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

[Comments-info-renewal-18mar19] Comment by Telepathy Inc. in opposition to the renewal of the .info agreement
by Nat Cohen April 29, 2019

April 29, 2019

I am writing to oppose the terms of the proposed .info renewal agreement for the reasons offered in the comment submitted by the Internet Commerce Association at https://mm.icann.org/pipermail/comments-info-renewal-18mar19/2019q2/000203.… and as discussed in the CircleID article "The Spurious Justifications for Eliminating Price Caps on .org and other Legacy Domains" located here: http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminat… The legacy domain names, including .info and .org, were handed over to ICANN as trustee to manage for the public benefit. ICANN has betrayed that trust by turning .info over to a private company to exploit for its own benefit. Of the various rationale given in support of this policy, *that ICANN does not want to "become a price regulator" is the most disingenuous and pernicious*. ICANN as a *trustee of the public interest* for the legacy domains is, and always has been, and unless it abdicates its responsibility, will continue to be a setter of prices within the legacy extensions. Has ICANN throughout its history been overstepping its authority when it entered into agreements that included terms governing pricing? The US Department of Justice viewed ICANN's role as creating competitive mechanisms, such as putting registry agreements out for rebid, to keep prices low for registrants, and failing that, the DOJ clearly stated it was ICANN's role to manage the TLDs in a manner that "*safeguards the interests of registrants* in obtaining high quality domains *at the lowest possible prices*." ( https://www.icann.org/en/system/files/files/baker-to-dengate-thrush-18dec08… ) The DOJ expressly stated that *ICANN should set price caps* in the absence of putting out registries for competitive bid: "Because ICANN's proposed registry agreement lacks any [pricing] safeguards,... ICANN should consider revising the proposed registry agreement, at least for instances where there is not competitive bidding to operate a new gTLD, to include provisions designed to limit the ability of the registry operator to exercise market power, i.e., *price caps*..." The DOJ called for agreements that included *a maximum price and limitations on price increases*: "ICANN's requests for bids [to operate a new gTLD] should expressly call for bids to specify *an initial maximum price* that would be charged by the operator for domain registrations, as well as* limitations on price increases *over time.." The DOJ knew that relying on market forces and competition were not adequate where registries had market power. The DOJ found that .com and other gTLD registry operators had *market power*: "our investigation of the .com agreement found evidence that *other gTLD registry operators may possess a degree of market power*. The market power inherent in other gTLDs is less than the market power in .com, but is still material..." and "Further, *the introduction of new gTLDs is not likely to constrain the market power by existing gTLDs*..." On the one hand we have a registry talking point that ICANN should not "become a price regulator". On the other hand, the US Department of Justice is castigating ICANN for not doing enough to protect registrants since "ICANN has not come close to fulfilling its obligations to employ competitive principles in its management of TLD registry operations." As a consequence, since ICANN has created an environment where registries have market power "*ICANN should take steps to protect consumers from the exercise of market power by gTLD operators*". The nature of developed domains as online brands, means that once established there is no substitute for that domain and the registrant is locked into continued use of that domain as long as it wants to continue using its brand. ICANN is creating a situation akin to the USPTO allowing a private company the right to set whatever price it wanted for trademark owners to continue using their trademarks or else the trademark owner would be forced to abandon the right to its trademark. I believe this commenter expresses the issue well: This is basically sanctioning extortion, a domain name is closer to a trademark, except a company is apparently not allowed to own it... instead they *must keep "leasing" their trademark from a registrar*. What do I get for improving my domain name (making my business known, improving public trust, running a well known blog/ news site)? Clearly higher rent costs on that same name. https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/001439.h… There is nothing pro-competitive about the proposed agreement. It is a set up for extortion. This approach should be rethought with appropriate price safeguards established.

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[Comments-info-renewal-18mar19] Please help keep our non-commercial Internet costs down
by ian April 29, 2019

April 29, 2019

As you can see by the sparse amount of comments for the ".info" top-level domain, there's not a whole lot of us out there. Please help protect our minority interests by keeping the costs down on .info domain registration. You have the power to do this, and we would appreciate your support in protecting our primarily non-commercial interests by keeping our costs affordable. Thank you for your consideration!

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[Comments-info-renewal-18mar19] Comment
by bb120190＠fastmail.fm April 29, 2019

April 29, 2019

Why is it deemed necessary to remove price-increase caps? Are running costs increasing that much from year to year despite no evidence of similar cost increases in other parts of the Internet and IT sectors? Domain rental is expensive enough as it is, and these caps are one of the few things preventing domain registration from potentially turning into a complete free-market free-for-all accessible only to the rich. There are and can be no reasonable grounds for removing these caps. J Gerrard, domain tenant.

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[Comments-info-renewal-18mar19] Proposed Renewal of .info & .biz Registry Agreements
by Saron Harford April 29, 2019

April 29, 2019

Hello, I am very concerned about the removal of price caps currently being discussed for .info and .biz domains. It will directly affect my business and hundreds of thousands of small business owners just like me. Advancements in technology should be driving the cost of operating a registry down, yet prices keep going up. Removing price caps is unfair to the millions of domain registrants. They will have no price protections. Every registrant will be at the complete mercy and whims of the registry. ICANN is supposed to represent a "bottom up, consensus-driven multistakeholder model". ICANN should not unilaterally impose URS in legacy TLDs when that issue is precisely what is being examined by the volunteer ICANN Working Group who has been mandated to review this issue. There is no "public benefit" justification to these changes. It is just a handout to business at the expense of registrants’ rights and protections. Where are the protections for the millions of domain registrants that this could effect in a negative way? These changes would give way too much power to the registry. I hope you will take my concerns seriously. Kind regards, | | | Saron Harford | | Designer & Developer | | Tiger-Fruit Web & Graphic Design | | m: | +353 868 272 999 | | w: | www.tiger-fruit.com e: saron(a)tiger-fruit.com | | Thank you for supporting Irish business

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[Comments-info-renewal-18mar19] Keep the price cap on INFO
by Brady Owens April 29, 2019

April 29, 2019

I write to oppose the removal of price caps on any of the “legacy” TLDs as doing so will only create a free-for-all on limitless price increases across the well-established board. These legacy domain names, some of which have been registered for many years, are unlike the new mess being created and owners of these legacy names have a reasonable expectation of affordability and stability. Brady Owens Owner Fastglass LLC tele: 617.682.9484 email: info(a)fastglass.net

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[Comments-info-renewal-18mar19] Proposed removal of pricing cap on .info
by Humphrey Drummond April 29, 2019

April 29, 2019

Dear ICANN I run my family email on a .info site. I object to the pricing cap being removed. I actually struggle to pay the current fees. Regards Humphrey Drummond

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[Comments-info-renewal-18mar19] Please do not increase prices
by Paula Salcedo April 29, 2019

April 29, 2019

Most .info domain owners are either small businesses, non-profit small groups or individuals. It would be really unfair for them to be affected by these changes. These websites are either educational or helpful platforms where people learn. Let's not make it difficult for them to share knowledge. Sincerely, *Ailleen Paula Salcedo*

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[Comments-info-renewal-18mar19] Reject Proposal
by David Powys April 29, 2019

April 29, 2019

A domain name is an ID which one would expect to keep for a long time. Remove price cap and unscrupulous domain registrars can lure one to by a domain name at a very low price, then increase this to a very high price on renewal. This is unacceptable Regards David Powys

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[Comments-info-renewal-18mar19] Do not allow unlimited price increases!
by Norman Edwards April 29, 2019

April 29, 2019

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[Comments-info-renewal-18mar19] Limit increase to 10%
by Christine Esposito April 29, 2019

April 29, 2019

To whom it may concern: Please retain the allowable 10% per year increase in wholesale price of .info domains. Please do not let Public Interest Registry (PIR) set whatever price it wants upon extension of its contract, which could mean exorbitant price increases. My understanding is that registrars would need to recupe their increased expenses by spreading them across various domain types. As a small business owner, I cannot afford such increases, which would mean losing my websites. Without them, I am severely hampered in my ability to gain new customers and sustain my business. Very concerned about the widespread negative impact of such a change, Christine Esposito

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