Before any office can be competent, the thing complained of must be identified. Ordinary speech treats "a domain" as one object with one owner and one remedy. The system that exists is otherwise. A name is several objects, loosely coupled by convention, and the powers that attach to each object do not travel with the others.
First, a name is a string in a namespace, allocated under a TLD. That string is a registry object. It is created in a database maintained by the registry. Statuses such as clientHold, serverHold, pending delete, and the various locks are attributes of that object. Cancellation, transfer, and renewal act on it. ICANN's Registrar Accreditation Agreement and the several Registry Agreements assign investigation and mitigation of DNS Abuse, as those instruments define the term, to registrars and to registries. The Operator is neither a registrar of record nor a registry operator.
Second, a name may be pointed at name servers. Pointing is a later act. It may never occur. When it does occur, the NS set published at the parent identifies hosts that will answer questions about the name. An authoritative nameserver, including those operated here, answers for zones an account has pointed here and refuses the rest. Glue, where glue exists, is an address published so that the NS host can be found. Glue is an addressing convenience. Title to the name remains with the registry object and with the sponsorship that the registrar of record continues to hold.
Third, a name may be used as a label for a website, a mailbox, a certificate, or a piece of speech. Those uses live on machines and in protocols other than the authoritative zone. A landing page is served by a host. Mail is accepted by an MX. A certificate is issued by a CA. Each of those operators has its own object and its own powers. Confusion among the three layers is the usual source of mail to this URL. The claimant has seen NS and has written as if a nameserver were a court of first instance over the registration. The Operator is a nameserver. It answers hosted names.
The error is a confusion of identity. The sign by which a thing is found is taken for the thing that can be acted upon. The sign here is NS. If the demand is takedown of the name, the proper object is the registry record. If the demand is removal of content, the proper object is the host. If the demand is a change of billing or of lock, the proper object is the registrar's sponsorship. The Operator holds answers. Answers do not unsell a registration, do not lock a TLD, and do not take down a page.