Submitted by: George Kirikos Company: Leap of Faith Financial Services Inc. Date: May 23, 2017 With regards to the proposed renewal of the .NET registry agreement posted by ICANN at: https://www.icann.org/public-comments/net-renewal-2017-04-20-en my company would like to supplement its previously submitted comments with 2 additional points: 1. My company is opposed to any attempt to impose the URS (Uniform Rapid Suspension) policy on .NET registrants. The URS is not a consensus policy that went through the rigorous GNSO PDP process. Instead, it is an implementation detail of the failed new gTLDs program. The implementation details of the failed new gTLDs program should not be mirrored through a back-room bilateral negotiation between ICANN staff and the .NET registry operator. Instead, the multi-stakeholder model demands that only policies that have gone through the GNSO be required to be adopted by registries/registrars/registrants once they are consensus policies. INTA claims that adoption of the URS is somehow an "operational cost" for new gTLD registry operators, and that they are somehow harmed by the URS. In fact, it's *registrants* who face the costs and obligations imposed by the flawed URS, an unproven system that was agreed to by new gTLD registry operators as part of the "price" of having their unwanted new gTLDs adopted. There is an active GNSO PDP that is reviewing all rights protection mechanisms, including the URS and UDRP. Any attempt to add the URS to legacy TLDs like .com/.net/.org should await the completion of that PDP. 2. The proposed .NET renewal agreement keeps the ICANN fees at 75 cents per domain per year, despite those fees being 25 cents per domain name per year in all other registry agreements, e.g. for .org: https://www.icann.org/resources/unthemed-pages/org-agmt-html-2013-09-12-en (section 7.2(a)) and .com: https://www.icann.org/resources/pages/agreement-2012-12-05-en (section 7.2(a)) The extra 50 cents per year per domain per year is a $7.5 million annual tax on .NET registrants, given there are 15 million .NET domain names at present and those fees are passed on to consumers (registrants). There is no good reason why .NET domain registrants should face this fee discrimination by ICANN. It needs to be reduced to 25 cents per domain per year. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/