
Njalla – A privacy-aware domain registration service - TonnyGaric
https://njal.la/blog/opening/
======
mattzito
> When you purchase a domain name through Njalla, we own it for you. However,
> the agreement between us grants you full usage rights to the domain.
> Whenever you want to, you can transfer the ownership to yourself or some
> other party.

That's extremely concerning, given that the domain name industry has a very
robust set of regulations and legal procedures to govern privacy, mediate
dispute, and establish consumer rights. I'd be very concerned about what this
relationship between Njalla and myself would do to those protections - they're
not a registrar, nor are they a reseller - what am I actually paying them for?

Unfortunately, the ToS and/or registration agreement that I am signing up for
doesn't appear anywhere that I was able to find. I went through the purchase
flow to try to buy a domain, but it won't let me proceed without funds in my
wallet, and I'm not going to put 30 euro just to try and read a legal doc.

In other words, this seems like it's Probably a Bad Idea(tm), though it's
difficult to know without more transparency on their part. (full disclosure: I
work for a company involved in the domain industry)

~~~
smarx007
§2.3:

1337 will have the right to immediately terminate the provision of the
Services and these Terms, as stipulated below under section 9.2. Such
termination will have the effect that 1337 may, at its discretion, choose to
assume the registered domain name and hold it in its own account, let it
expire, or sell it to a third party.

~~~
HenryBemis
Seriously? "leet"??

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jaclaz
Isn't it queer that "right-wing extremists" are seemingly prohibited from
expressing their own "political weird thinking"?

>Think of us as your friendly drunk (but responsibly so) straw person that
takes the blame for your expressions. As long as you keep within the
boundaries of reasonable law and you're not a right-wing extremist, we’re for
promoting your freedom of speech, your political weird thinking, your kinky
forums and whatever. Even Trump is welcome. Hell, he might even be a customer.
We’ll never know. We might even be approved by him! Or not. We don’t really
care.

~~~
uiri
I found this strange too. It sets a bad precedent. Neonazis are banned but the
Black Bloc is OK? Does the Westboro Baptist Church fall under the umbrella of
right-wing extremists? They mention reasonable law too. That seems to exclude
child porn. What about libel? Copyright infringement? Pro-marijuana domains?
Or domain usage that is pro-hard drugs?

~~~
Nullabillity
> Copyright infringement?

This is one of Peter Sunde's projects, I wouldn't be too worried about that
one.

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wlkr
Another similar service which has been around for a while is PRQ [0,1] which
was created by Gottfrid Svartholm and Fredrik Neij, both founders of TPB. PRQ
offer far more than just domains and accept payment via BTC. They also have a
proven track record of hosting extremely controversial content.

[0]: [https://prq.se/](https://prq.se/)

[1]: [https://en.wikipedia.org/wiki/PRQ](https://en.wikipedia.org/wiki/PRQ)

~~~
ReverseCold
[http://i.imgur.com/3mpqkOPh.jpg](http://i.imgur.com/3mpqkOPh.jpg)

~~~
wlkr
As far as I can tell that's the result of an image (from ipv6forum.com) in
their footer being loaded over http.

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GBiT
Main selling point of Njalla is that one of its founders is ex ThePirateBay
guy, Peter Sunde who fights for privacy and creating privacy related services.
He is a co-founder of Flattr. So it is more of a trust service.

------
brey
> As long as you keep within the boundaries of reasonable law

that's pretty subjective.

~~~
amq
> If you use our service in a way that affects anyones health or safety, we
> reserve the right to suspend your service

Clarifies it a bit

~~~
vertex-four
I'd argue that's still overly broad, unfortunately. Do we interpret that as
direct threat - i.e. someone's somehow using the service to directly fuck with
people's pacemakers or nuclear facilities or something - or something broader,
like for example a site being used to organise a harassment campaign against
someone? Does a site used for serving malware fit in that definition
somewhere? Etc etc.

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imjustsaying
>As long as you keep within the boundaries of reasonable law and you're not a
_right-wing extremist_ , we’re for promoting your freedom of speech

What did he mean by this

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marjans
lol I made almost the same thing earlier this year and everyone told me that
it's never going to work out (it also didn't because I'm getting like 0
visits) [http://anonname.com/](http://anonname.com/)

~~~
tyingq
It might be the lack of any upfront information on the terms and conditions as
well as your technical approach to preserve privacy (remailers, etc).

~~~
marjans
yeah you are probably right, I should add that ..

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Artemis2
How do people concerned about security here register their domains? Security
of some registrars seems extremely spotty and nobody really talks about how
they're safer to use than the competition, but domains are a huge single point
of failure. Maybe there is space for a specialized service, something close to
Cloudflare Registrar
([https://www.cloudflare.com/registrar/](https://www.cloudflare.com/registrar/))?

------
feld
This is good. The closest I've been able to get to anonymous ownership is
buying a domain on Gandi and then delegating all roles except Owner to another
Gandi account under a fake name. This way I never show up in WHOIS at all but
I guess Gandi still knows who bought it (I didn't use bitcoin)

I really want to see more of these kinds of services. Anonymity is important.

~~~
tyingq
Section 9.2 in their TOS, though, seems a little concerning.

 _" 9.2 1337 may in its sole discretion, also terminate the Services and these
Terms and choose to keep, sell, suspend or cancel your domain name
registration if:"[1]_ (list of conditions follows)

I can see why that's needed, but it doesn't give a good feel to how much
they'll push back before abandoning you once somebody is unhappy with your
domain and/or content. Would have a better feel if they replaced "keep/sell"
with "transfer", which they would be compelled to do, for example, if an ICANN
dispute was lost. I would really want a little more detail on what exactly
they do for common things like ICANN inquiries, disputes, DMCA, etc.

[1][https://njal.la/tos/#term_9_2](https://njal.la/tos/#term_9_2)

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interfixus
Handing over my domain control to some hazy third party?

Some hazy third party in _Sweden_ , where top officials up to and including
government ministers vocally promote the idea the idea of internet censorship,
and where people have actually been sent to actual jail for voicing opinions.

I think I'll pass.

~~~
galagan
Njalla is owned by 1337 LLC in Nevis. It's also possible to own your domain
within Njalla if you don't want them to be the actually owner of it.

I just moved my domains there. Super happy with the service since it's so
simple and clean.

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nolok
I see that they are offering the .fr TLD, for which such anonymity is illegal
as far as I know (eg even OVH as a registrar and they OwO service which
display OVH as the owner to be contacted and then transmit contact to you is
not allowed).

I guess the difference here is that they don't hide the real owner behind a
"contact us to get through" as they are themselves the real owner, so they
might be legal, but then comes the question of "do you really want someone
else to be the legal owner of the domain of your website".

~~~
user5994461
>>> "do you really want someone else to be the legal owner of the domain of
your website".

Interesting. I'd expect the problem to be the other way around.

Do Njalla want to be legally liable for all domains run by their customers?

~~~
nolok
I see that as a non issue because of the jurisdiction they're in (a small
Caribbean place).

If there is an issue (drugs, pedophilia, the usual suspects ...) they close it
down immediately, claim they weren't owner of the content and were merely
leasing the domain to the user, since a sub-lease is what they're effectively
doing.

If the domain because popular, they can seize control of it easily, or start
snooping on users, or do whatever the hell they want.

------
uiri
.ca solves this issue by not publicly publishing the details of individual
registrants in the Whois system. CIRA still keeps a record so that they know
who the owner of the domain is. Corporate/organizational registrants still
have their contact information made public.

Is there a reason why Njalla is better than this reasonable system?

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ijafri
Their ratio is going to be 10 customers x 10 DMCA notices.

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redxblood
This is extremely expensive.

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dijhrykl
This is an interesting idea executed terribly. Obviously there are huge
liabilities associated with this kind of proxying, but for people which want
or need highly anonymous domain registration it could be a worthwhile idea if
backed up by an adequately robust contract.

The issues: firstly, they don't support freedom of speech:

>As long as you keep within the boundaries of reasonable law and you're not a
right-wing extremist, we’re for promoting your freedom of speech

Secondly, they don't make it clear in what jurisdiction they operate.

Thirdly, they don't specify anywhere what registrar(s) they use to register
domains. This prevents customers from performing due diligence on the
registrar and its history (for example, does the registrar have a history of
arbitrary domain suspensions?)

Fourthly, as mentioned in another comment, their terms of service is absurdly
loose with regards to their responsibilites; they can terminate service
arbitrarily, and have no obligation to transfer ownership to you in this case.
This is completely unacceptable.

Fifthly, their website doesn't work properly without JavaScript. This is
completely unacceptable in any case, but is particularly egregious for an
anonymity-focused service which provides a Tor hidden service, where many
customers may wish to keep JavaScript disabled (as is Tor Browser's default)
to reduce attack surface. Apparently people don't know how to make websites
anymore.

Sixthly, their website copy is amateurish and has basic typographical errors.

Seventh, and perhaps most gravely of all, their entire website betrays a
fundamental misconception of the roles and demarcation of a registrar (or
pretend registrar, as is the case here.) Above I mention that they are anti-
free speech, but the very fact that they think it is the place of a (pretend)
registrar to have a policy on this matter betrays a fundamental misconception
about the liabilities of a domain registrar. The very idea that a domain
registrar (or pretend domain registrar) should be in some way responsible for
content hosted "on" a domain is faulty, and at the same time sets a hazardous
precedent; this is exactly the kind of thinking which absolutely should not be
encouraged or perpetuated in the domain name industry, as it is only going to
lead to more and more political intervention at the domain name level.

A domain name registrar nominates domain names (meaning essentially the name
itself, plus the specified nameservers) to a domain name registry. The only
legitimate involvement a registrar has in the use of the domain name is any
issue involving the legality of the literal domain name string itself, or the
nameserver names, or maybe WHOIS data. Notice that for all its faults, this
actually moreorless matches the ICANN model: There are dispute processes for
trademark issues regarding the domain name string itself, and dispute
processes for WHOIS data. There are emphatically not ICANN dispute processes
for content served by nameservers, or content served by hosts referenced by
zone data served by nameservers! (I suppose theoretically someone could find a
way to break a law with the nameserver names themselves; setting a nameserver
for example.com to <illegal-string>.example.com, say, but it seems like that's
sufficiently obscure a possibility that it has not yet arisen.)

A domain name registrar is not responsible for the content served by name
servers referenced by a domain name, let alone the content served by services
provided by hosts referenced by the content of a zone file served by a name
server referenced by a domain name. That this pretend registrar fundamentally
fails to comprehend this demarcation of responsibility is extremely
problematic, and betrays a troubling lack of understanding of the system.

Of course, it certainly may be the case that domain name registries and
registrars (and pretend registrars) in the future get more and more dragged
into disputes regarding services provided by hosts referenced by zone files
served by nameservers referenced by a domain name, but this is _extremely_
undesirable. It would represent the politicization of the domain name system,
which would itself seriously undermine its stability and reliability. We have
already seem some attempts to politicize the system and they do not bode well;
it's certainly not helpful if registrars start overestimating the degree of
their responsibility, as it only increases the feasibility of future
politicization of the domain name system.

In particular, it should be noted that there is basically no case where the
seizure of a domain name for the content it "hosts" (in reality, references,
not even directly but via a set of referenced nameservers) can be
proportionate; or at least, no case where it can be reliably ascertained that
the seizure of a domain would not be grossly disproportionate.

For example, if google.com accidentally hosts a small amount of illegal
material, should google.com be suspended? Of course not; so unless one is
suggesting that 'important' domains should be subject to different, more
preferential rules than 'unimportant' domains (an affront to the idea of an
internet open for all), where is one supposed to draw the line?

Moreover, most nameservers do not allow zone transfers. This means that the
extent of a zone served by nameservers referenced by a domain name cannot be
reliably ascertained, which again means that there is no way to reliably
ascertain that the seizure of a domain name is not grossly disproportionate.
If a domain hosts illegal.example.com, but also hosts a million legal
subdomains, how can the seizure of example.com for hosting illegal.example.com
be proportionate? There is no way to reliably ascertain the existence of
subdomains, so illegal.example.com could be known to search engines but the
million legal subdomains could be unpublished, internal names yet unknown (by
obscurity) to the world. Even if the full contents of a zone could be reliably
ascertained, most records reference IPs (A/AAAA), not services (SRV, MX), so
unless you portscanned every IP referenced, that doesn't tell you what type of
service is hosted on those subdomains (and even if you did portscan those IP
addresses, there's the possibility that some services are firewalled to
certain source IPs, for example services for internal use only, etc. etc.; the
possibilities are endless, and thus so are the opportunities for unforeseeable
collateral damage).

There is an extremely relevant real-world example of this: the no-ip.org
debacle (no-ip.org is a domain which provides free subdomains to arbitrary
parties), in which a court, truly extraordinarily, allowed a private
corporation, Microsoft, to assume control of the entire no-ip.org domain,
simply because of a single bad user, and a very tenuous claim that the abusive
subdomain involved infringement of a Microsoft trademark. This resulted in
massive disruption to all other no-ip.org users. Again, there is no way of
reliably ascertaining an upper bound for the operational impact caused by a
domain seizure.

~~~
dijhrykl
Another example is the case of US ICE seizing domains quite dubiously. This
brings me to another example of how the seizure of domains for law enforcement
purposes related only to services provided by hosts referenced by the zone
files served by nameservers referenced by those domains is almost necessarily
disproportionate: when one seizes a domain one assumes control of all records
served by it, including MX records. As such, when one seizes a domain, one
takes control not just of any websites served via it, but any email service
for it as well. (For this reason in particular, thinking of domain names as
fundamentally website-centric is hazardous to the future political integrity
of the domain name system. Domain names are not websites.) As such when ICE
seizes a domain, they also are implicitly assuming the right to redirect all
incoming email to that domain to them (not even intercept but forward, e.g.
with a warrant, but redirect outright). In fact, I'm not sure if this would
even be illegal; if you've obtained a domain legally, you can configure it as
you wish.

If someone claims a domain of mine, example.com, has a website facilitating
illegal activity, and has it seized by some jurisdiction's law, what if my
principal email address is @example.com? Now I am deprived of the ability to
engage in correspondance so as to ascertain the grounds for such seizure and
contest it. The intention was to disable the website, yet email service and
potentially an arbitrary number of other services are also disrupted. Again, I
reiterate that there is no way of reliably ascertaining an upper bound to the
operational impact of a domain seizure, and as such it is hard to see that
domain seizures can ever be reliably ascertained to be proportionate as a law
enforcement measure in advance.

The idea of domain seizures as a law enforcement method is a really, really
bad idea. It makes about as much sense, and is as about as proportionate, as
the postal service revoking the address of someone who commits mail fraud;
their house number is literally erased from databases, and mailmen return mail
sent to that house number as undeliverable. Nobody would claim this is a sane
way of dealing with abuse of the postal service.

And of course, nothing in this should seem like it makes law enforcement
impractical. If a service is illegal, go after the people, the company, the
servers; going after the domain always has the potential to cause extreme
collateral damage, and the degree of damage which may be caused cannot be
ascertained in advance. Even more worryingly, to the extent that we've seen
seizures so far, it seems like something mostly done because it is easy, not
because it is right; a cheap, usually due-process-free way of smiting websites
deemed improper when persuing the persons or machines involved would be more
effort. This reduces the trustworthiness and reliability of the domain name
system, and its ability to serve an apolitical role for entities of all
countries worldwide. This is a disaster for the law abiding just as much as it
is for the lawless.

If this company is serious about the robustness of domain names, it needs to
stop perpetuating an idea of the registrar (or pretend registrar) as a
publisher, as a legally responsible entity for the services dereferencable via
domain names, particularly since such a model of liability is, mercifully, not
yet one that has appears to have become reality. To do so simply accelerates
the undesirable.

------
vavoida
nice service, I like the idea of the automatic pgp-key-lookup-service

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franciskim
ICANN shutting this down in 3...2...1...

~~~
jbg_
It won't even take ICANN, since I seriously doubt they are accredited
themselves. They are probably dealing with one or more resellers and may well
be breaching the terms of their agreements with those resellers.

~~~
galagan
You don't think they have look this up before they started to build this
service? I'm pretty sure they have been thinking of every little scenarios
that might come up and double check with all parts involved.

~~~
jbg_
It really wouldn't be the first time a startup hadn't fully checked the
regulations that would affect them, or decided to take their chances with
flaunting them…

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lsjdfkljdfwkwdf
No DNSSEC support?

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Sophira
They don't seem to be very interested in listening to feedback:

> We're sure it's the best there is, but since we're always improving, we'll
> pretend to listen to your feedback and make it better.

Openly saying that they'll only "pretend" to listen to feedback doesn't fill
me with confidence.

~~~
galagan
Think it where writing with some irony...

