One document matched: draft-oreirdan-mody-bot-remediation-09.txt
Differences from draft-oreirdan-mody-bot-remediation-08.txt
Internet Engineering Task Force J. Livingood
Internet-Draft N. Mody
Intended status: Informational M. O'Reirdan
Expires: December 8, 2010 Comcast
June 6, 2010
Recommendations for the Remediation of Bots in ISP Networks
draft-oreirdan-mody-bot-remediation-09
Abstract
This document contains recommendations on how Internet Service
Providers can manage the effects of computers used by their
subscribers, which have been infected with malicious bots, via
various remediation techniques. Internet users with infected
computers are exposed to risks such as loss of personal data, as well
as increased susceptibility to online fraud and/or phishing. Such
computers can also become an inadvertent participant in or component
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 Internet-Draft is submitted in full conformance with the
provisions of BCP 78 and BCP 79.
Internet-Drafts are working documents of the Internet Engineering
Task Force (IETF). Note that other groups may also distribute
working documents as Internet-Drafts. The list of current Internet-
Drafts is at http://datatracker.ietf.org/drafts/current/.
Internet-Drafts are draft documents valid for a maximum of six months
and may be updated, replaced, or obsoleted by other documents at any
time. It is inappropriate to use Internet-Drafts as reference
material or to cite them other than as "work in progress."
This Internet-Draft will expire on December 8, 2010.
Copyright Notice
Copyright (c) 2010 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
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Table of Contents
1. Requirements Language . . . . . . . . . . . . . . . . . . . . 4
2. Key Terminology . . . . . . . . . . . . . . . . . . . . . . . 4
3. Introduction and Problem Statement . . . . . . . . . . . . . . 6
4. Important Notice of Limitations and Scope . . . . . . . . . . 8
5. Detection of Bots . . . . . . . . . . . . . . . . . . . . . . 8
6. Notification to Internet Users . . . . . . . . . . . . . . . . 12
7. Remediation of Hosts Infected with a Bot . . . . . . . . . . . 18
8. Guided Remediation Process . . . . . . . . . . . . . . . . . . 20
9. Professionally-Assisted Remediation Process . . . . . . . . . 21
10. Sharing of Data from the User to the ISP . . . . . . . . . . . 22
11. Security Considerations . . . . . . . . . . . . . . . . . . . 22
12. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 23
13. Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . 23
14. Informative references . . . . . . . . . . . . . . . . . . . . 24
Appendix A. Document Change Log . . . . . . . . . . . . . . . . . 26
Appendix B. Open Issues . . . . . . . . . . . . . . . . . . . . . 27
Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . . 29
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1. Requirements Language
The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT",
"SHOULD", "SHOULD NOT", "RECOMMENDED", "MAY", and "OPTIONAL" in this
document are to be interpreted as described in [RFC2119].
2. Key Terminology
This section defines the key terms used in this document.
2.1. 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', or benign bots. Such
benign bots are often found in such environments such as gaming and
Internet Relay Chat (IRC) [RFC1459], where a continual, interactive
presence can be a requirement for participating in the games,
interacting with a computing resource. Since such benign 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.
Thus, while there may be benign, 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 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.
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2.2. Bot Networks, or Botnets
These are defined as concerted networks 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), 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 hosting, hosting of illegal content, use in man-
in-the-middle attacks, and click fraud.
Infection vectors include un-patched operating systems, software
vulnerabilities (which include so-called zero-day vulnerabilities
where no patch yet exists), weak/non-existent passwords, malicious
websites, un-patched browsers, malware, vulnerable helper
applications 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, network security engineers and bot developers.
Initially, some bots used IRC to communicate but were easy to
shutdown 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 P2P, HTTP and
other resilient communication protocols along with 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.
2.3. Host
An end user's host, or computer, as used in the context of this
document, 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, as
well as mobile phones, smart phones, home gateway devices, and other
end user computing devices which are connected or can connect to the
public Internet and/or private IP networks.
Increasingly, other household systems and devices contain embedded
hosts which 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
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with various smart home and smart grid devices.
2.4. Malware
This 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 host to be infected with malware, which may
include a bot or cause a bot to install itself, via inadvertently
accessing a specific website, 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.
2.5. Fast Flux
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 which
then route the web requests to the real host which serves the data
being sought. The proxies are normally run on compromised user
hosts. 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.
3. Introduction and Problem Statement
Hosts used by Internet users, which in this case are customers of an
Internet Service Provider (ISP), can be infected with malware which
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: An Empirical Analysis of Spam Marketing Conversion].
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').
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In addition, these bots can act as platforms for directing,
participating in, or otherwise conducting attacks on critical
Internet infrastructure [Emerging Cyber Threats Report for 2009:
Data, Mobility and Questions of Responsibility will Drive Cyber
Threats in 2009 and Beyond]. Bots are frequently used as part of
coordinated Distributed Denial of Service (DDoS) attacks for
criminal, political or other motivations [The Gh0st in the Shell:
Network Security in the Himalayas] [The snooping dragon:
social-malware surveillance of the Tibetan movement]. 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 [Battling
Botnets and Online Mobs: Estonia's Defense Efforts during the
Internet War] [Cyberspace as a Combat Zone: The Phenomenon of
Electronic Jihad]. Motivations for such coordinated DDoS attacks can
range from criminal extortion attempts through to online protesting
and nationalistic fervor [Case Study: How a Bookmaker and a Whiz Kid
Took On a DDOS-based Online Extortion Attack].
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 bot nets
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.
From end users perspective, 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 which may stem from the bot infection, and protect
themselves againts future threats. Given that 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), destroy or leave the
host in an unrecoverable state via 'kill switch' bot technologies, it
is important to notify the user that they may be infected with a bot.
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 bot nets and minimize the
potential harm that bots can inflict upon Internet infrastructure
generally, 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 bot nets with less capability for disruption.
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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.
4. 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, and 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 [Persistent Memory
Infection]. Experienced users would have to re-flash or re-image
persistent memory sections or components of their hosts in order to
remove persistent memory 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 in some cases enable the user to remediate
the infection. Care must 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.
5. Detection of Bots
An ISP must first identify that an Internet user, in this case a user
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that is assumed to be their customer or otherwise connected to the
ISP's network, is determined to be infected, or likely to have been
infected with a bot. The ISP must attempt to detect the presence of
bots using methods, processes, and tools which maintain the privacy
of the personally identifiable information (PII) of their customers.
The ISP must not block legitimate traffic in the course of bot
detection, and must instead employ detection methods, tools, and
processes which 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 which 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 validate a bot infect 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 to determine potential
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 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 have a relatively low false positive rate in order to
maintain the trust of users. This 'definitive-vs-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 software on their host. This can enable rapid
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performance of 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' PII is maintained. 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, as just as spam defenses may involve scanning the content
of email messages, which may contain PII, then so to may bot defenses
similarly come into incidental contact with PII. The definition of
PII varies from one jurisdiction to the next so proper care must 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
which are available to the customers of a particular ISP.
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 legally permissible or otherwise an industry accepted
practice in a particular market region, an ISP may in some manner
"scan" their 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 to already 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
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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 which may be utilized, it is
unlikely to be particularly effective and it 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 data may include, but is not limited to, IP
addresses of hosts which have or are likely 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
include SNDS from Microsoft, XBL and PBL from Spamhaus, the
DSHIELD AS tool from the SANS Institute.
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 which
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,
frequently as observed at network borders (though ISPs should
beware of source IP address spoofing techniques 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), often by matching
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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. User complaints: 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
RFC2142-specified [RFC2142] role accounts, 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, with security researchers, and with blocklist
operators.
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) 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.
6. 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. Depending upon a range of factors, from
the technical capabilities of the ISP, to the technical attributes of
their 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, among other things, an ISP should decide the most
appropriate method or methods for providing notification to one or
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more of their customers or Internet users. Such notification methods
may include one or more of the following, 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 or a timely basis, 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 such a period as
allows any commonly used bot detection technology to be able to
accurately link an infected IP address to a subscriber. This record
should only be maintained for a period of time which is necessary, in
order to maintain the protection of the privacy of an individual
subscriber.
One important factor to bear in mind is that notification to end
users needs to be resistant to potential spoofing. This must 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.
6.1. 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 that which they have 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 in 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
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access the user's email account and delete the email before it is
read by the user.
6.2. 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
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
as such 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.
6.3. Postal Mail Notification
This form of notification is probably the least popular and effective
means of communication, due to both preparation time, delivery time,
the cost of printing and paper, and the cost of postage.
6.4. 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 are
typically limited by the ISP. In contrast a leaky walled garden
environment permits access to all Internet resources except those
deemed malicious or service and resources that can be used to notify
the users.
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 using a host that uses a web browser or which has a web
browser actively running on it, or that uses another application
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which uses ports which 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
which are 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 different set of drawbacks.
The ISP has to assume that the user will eventually use a web browser
to acknowledge the notification other wise the user will remain in
the walled garden and not know it. If the intent of the leaky walled
garden is to solely 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. For example show
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 which 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 to
either 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
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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 if the user has multiple hosts sharing a single IP
address, such as via a common home gateway device which performs
Network 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 which 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.
6.5. Instant Message Notification
Instant messaging provides the ISP with a simple means to communicate
with the user. There are several advantages to using Instant
Messaging (IM) which makes 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 via a manual process, by 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 subscriber may interpret the communication
to be spim, and as such 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.
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6.6. Short Message Service (SMS) Notification
SMS allows the ISP 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
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 maybe
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.
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 as such 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 maybe 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.
6.7. Web Browser Notification
Near real-time notification to the user's web browser is another
technique that may be utilized for notifying the user, 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
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specified list of destinations in the same way that a walled garden
by definition would. However, as with a walled garden notification,
there is no guarantee that a user is at any given time making use of
a web browser, 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 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 6.4).
6.8. 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 know
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.
6.9. Considerations for Notification to Network Locations Using a
Shared IP Address
Delivering a notification to a location that Internet access 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.
7. 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
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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 provide 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
notice regular 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."
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 which 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 which does not have a typical Windows
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or Macintosh user interface. As a result, diligence needs to be
taken by the ISP where possible such that they can identify and
communicate the specific nature of the device that has been infected
with a bot, and further providing appropriate remediation advice.
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 focussed 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.
8. Guided Remediation Process
Minimally the Guided Remediation Process should include options
and/or recommendations on how a user should:
1. Backup personal Documents, 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 back-up software utility, which may be part of
your Operating System (OS). You can back your files up to a USB
Thumb Drive (aka USB Key), a writeable CD/DVD-ROM, an external
hard drive, or a network file server."
2. Download OS patches and Anti-Virus (A/V) software updates. For
example, links could be provided to Microsoft Windows updates at
http://update.microsoft.com/microsoftupdate/v6/
default.aspx?ln=en-us as well as to Apple MacOS updates at
http://support.apple.com/kb/HT1338?viewlocale=en_US.
3. Explain how to 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. The flow should also have the option for users to get
professional assistance if they are unable to remove the bots
themselves. If purchasing professional assistance, then the user
should be encouraged to pre-determine how much they are willing
to pay for that help. If the host that is being remediated is
old and can easily be replaced with a new, faster, larger and
more reliable system for three or four hundred dollars, the it
makes no sense to spend five or six hundred dollars to fix the
old host, for example. On the other hand, if the customer has a
brand new host that cost several thousand dollars, it might make
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perfect sense to spend the money in attempting to remediate it.
5. To continue, regardless of whether the user or a knowledgeable
technical assistant is working on remediating the host, their
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 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. 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.
7. If the user is interested in reporting his or her host's bot
infection to an applicable law enforcement authority, then the
host effectively becomes a cyber "crime scene" and should not be
mitigated unless or until law enforcement has collected the
necessary evidence. For individuals in this situation, the ISP
should refer them 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.
8. Users may also be interested in links to security expert forums,
where other users can assist them.
9. 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.
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10. 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 infection 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,
to 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 must be enabled on an opt-in based,
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 in
accordance with those laws and applicable regulations.
11. Security Considerations
This document describes in detail the numerous security risks and
concerns relating to bot nets. 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. This document
also describes at a high level the activities that ISPs should be
sensitive to, where the collection or communication of PII may be
possible. Finally, the document also describes security risks which
may relate to the particular methods of communicating a notification
to Internet users. Bot networks and bot infections pose extremely
serious security risks and any reader should review this document
carefully.
In addition, regarding notifications, as described in Section 6, 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, or 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.
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As noted in Section 10, any sharing of data from the user to the ISP
and/or authorized third parties must be done on an opt-in basis.
Additionally the ISP and or authorized third parties must clearly
state what data will be shared and with whom the data will be shared
with.
Lastly, as noted in some other sections, there my be legal
requirements in particular legal jurisdictions concerning how long
any subscriber-related or other data is retained, of which an ISP
operating in such a jurisdiction must be aware and with which an ISP
must comply.
12. IANA Considerations
There are no IANA considerations in this document.
13. Acknowledgements
The authors wish to acknowledge the following individuals for
performing a detailed review of this document and/or providing
comments and feedback with had helped to improve and evolve this
document:
Mark Baugher
Richard Bennett
James Butler
Vint Cerf
Alissa Cooper
Jonathan Curtis
Jeff Chan
Roland Dobbins
Dave Farber
Eliot Gillum
Joel Halpern
Joel Jaeggli
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Scott Keoseyan
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
Eric Ziegast
14. Informative references
[Battling Botnets and Online Mobs: Estonia's Defense Efforts during
the Internet War]
Evron, G., "Battling Botnets and Online Mobs: Estonia's
Defense Efforts during the Internet War", May 2005, <http:
//docs.google.com/
gview?a=v&
q=cache%3AbyUMj6Djlb8J%3Awww.ciaonet.org%2Fjournals%
2Fgjia%2Fv9i1%2F0000699.pdf>.
[Case Study: How a Bookmaker and a Whiz Kid Took On a DDOS-based
Online Extortion Attack]
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>.
[Cyberspace as a Combat Zone: The Phenomenon of Electronic Jihad]
Alshech, E., "Cyberspace as a Combat Zone: The Phenomenon
of Electronic Jihad", February 2007, <http://
www.memrijttm.org/content/en/report.htm?report=1822>.
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[Distributed Denial of Service Attacks: Explanation, Classification
and Suggested Solutions]
Saafan, A., "Distributed Denial of Service Attacks:
Explanation, Classification and Suggested Solutions",
March 2009, <https://docs.google.com/
fileview?id=0B5f1QniGr-
BuZmQ4NDkzNTEtNzkxMy00Nzk4LTlkMjgtNGJlNjAwYWNkYjE3&hl=en>.
[Emerging Cyber Threats Report for 2009: Data, Mobility and Questions
of Responsibility will Drive Cyber Threats in 2009 and Beyond]
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>.
[Persistent Memory Infection]
Sacco, A. and A. Ortega, "Persistent BIOS Infection",
March 2009, <http://www.coresecurity.com/files/
attachments/Persistent_BIOS_Infection_CanSecWest09.pdf>.
[RFC1459] Oikarinen, J. and D. Reed, "Internet Relay Chat Protocol",
RFC 1459, May 1993.
[RFC2119] Bradner, S., "Key words for use in RFCs to Indicate
Requirement Levels", BCP 14, RFC 2119, March 1997.
[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.
[Spamalytics: An Empirical Analysis of Spam Marketing Conversion]
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>.
[The Gh0st in the Shell: Network Security in the Himalayas]
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>.
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[The snooping dragon: social-malware surveillance of the Tibetan
movement]
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>.
Appendix A. Document Change Log
[RFC Editor: This section is to be removed before publication]
-09 version:
o Corrected nits pointed out by Sean
o Removed occurrences of double spacing
o Grammar and spelling corrections in many sections
o Added text for leaky walled garden
-08 version:
o Corrected a reference error in Section 10.
o Added a new informative reference
o Change to Section 5.a., to note additional port scanning
limitations
o Per Joel Jaeggli, change computer to host, to conform to IETF
document norms
o Several other changes suggested by Joel Jaeggli and Donald Smith
on the OPSEC mailing list
o Incorp. other feedback received privately
o Because Jason is so very dedicated, he worked on this revision
while on vacation ;-)
-07 version:
o Corrected various spelling and grammatical errors, pointed out by
additional reviewers. Also added a section on information flowing
from the user. Lastly, updated the reviewer list to include all
those who either were kind enough to review for us or who provided
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interesting, insightful, and/or helpful feedback.
-06 version:
o Corrected an error in the version change log, and added some extra
information on user remediation. Also added an informational
reference to BIOS infection.
-05 version:
o Minor tweaks made by Jason - ready for wider review and next
steps. Also cleared open issues. Lastly, added 2nd paragraph to
security section and added sections on limitations relating to
public and other shared network sites. Added a new section on
professional remediation.
-04 version:
o Updated reference to BIOS based malware, added wording on PII and
local jurisdictions, added suggestion that industry body produce
bot stats, added suggestion that ISPs use volunteer forums
-03 version:
o all updates from Jason - now ready for wider external review
-02 version:
o all updates from Jason - still some open issues but we're now at a
place where we can solicit more external feedback
-01 version:
o -01 version published
Appendix B. Open Issues
[RFC Editor: This section is to be removed before publication]
per Donald, where SNDS is mentioned: That is a list of good examples
but there are a lot of other good 3rd party infected client
notification resources. Arbor via atlas, ShadowServer, Cymru, SIE,
Support Intelligence and many others. It might be worth having a
seperate section near the end that has a list of 3rd parties that are
willing to share this kind of information with ISPs and provide
contact info such as was done for conficker. http://
www.confickerworkinggroup.org/wiki/pmwiki.php/SP/ServiceProviders
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That list is NOT complete in any sense of the word. Providing
contact information may help other ISPs get a more complete set of
third party reports. I am a bit concerned that some of the 3rd party
contact information could change later and be outdated but I believe
most of them will use a role based email account or a link.
per Sean, There is no RFC 2119 language in the document. Was this
intentional? If it is then we could delete section 1. If it's not
then you'll need to figure out which "must", "should", etc. need to
be capitalized.
per Donald, in notification method section, consider taking this text
from the phone method and using as a new section with drawbacks/
challenges: 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.
per Donald, consider w/r/t the WG method: That is really the
definition of a quarantine walled garden. Walled garden's don't have
to quarantine the user (much) to notify the customer. They can be
fairly leaky and still notify the customer of their infection.
per Donald, consider text re users who continue to fail to mitigate:
Another good approach is just to keep track of whom was put into the
walled garden for which infection and if they keep showing up as
infected via the trusted third party reports then you can assume they
are unable/unwilling to remediate and take what ever additional
actions you deem appropriate.
per Donald, inclusion of PII is a good general stmt to consider for
an opening section in the notification part of the doc: As such,
should this method be used, the notification should be discreet and
not include any PII in the notification itself.
per Donald, do we want to consider adding a 'leaky' WG? 'Or design a
leaky walled garden that allows most traffic without interference
only redirecting the traffic needed to mitigate or notify.'
Address suggestion from Donald Smith: The risks to users of infected
systems and others are included/defined in many places within this
document. It should probably be defined clearly in one place and
referenced in all other places.
per Roger - ponder acct termination
A question has been raised about whether this should change from
Informational to BCP.
Livingood, et al. Expires December 8, 2010 [Page 28]
Internet-Draft Remediation of Bots in ISP Networks June 2010
Guided remediation -- these urls while provided for the purpose of
examples are unlikely to be stable on any kind of long timescale.
fundamentally updating os software addresses vulnerability not
remediation (windows malicious software removal tool notwithstanding)
Guided remediation, bullets 4 - 7 -- It's unclear how these steps are
even feasible to undertake for organizations nominally characterized
as ISPs. there's a several thousand fold cost differential between
automated help and remediation by sending a train professional to lay
hands on one computer.
Authors' Addresses
Jason Livingood
Comcast Cable Communications
One Comcast Center
1701 John F. Kennedy Boulevard
Philadelphia, PA 19103
US
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
US
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
US
Email: michael_oreirdan@cable.comcast.com
URI: http://www.comcast.com
Livingood, et al. Expires December 8, 2010 [Page 29]
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