using a host with a web browser when they are placed in the
walled garden and may instead be in the course of a telephone
conversation or may be expecting to receive a call using a Voice over
IP (VoIP) device of some type. As a result, the ISP may feel the
need to maintain a potentially lengthy white list of domains that are
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not subject to the typical restrictions of a walled garden, which
could well prove to be an onerous task from an operational
perspective.
For these reasons, the implementation of a leaky walled garden makes
more sense, but a leaky walled garden has a different set of
drawbacks. The ISP has to assume that the user will eventually use a
web browser to acknowledge the notification; otherwise, the user will
remain in the walled garden and not know it. If the intent of the
leaky walled garden is solely to notify the user about the bot
infection, then the leaky walled garden is not ideal because
notification is time sensitive, and the user may not receive the
notification until the user invokes a request for the targeted
service and/or resource. This means the bot can potentially do more
damage. Additionally, the ISP has to identify which services and/or
resources to restrict for the purposes of notification. This does
not have to be resource specific and can be time based and/or policy
based. An example of how notification could be made on a timed basis
could involve notification for all HTTP requests every 10 minutes, or
show the notification for one in five HTTP requests.
The ISP has several options to determine when to let the user out of
the walled garden. One approach may be to let the user determine
when to exit. This option is suggested when the primary purpose of
the walled garden is to notify users and provide information on
remediation only, particularly since notification is not a guarantee
of successful remediation. It could also be the case that, for
whatever reason, the user makes the judgment that they cannot then
take the time to remediate their host and that other online
activities that they would like to resume are more important. Exit
from the walled garden may also involve a process to verify that it
is indeed the user who is requesting exit from the walled garden and
not the bot.
Once the user acknowledges the notification, they may decide either
to remediate and exit the walled garden or to exit the walled garden
without remediating the issue. Another approach may be to enforce a
stricter policy and require the user to clean the host prior to
permitting the user to exit the walled garden, though this may not be
technically feasible depending upon the type of bot, obfuscation
techniques employed by a bot, and/or a range of other factors. Thus,
the ISP may also need to support tools to scan the infected host (in
the style of a virus scan, rather than a port scan) and determine
whether it is still infected or rely on user judgment that the bot
has been disabled or removed. One challenge with this approach is
that the user might have multiple hosts sharing a single IP address,
such as via a common home gateway device that performs Network
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Address Translation (NAT). In such a case, the ISP may need to
determine from user feedback, or other means, that all affected hosts
have been remediated, which may or may not be technically feasible.
Finally, when a walled garden is used, a list of well-known addresses
for both operating system vendors and security vendors should be
created and maintained in a white list that permits access to these
sites. This can be important for allowing access from the walled
garden by end users in search of operating system and application
patches. It is recommended that walled gardens be seriously
considered as a method of notification as they are easy to implement
and proven to be effective as a means of getting end user attention.
5.5. Instant Message Notification
IM provides the ISP with a simple means to communicate with the user.
There are several advantages to using IM that make it an attractive
option. If the ISP provides IM service and the user subscribes to
it, then the user can be notified easily. IM-based notification can
be a cost-effective means to communicate with users automatically
from an IM alert system or by a manual process, involving the ISP's
support staff. Ideally, the ISP should allow the user to register
their IM identity in an ISP account management system and grant
permission to be contacted via this means. If the IM service
provider supports off-line messaging, then the user can be notified
regardless of whether they are currently logged into the IM system.
There are several drawbacks with this communications method. There
is a high probability that a subscriber may interpret the
communication to be spim and thus ignore it. Also, not every user
uses IM and/or the user may not provide their IM identity to the ISP
so some alternative means have to be used. Even in those cases where
a user does have an IM address, they may not be signed onto that IM
system when the notification is attempted. There may be a privacy
concern on the part of users when such an IM notification must be
transmitted over a third-party network and/or IM service. As such,
should this method be used, the notification should be discreet and
not include any PII in the notification itself.
5.6. Short Message Service (SMS) Notification
SMS allows the ISP to send a brief description of the problem to
notify the user of the issue, typically to a mobile device such as a
mobile phone or smart phone. Ideally, the ISP should allow the user
to register their mobile number and/or SMS address in an ISP account
management system and grant permission to be contacted via this
means. The primary advantage of SMS is that users are familiar with
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receiving text messages and are likely to read them. However, users
may not act on the notification immediately if they are not in front
of their host at the time of the SMS notification.
One disadvantage is that ISPs may have to follow up with an alternate
means of notification if not all of the necessary information may be
conveyed in one message, given constraints on the number of
characters in an individual message (typically 140 characters).
Another disadvantage with SMS is the cost associated with it. The
ISP has to either build its own SMS gateway to interface with the
various wireless network service providers or use a third-party SMS
clearinghouse (relay) to notify users. In both cases, an ISP may
incur fees related to SMS notifications, depending upon the method
used to send the notifications. An additional downside is that SMS
messages sent to a user may result in a charge to the user by their
wireless provider, depending upon the plan to which they subscribe
and the country in which the user resides. Another minor
disadvantage is that it is possible to notify the wrong user if the
intended user changes their mobile number but forgets to update it
with the ISP.
There are several other drawbacks with this communications method.
There is a high probability that subscriber may interpret the
communication to be spam and thus ignore it. Also, not every user
uses SMS, and/or the user may not provide their SMS address or mobile
number to the ISP. Even in those cases where a user does have an SMS
address or mobile number, their device may not be powered on or
otherwise available on a wireless network when the notification is
attempted. There may also be a privacy concern on the part of users
when such an SMS notification must be transmitted over a third-party
network and/or SMS clearinghouse. As such, should this method be
used, the notification should be discreet and not include any PII in
the notification itself.
5.7. Web Browser Notification
Near-real-time notification to the user's web browser is another
technique that may be utilized for notifying the user [RFC6108],
though how such a system might operate is outside the scope of this
document. Such a notification could have a comparative advantage
over a walled garden notification, in that it does not restrict
traffic to a specified list of destinations in the same way that a
walled garden would, by definition. However, as with a walled garden
notification, there is no guarantee that a user is making use of a
web browser at any given time, though such a system could certainly
provide a notification when such a browser is eventually used.
Compared to a walled garden, a web browser notification is probably
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preferred from the perspective of Internet users, as it does not have
the risk of disrupting non-web sessions, such as online games, VoIP
calls, etc. (as noted in Section 5.4).
There are alternative methods of web browser notification offered
commercially by a number of vendors. Many of the techniques used are
proprietary, and it is not within the scope of this document to
describe how they are implemented. These techniques have been
successfully implemented at several ISPs.
It should be noted that web notification is only intended to notify
devices running a web browser.
5.8. Considerations for Notification to Public Network Locations
Delivering a notification to a location that provides a shared public
network, such as a train station, public square, coffee shop, or
similar location may be of low value since the users connecting to
such networks are typically highly transient and generally not known
to site or network administrators. For example, a system may detect
that a host on such a network has a bot, but by the time a
notification is generated, that user has departed from the network
and moved elsewhere.
5.9. Considerations for Notification to Network Locations Using a
Shared IP Address
Delivering a notification to a location that accesses the Internet
routed through one or more shared public IP addresses may be of low
value since it may be quite difficult to differentiate between users
when providing a notification. For example, on a business network of
500 users, all sharing one public IP address, it may be sub-optimal
to provide a notification to all 500 users if you only need one
specific user to be notified and take action. As a result, such
networks may find value in establishing a localized bot detection and
notification system, just as they are likely to also establish other
localized systems for security, file sharing, email, and so on.
However, should an ISP implement some form of notification to such
networks, it may be better to simply send notifications to a
designated network administrator at the site. In such a case, the
local network administrator may like to receive additional
information in such a notification, such as a date and timestamp, the
source port of the infected system, and malicious sites and ports
that may have been visited.
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5.10. Notification and End User Expertise
The ultimate effectiveness of any of the aforementioned forms of
notification is heavily dependent upon both the expertise of the end
user and the wording of any such notification. For example, while a
user may receive and acknowledge a notification, that user may lack
the necessary technical expertise to understand or be able to deal
effectively with the threat. As a result, it is important that such
notifications use clear and easily understood language, so that the
majority of users (who are non-technical) may understand the
notification. In addition, a notification should provide easily
understood guidance on how to remediate a threat as described in
Section 6, potentially with one path for technical users to take and
another for non-technical users.
6. Remediation of Hosts Infected with a Bot
This section covers the different options available to remediate a
host, which means to remove, disable, or otherwise render a bot
harmless. Prior to this step, an ISP has detected the bot, notified
the user that one of their hosts is infected with a bot, and now may
provide some recommended means to clean the host. The generally
recommended approach is to provide the necessary tools and education
to the user so that they may perform bot remediation themselves,
particularly given the risks and difficulties inherent in attempting
to remove a bot.
For example, this may include the creation of a special web site with
security-oriented content that is dedicated for this purpose. This
should be a well-publicized security web site to which a user with a
bot infection can be directed to for remediation. This security web
site should clearly explain why the user was notified and may include
an explanation of what bots are and the threats that they pose.
There should be a clear explanation of the steps that the user should
take in order to attempt to clean their host and information on how
users can keep the host free of future infections. The security web
site should also have a guided process that takes non-technical users
through the remediation process, on an easily understood, step-by-
step basis.
In terms of the text used to explain what bots are and the threats
that they pose, something simple such as this may suffice:
What is a bot? A bot is a piece of software, generally installed
on your machine without your knowledge, which either sends spam or
tries to steal your personal information. They can be very
difficult to spot, though you may have noticed that your computer
is running much more slowly than usual or you may notice regular
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disk activity even when you are not doing anything. Ignoring this
problem is risky to you and your personal information. Thus, bots
need to be removed to protect your data and your personal
information.
Many bots are designed to work in a very stealthy manner, and as
such, there may be a need to make sure that the Internet user
understands the magnitude of the threat faced despite the stealthy
nature of the bot.
It is also important to note that it may not be immediately apparent
to the Internet user precisely which devices have been infected with
a particular bot. This may be due to the user's home network
configuration, which may encompass several hosts, where a home
gateway that performs Network Address Translation (NAT) to share a
single public IP address has been used. Therefore, any of these
devices can be infected with a bot. The consequence of this for an
ISP is that remediation advice may not ultimately be immediately
actionable by the Internet user, as that user may need to perform
additional investigation within their own home network.
An added complication is that the user may have a bot infection on a
device such as a video console, multimedia system, appliance, or
other end user computing device that does not have a typical desktop
computing interface. As a result, diligence needs to be taken by the
ISP where possible such that it can identify and communicate the
specific nature of the device that has been infected with a bot and
provide further appropriate remediation advice. If the ISP cannot
pin down the device or identify its type, then it should make it
clear to the user that any initial advice given is generic and
further advice can be given (or is available) once the type of
infected device is known.
There are a number of forums that exist online to provide security-
related support to end users. These forums are staffed by volunteers
and often are focused around the use of a common tool set to help end
users to remediate hosts infected with malware. It may be
advantageous to ISPs to foster a relationship with one or more
forums, perhaps by offering free hosting or other forms of
sponsorship.
It is also important to keep in mind that not all users will be
technically adept, as noted in Section 5.10. As a result, it may be
more effective to provide a range of suggestion options for
remediation. This may include, for example, a very detailed "do it
yourself" approach for experts, a simpler guided process for the
average user, and even assisted remediation as described in
Section 6.2.
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6.1. Guided Remediation Process
Minimally, the Guided Remediation Process should include the
following goals, with options and/or recommendations for achieving
them:
1. Back up personal files. For example:
Before you start, make sure to back up all of your important
data. (You should do this on a regular basis anyway.) You
can back up your files manually or using a system backup
software utility, which may be part of your Operating System
(OS). You can back up your files to a USB Thumb Drive (aka
USB Key), a writable CD/DVD-ROM, an external hard drive, a
network file server, or an Internet-based backup service.
It may be advisable to suggest that the user backup is performed
onto separate backup media or devices if they suspect bot
infection.
2. Download OS patches and Anti-Virus (A/V) software updates. For
example, links could be provided to Microsoft Windows updates,
Apple Mac OS updates, or other major operating systems that are
relevant to users and their devices.
3. Configure the host to automatically install updates for the OS,
A/V, and other common web browsers such as Microsoft Internet
Explorer, Mozilla Firefox, Apple Safari, Opera, and Google
Chrome.
4. Get professional assistance if they are unable to remove the bots
themselves. If purchasing professional assistance, then the user
should be encouraged to predetermine how much they are willing to
pay for that help. For example, if the host that is being
remediated is old and can easily be replaced with a new, faster,
larger, and more reliable system for a certain cost, then it
makes no sense to spend more than that cost to fix the old host.
On the other hand, if the customer has a brand-new host, it might
make perfect sense to spend the money to attempt to remediate it.
5. To continue, regardless of whether the user or a knowledgeable
technical assistant is working on remediating the host, the first
task should be to determine which of multiple potentially
infected machines may be the one that needs attention (in the
common case of multiple hosts in a home network). Sometimes, as
in cases where there is only a single directly attached host, or
the user has been noticing problems with one of their hosts, this
can be easy. Other times, it may be more difficult, especially
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if there are no clues as to which host is infected. If the user
is behind a home gateway/router, then the first task may be to
ascertain which of the machines is infected. In some cases, the
user may have to check all machines to identify the infected one.
6. ISPs may also look at offering a CD/DVD with remediation
processes and software in the event that a host is so badly
infected as to be unable to communicate over the Internet.
7. User surveys to solicit feedback on whether the notification and
remediation process is effective and what recommended changes
could be made in order to improve the ease, understandability,
and effectiveness the remediation process.
8. If the user is interested in reporting the host's bot infection
to an applicable law enforcement authority, then the host
effectively becomes a cyber "crime scene", and the infection
should not be mitigated unless or until law enforcement has
collected the necessary evidence. For individuals in this
situation, the ISP may wish to provide links to local, state,
federal, or other relevant computer crime offices. (Note: Some
"minor" incidents, even if highly traumatic to the user, may not
be sufficiently serious for law enforcement to commit some of
their limited resources to an investigation.) In addition,
individual regions may have other, specialized computer crime
organizations to which these incidents can be reported. For
example, in the United States, that organization is the Internet
Crime Complaint Center, at http://www.ic3.gov.
9. Users may also be interested in links to security expert forums,
where other users can assist them.
6.2. Professionally Assisted Remediation Process
It should be acknowledged that, based on the current state of
remediation tools and the technical abilities of end users, that many
users may be unable to remediate on their own. As a result, it is
recommended that users have the option for professional assistance.
This may entail online or telephone assistance for remediation, as
well as working face to face with a professional who has training and
expertise in the removal of malware. It should be made clear at the
time of offering this service that this service is intended for those
that do not have the skills or confidence to attempt remediation and
is not intended as an up-sell by the ISP.
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7. Failure or Refusal to Remediate
ISP systems should track the bot infection history of hosts in order
to detect when users consistently fail to remediate or refuse to take
any steps to remediate. In such cases, ISPs may need to consider
taking additional steps to protect their network, other users and
hosts on that network, and other networks. Such steps may include a
progression of actions up to and including account termination.
Refusal to remediate can be viewed as a business issue, and as such,
no technical recommendation is possible.
8. Sharing of Data from the User to the ISP
As an additional consideration, it may be useful to create a process
by which users could choose, at their option and with their express
consent, to share data regarding their bot infections with their ISP
and/or another authorized third party. Such third parties may
include governmental entities that aggregate threat data, such as the
Internet Crime Complaint Center referred to earlier in this document,
academic institutions, and/or security researchers. While in many
cases the information shared with the user's ISP or designated third
parties will only be used for aggregated statistical analysis, it is
also possible that certain research needs may be best met with more
detailed data. Thus, any such data sharing from a user to the ISP or
authorized third party may contain some type of personally
identifiable information, either by design or inadvertently. As a
result, any such data sharing should be enabled on an opt-in basis,
where users review and approve of the data being shared and the
parties with which it is to be shared, unless the ISP is already
required to share such data in order to comply with local laws and
applicable regulations.
9. Security Considerations
This document describes in detail the numerous security risks and
concerns relating to botnets. As such, it has been appropriate to
include specific information about security in each section above.
This document describes the security risks related to malicious bot
infections themselves, such as enabling identity theft, theft of
authentication credentials, and the use of a host to unwittingly
participate in a DDoS attack, among many other risks. Finally, the
document also describes security risks that may relate to the
particular methods of communicating a notification to Internet users.
Bot networks and bot infections pose extremely serious security
risks, so readers should review this document carefully.
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In addition, regarding notifications as described in Section 5, care
should be taken to assure users that notifications have been provided
by a trustworthy site and/or party, so that the notification is more
difficult for phishers and/or malicious parties using social
engineering tactics to mimic. Otherwise, care should be taken to
ensure that the user has some level of trust that the notification is
valid and/or that the user has some way to verify via some other
mechanism or step that the notification is valid.
10. Privacy Considerations
This document describes at a high level the activities to which ISPs
should be sensitive, i.e., where the collection or communication of
PII may be possible. In addition, when performing notifications to
end users (see Section 5), those notifications should not include
PII.
As noted in Section 8, any sharing of data from the user to the ISP
and/or authorized third parties should be done on an opt-in basis.
Additionally the ISP and or authorized third parties should clearly
state what data will be shared and with whom the data will be shared.
Lastly, as noted in other sections, there may be legal requirements
in particular legal jurisdictions concerning how long any subscriber-
related or other data is retained. An ISP operating in such a
jurisdiction should be aware of these requirements and should comply
with them.
11. Acknowledgements
The authors wish to acknowledge the following individuals and groups
for performing a detailed review of this document and/or providing
comments and feedback that helped to improve and evolve this
document:
Mark Baugher
Richard Bennett
James Butler
Vint Cerf
Alissa Cooper
Jonathan Curtis
Jeff Chan
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Roland Dobbins
Dave Farber
Stephen Farrell
Eliot Gillum
Joel Halpern
Joel Jaeggli
Scott Keoseyan
Murray S. Kucherawy
The Messaging Anti-Abuse Working Group (MAAWG)
Jose Nazario
Gunter Ollmann
David Reed
Roger Safian
Donald Smith
Joe Stewart
Forrest Swick
Sean Turner
Robb Topolski
Maxim Weinstein
Eric Ziegast
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12. Informative References
[BIOS] Sacco, A. and A. Ortega, "Persistent BIOS Infection",
March 2009, <http://www.coresecurity.com/files/
attachments/Persistent_BIOS_Infection_CanSecWest09.pdf>.
[Combat-Zone]
Alshech, E., "Cyberspace as a Combat Zone: The Phenomenon
of Electronic Jihad", February 2007, <http://
www.memrijttm.org/content/en/report.htm?report=1822>.
[Conficker]
Porras, P., Saidi, H., and V. Yegneswaran, "An Analysis of
Conficker's Logic and Rendezvous Points", March 2009,
<http://mtc.sri.com/Conficker/>.
[DDoS] Saafan, A., "Distributed Denial of Service Attacks:
Explanation, Classification and Suggested Solutions",
March 2009, <www.exploit-db.com/download_pdf/14738/>.
[Dragon] Nagaraja, S. and R. Anderson, "The snooping dragon:
social-malware surveillance of the Tibetan movement",
March 2009,
<http://www.cl.cam.ac.uk/techreports/UCAM-CL-TR-746.pdf>.
[Estonia] Evron, G., "Battling Botnets and Online Mobs: Estonia's
Defense Efforts during the Internet War", 2008, <http://
journal.georgetown.edu/wp-content/uploads/9.1-Evron.pdf>.
[Gh0st] Vallentin, M., Whiteaker, J., and Y. Ben-David, "The Gh0st
in the Shell: Network Security in the Himalayas",
February 2010, <http://www.infowar-monitor.net/wp-content/
uploads/2010/02/cs294-28-paper.pdf>.
[RFC1459] Oikarinen, J. and D. Reed, "Internet Relay Chat Protocol",
RFC 1459, May 1993.
[RFC2142] Crocker, D., "MAILBOX NAMES FOR COMMON SERVICES, ROLES AND
FUNCTIONS", RFC 2142, May 1997.
[RFC3954] Claise, B., "Cisco Systems NetFlow Services Export Version
9", RFC 3954, October 2004.
[RFC5070] Danyliw, R., Meijer, J., and Y. Demchenko, "The Incident
Object Description Exchange Format", RFC 5070,
December 2007.
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[RFC5965] Shafranovich, Y., Levine, J., and M. Kucherawy, "An
Extensible Format for Email Feedback Reports", RFC 5965,
August 2010.
[RFC6108] Chung, C., Kasyanov, A., Livingood, J., Mody, N., and B.
Van Lieu, "Comcast's Web Notification System Design",
RFC 6108, February 2011.
[Snort] Roesch, M., "Snort Home Page", March 2009,
<http://www.snort.org/>.
[Spamalytics]
Kanich, C., Kreibich, C., Levchenko, K., Enright, B.,
Voelker, G., Paxson, V., and S. Savage, "Spamalytics: An
Empirical Analysis of Spam Marketing Conversion",
October 2008, <http://www.icir.org/christian/publications/
2008-ccs-spamalytics.pdf>.
[Threat-Report]
Ahamad, M., Amster, D., Barret, M., Cross, T., Heron, G.,
Jackson, D., King, J., Lee, W., Naraine, R., Ollman, G.,
Ramsey, J., Schmidt, H., and P. Traynor, "Emerging Cyber
Threats Report for 2009: Data, Mobility and Questions of
Responsibility will Drive Cyber Threats in 2009 and
Beyond", October 2008, <http://smartech.gatech.edu/
bitstream/1853/26301/1/CyberThreatsReport2009.pdf>.
[Whiz-Kid] Berinato, S., "Case Study: How a Bookmaker and a Whiz Kid
Took On a DDOS-based Online Extortion Attack", May 2005,
<http://www.csoonline.com/article/220336/
How_a_Bookmaker_and_a_Whiz_Kid_Took_On_a_DDOS_based_Online
_Extortion_Attack>.
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Appendix A. Examples of Third-Party Malware Lists
As noted in Section 4, there are many potential third parties that
may be willing to share lists of infected hosts. This list is for
example purposes only, is not intended to be either exclusive or
exhaustive, and is subject to change over time.
o Arbor - Atlas, see http://atlas.arbor.net/
o Internet Systems Consortium - Secure Information Exchange (SIE),
see https://sie.isc.org/
o Microsoft - Smart Network Data Services (SNDS), see
https://postmaster.live.com/snds/
o SANS Institute / Internet Storm Center - DShield Distributed
Intrusion Detection System, see http://www.dshield.org/about.html
o ShadowServer Foundation, see http://www.shadowserver.org/
o Spamhaus - Policy Block List (PBL), see
http://www.spamhaus.org/pbl/
o Spamhaus - Exploits Block List (XBL), see
http://www.spamhaus.org/xbl/
o Team Cymru - Community Services, see http://www.team-cymru.org/
Livingood, et al. Informational [Page 28]
RFC 6561 Remediation of Bots in ISP Networks March 2012
Authors' Addresses
Jason Livingood
Comcast Cable Communications
One Comcast Center
1701 John F. Kennedy Boulevard
Philadelphia, PA 19103
USA
EMail: jason_livingood@cable.comcast.com
URI: http://www.comcast.com
Nirmal Mody
Comcast Cable Communications
One Comcast Center
1701 John F. Kennedy Boulevard
Philadelphia, PA 19103
USA
EMail: nirmal_mody@cable.comcast.com
URI: http://www.comcast.com
Mike O'Reirdan
Comcast Cable Communications
One Comcast Center
1701 John F. Kennedy Boulevard
Philadelphia, PA 19103
USA
EMail: michael_oreirdan@cable.comcast.com
URI: http://www.comcast.com
Livingood, et al. Informational [Page 29]
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