- comments-info-renewal-18mar19@icann.org

[Comments-info-renewal-18mar19] I oppose the removal of the price cap
by Paul Pliska April 30, 2019

April 30, 2019

As someone who uses .info domain as a main email and web address, I understand that existing registrants will keep their price protection, but even so I oppose the removal of the price cap. I don't think older TLDs, such as .info, can be compared to newer "vanity" TLDs. Moreover, I see no reason to give them a new Registry Operator a new better deal, let them stick to what was originally agreed.

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[Comments-info-renewal-18mar19] Comment on the proposed renewal of .info Registry Agreement.
by Paul Tattersfield April 29, 2019

April 29, 2019

Mr. Russ Weinstein, Global Domains Division 29-04-19 Dear Mr. Weinstein, Thank you for the opportunity to comment on the proposed renewal of .info Registry Agreement. ICANN needs to decide if it wishes to be a bottom-up consensus driven governance organization or simply a trade organization looking after its own contracted parties from which it derives its own revenue. This conflict of interest is not new In 1776 Adam Smith in “An Inquiry Into the Nature and Causes of the Wealth of Nations (vol. 1 chapter 10)” wrote: “People of the same trade seldom meet together, even for merriment and diversion, but the conversation ends in a conspiracy against the public, or in some contrivance to raise prices. It is impossible indeed to prevent such meetings, by any law which either could be executed, or would be consistent with liberty and justice. But though the law cannot hinder people of the same trade from sometimes assembling together, it ought to do nothing to facilitate such assemblies, much less to render them necessary.” Smith's point is that the only way businesses can succeed in a ‘conspiracy against the public’ is if they are given protection by governmental regulation. Under the false premise of competition and standardization of contracts ICANN GDD staff are asking the public to believe that they are acting in the public interest even when it is quite straightforward to show that the removal of pricing caps is clearly to the detriment of consumers. The justifications for additional commercial freedoms for ICANN’s contracted parties are being presented as being in return for the acceptance of improved protections such as URS. Whilst this may at first sound plausible ICANN GDD staff must be aware that the URS rights protection mechanism is currently being reviewed by the All Rights Protection Mechanism Working Group (RPM WG) through the bottom-up multi-stakeholder consensus driven model. Indeed one of the questions being asked by the RPM WG is should URS be extended to all gTLDs including .info and .org? So one has to wonder why ICANN even bothers having a bottom-up multi-stakeholder model, where some of the most qualified people in the world freely give up hundreds of hours of their time to find the best solutions, if its outcomes are to be pre-determined top-down by ICANN GDD staff. The other justification is competition through an equal playing field this is based on ICANN’s mission to introduce competition. >From the 1998 MOU part of ICANN mission was to introduce competition II.C.2. Competition - This Agreement promotes the management of the DNS in a manner that will permit market mechanisms to support competition and consumer choice in the technical management of the DNS. This competition will lower costs, promote innovation, and enhance user choice and satisfaction. 1 More specifically V.C.9.c. Potential consumer benefits/costs associated with establishing a competitive environment for gTLD registries. 1 One way of establishing competition is to allocate the rights to run a registry for a fixed term and on expiry of that term hold an invitation to tender for a subsequent term. The alternative approach to registry competition which ICANN has tried to adopt is to award each gTLD to a registry in perpetuity and then try and generate the competition, sort under the various MOUs, by awarding new additional gTLDs to competing registry companies. Whilst this approach has provided substantial benefits for ICANN’s contracted parties this approach has provided very few tangible consumer benefits. This is quite simply because domains are not substitutable. The disruption cost to move to an alternative far outweighs the cost to provide the service, so rather than creating the required competition ICANN is simply creating a series of non-competing private monopolies and the removal of prices caps will simply compound this policy failure. One only has to look around the world where contracts to run TLD registries are awarded at $2-$3 per domain to realise that ICANN’s attempts to introduce competition are failing. If ICANN is not prepared to operate a model where it puts the running of its gTLDs out to tender then it should be looking at introducing wholesale price caps in the $3 - $4 range. .info is used by a lot of small site owners often on a low or non-profit basis around the world. These users are particularly sensitive to price increases and especially so when their local prices are multiplied by a strong US Dollar exchange rate against their own currency. So ICANN really does need to reflect on how it can provide greater consumer benefits/costs associated with establishing a genuinely competitive environment for gTLD registries as opposed to its current approach of creating an increasingly generously rewarded series of non-competing private monopolies. Yours sincerely, Paul Tattersfield https://gpmgroup.info/

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[Comments-info-renewal-18mar19] Tucows Comment on Legacy TLD Contracts
by Graeme Bunton April 29, 2019

April 29, 2019

Please see the attached comment from Tucows. Regards Graeme -- ____________________________ Graeme Bunton Director, Analytics & Policy Tucows Inc. PH: 416 535 0123 ext 1634

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[Comments-info-renewal-18mar19] RrSG response to Proposed Renewal of .info, .org & .biz Registry Agreements
by Zoe Bonython April 29, 2019

April 29, 2019

Hello, On behalf of the Registrar Stakeholder Group I would like to submit the attached combined response to proposed Renewal of .info, .org & .biz Registry Agreements. Kind regards, Zoe Bonython RrSG Secretariat

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[Comments-info-renewal-18mar19] Keep Price Caps on Domain Names!
by Derek Gunn April 29, 2019

April 29, 2019

If price-caps removed, prices of domain names will inevitably increase. This will make it that much harder for innovators to take their first steps. Given that the web itself is an innovation, it is not at all in the spirit to allow a hurdle to prevent further innovation. Sincerely, Derek Gunn -- *LERT.Info* Alerting Systems

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[Comments-info-renewal-18mar19] INTA Comments
by Lori Schulman April 29, 2019

April 29, 2019

Please find INTA's comments attached. If you have any questions or concerns, please do not hesitate to contact me. Lori Schulman Senior Director, Internet Policy International Trademark Association 1250 Connecticut Avenue, Suite 700 Washington DC, USA +1-202-704-0408, skype: lsschulman www.inta.org<http://www.inta.org/> [2019_AM_Boston_register (003)] Find us on: [Description: Description: Description: cid:F361C18F-02FE-4CF0-A43E-AA8566DC2514] Twitter<https://twitter.com/INTA> [Description: Description: LinkedIn] LinkedIn<http://www.linkedin.com/groupInvitation?groupID=69899> [Description: Description: facebook-logo (2)] Facebook<http://www.facebook.com/home.php?#!/GoINTA?ref=ts> [Description: Description: pnpb_sig.png]

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[Comments-info-renewal-18mar19] info pricing
by Burt Culver April 29, 2019

April 29, 2019

Please do not change the domain pricing policy for .info domains. Allowing the prices of domains to increase dramatically whill mean that non-profits and small companies will struggle to pay for their domain names and will eventually be priced off the internet. Regards, Burt Burt Culver Los Angeles, CA

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[Comments-info-renewal-18mar19] CHUT SHEL CHESSED'S PUBLIC COMMENT SUBMITTED BY RABBI SHALOM ARUSH ON PROPOSED RENEWAL OF .INFO REGISTRY AGREEMENT
by RUBIN INTERNATIONAL LAW FIRM AND NOTARY April 29, 2019

April 29, 2019

Hi, Please find enclosed the Public Comment regarding the Proposed Renewal of .info Registry Agreement, of the Chut Shel Chessed Institutions submitted by Rabbi Shalom Arush, Head of the Institutions. Regards Jean-Philippe Naftali Rubin, International lawyer since 1992 LLM BA MA Licensed in Israel and in Europe Member of the forums of international law and cyber law of the Hebrew University of Jerusalem Rubin International Law Firm & Notary Avinoam Yelin 11 St., POB 5552 Jerusalem, Israel Tel: +972-(0)2-6422295 - Fax: +972-(0)2-6311227 Cellular: +972-(0)544-705-200 Website: <http://www.advrubin.com/> www.advrubin.com Email: <mailto:naftali.rubin@gmail.com> naftali.rubin(a)gmail.com info(a)advrubin.com <mailto:info@advrubin.com>

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[Comments-info-renewal-18mar19] Dont modify the agreement to uncap renewal increases
by Hiram Munn April 29, 2019

April 29, 2019

I find it troubling that the proposed change would remove renewal fee caps on existing .info domains. This change would remove the stability that the core, "legacy" domains provide new and upcoming businesses, as well as protected entrenched businesses from being punished for succeeding in business. Please stop/do not make this change. It only seeks to further commercialize and exploit the internet. - Hiram Munn Concerned Domain Registrant

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[Comments-info-renewal-18mar19] .info price caps
by jules hummon April 29, 2019

April 29, 2019

It is completely unfair to the nonprofits serving the public good, to be charged for their .info domain name as if they were a for-profit company and had money to spare. I reject this proposed increase.

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