April 2019 - comments-org-renewal-18mar19@icann.org

[Comments-org-renewal-18mar19] Comment Re: Removal of Price Caps in .org Registry Agreement -- Submitted by NPR, YMCA, C-SPAN, National Geographic Society, AARP, The Conservation Fund, Oceana, and National Trust for Historic Preservation
by Briana Thibeau April 29, 2019

April 29, 2019

[NPRLogo_RGB] April 29, 2019 ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Attn: Russ Weinstein, Global Domains Division To the ICANN Staff and Board: The undersigned non-profit organizations write to express our opposition to the removal of price caps in the .org Registry Agreement (the ".org Agreement"). We agree with the current .org registry operator, the Public Interest Registry, that the .org gTLD "has assumed the reputation as the domain of choice for organisations dedicated to serving the public interest."[1] We have come to rely on this reputation to help distinguish the online presence of our organizations from the online presence of organizations that are not intended to serve the public interest. As nonprofit organizations, we also have come to rely on the certainty and predictability of reasonable domain name registration expenses when allocating our limited resources. We therefore are disappointed and concerned that ICANN has proposed removing price caps from the .org Agreement. The reasonable expectation of .org registrants was, and continues to be, that prices would remain capped to ensure stable and reasonable domain name pricing for the millions of nonprofit organizations that have invested in a .org web presence. These organizations put their trust in ICANN as caretaker of the public interest in the .org name space. If the existing price caps are removed, there will be no limits on the prices the Public Interest Registry can charge, and any wholesale cost increases imposed by the registry likely will be passed on to .org registrants such as the organizations we represent. This will accordingly introduce new budgetary uncertainty to the class of organizations that can least afford such uncertainty. Every additional dollar earmarked for domain name registrations is a dollar that is not available to advance the public interest purpose of nonprofit registrants that use the .org name space. While it is possible the Public Interest Registry may choose not to raise prices, despite the removal of the caps, the .org registry is too important to leave this decision to the registry's discretion. ICANN has articulated no compelling policy basis for this proposed change. Instead, ICANN has represented that the intent is just to bring the .org Agreement into conformity with the base registry agreement used by ICANN with respect to other gTLDs not set aside for organizations that serve the public interest. This strikes us as conformity for its own sake. ICANN should not disregard the public interest in favor of administrative convenience. Moreover, the Public Interest Registry is a nonprofit organization itself, and there is no evidence that it needs to somehow compete with for-profit registries, or that it needs unlimited additional funds to continue to operate as it has. The .org gTLD is in a unique position as the presumed domain space for public interest organizations - a domain space that was created to benefit the public. ICANN has an obligation to ensure that the name space and the governing .org Agreement continue to reflect the public interest objectives of its constituency. We hope that ICANN will reconsider this proposal and ensure that price caps are retained in the final agreement. _______________________ [1] https://pir.org/about-us/history/ Sincerely, NPR [cid:image002.png@01D4FEAC.C3571080] Briana E. Thibeau, Deputy General Counsel YMCA OF THE USA Karyn Boston, Executive Vice President and Chief Legal Officer C-SPAN Bruce D. Collins, Corp. VP & General Counsel National Geographic Society Angelo M. Grima, EVP, General Counsel & Secretary AARP Leslie Nettleford, Associate General Counsel The Conservation Fund Holly Cannon, Executive Vice President and General Counsel Oceana Eric A. Bilsky, Assistant General Counsel National Trust for Historic Preservation Paul W. Edmondson, Interim President and CEO ________________________________ [1] https://pir.org/about-us/history/

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[Comments-org-renewal-18mar19] .org pricing
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 .org domain name as if they were a for-profit company and had money to spare. I reject this proposed increase. Jules

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[Comments-org-renewal-18mar19] Objection to removal of .org price cap
by Benjamin Esham April 29, 2019

April 29, 2019

Hello, I am writing with regard to the terms of the proposed renewal of the .org registry agreement; specifically, with the removal of the price cap provision in the current version of the agreement. This provision protects current registrants from arbitrary, capricious, and unearned increases in the price of their domain registrations. New registrants should get the same protection. The removal of the price cap would enrich wholesale registries while providing no benefit to—and, indeed, hurting—everyone else, including the many non-profit and charitable organizations that register .org domains. Please do not adopt any agreement that removes the price cap. Thank you. Benjamin Esham

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Suvil Sipani April 29, 2019

April 29, 2019

I am a domain name registrant. ICANN does not seem to recognize the difference between a legacy extension created with the support of the US government, that predates the existence of ICANN and that has millions of existing users and the brand new extensions that started off with a new set of rules, in particular no price controls, and no existing registrants. They have completely different characteristics, history, and ownership structure. It is not acceptable for ICANN to ignore these differences and to propose that they be treated the same. Removing price caps is not fair to .org domain owners. Many of them have websites that they have used for years. If price caps are removed, the cost to renew their domain names may become too expensive, and they could be forced to give up websites that are important to them. The Uniform Rapid Suspension policy is too new and untested to apply on domain names that may be 20 years old or more. With the URS, the domain names could be taken down in a matter of days with little notice. ICANN should be doing more to protect owners of .org domain names. Why is ICANN trying to remove price protections for .org domain owners, so many of which are non-profits, so that they can be overcharged for their domain names?

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[Comments-org-renewal-18mar19] Do not remove price caps
by Puli gesi April 29, 2019

April 29, 2019

Hello, I'm referring to this article - https://domainnamewire.com/2019/04/24/how-icann-uses-the-org-registry-to-fu… On behalf of 10 million Non profits out there. It's not okay to remove the price caps on the .org TLD. Protect non profits from rent seeking monopolies. Regards, Puligesi

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[Comments-org-renewal-18mar19] Don’t remove price caps for legacy TLDs
by Yevgen Yeryomenko April 29, 2019

April 29, 2019

I am a .org registrant. ICANN staff 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. ICANN policy making is supposed to be a ‘bottom up, multi-stakeholder model’. I believe that legacy gTLDs are fundamentally different from for-profit new gTLDs. Legacy TLDs are essentially a public trust, unlike new gTLDs which were created, bought and paid for by private interests. Registrants of legacy TLDs are entitled to price stability and predictability, and should not be subject to price increases with no maximums. Unlike new gTLDs, registrants of legacy TLDs registered their names and made their online presence on legacy TLDs on the basis that price caps would continue to exist. Unrestrained price increases on the millions of .org registrants who are not-for-profits or non-profits would be unfair to them. Unchecked price increases have the potential to result in hundreds of millions of dollars being transferred from these organizations to one non-profit, the Internet Society, with .org registrants receiving no benefit in return. ICANN should not allow one non-profit nearly unlimited access to the funds of other non-profits. ICANN appears to be entirely catering to registries by removing price caps. ICANN should stand up for the public interest and registrants! Sincerely, Eugene

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[Comments-org-renewal-18mar19] Comment re: .org price cap lift
by Samuel Reed April 29, 2019

April 29, 2019

The Internet is a public resource and it is ICANN's responsibility to be the caretakers for it, not to extract maximum profit from it. The proposed cap lift on .info, .org, and .biz is the beginning of the end for the democratization of the Internet and DNS as a whole. When we all got on the Internet, we thought we had truly discovered something different, something democratic, by the people for the people. Please don't prove a whole generation wrong for dollars.

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[Comments-org-renewal-18mar19] Price cap removal an abdication of responsibility
by Kevin Ohashi April 29, 2019

April 29, 2019

Removing the price cap on legacy gTLDs is an act of regulatory capture, plain and simple. These are non-competitive, monopoly contracts providing internet services with diminishing costs at scale and for years ICANN has allowed them to raise their prices on consumers. The fixed increases were bad enough, but uncapping it and saying the market will decide is dangerous and irresponsible. Perhaps PIR could increase the price of icann.org to match every dollar in the ICANN budget, that would be acceptable and surely ICANN could simply move to another TLD without issue. It would be a massive problem, everyone can understand that. So why is anyone even considering removing the price cap provisions? Do your job properly and keep price cap provisions in the contract. Kevin Ohashi

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[Comments-org-renewal-18mar19] concern at removing .org domain price increase limits
by michael＠cryptograph.org April 29, 2019

April 29, 2019

Dear sirs, As a long-time registered owner of two .org domains used for hobbyist purposes, I am concerned about proposed changes to remove the ten percent per year price increase limits on .org domains. I understand that commercial domain, such as .com domains, can involve greater maintenance costs, and sometimes justify larger cost increases, but I wish to urge you to retain some limits on ability to increase .org domain costs on a yearly basis. Michael Jeffrey Brooks

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Niall Pithey April 29, 2019

April 29, 2019

I am a domain name registrant. ICANN does not seem to recognize the difference between a legacy extension created with the support of the US government, that predates the existence of ICANN and that has millions of existing users and the brand new extensions that started off with a new set of rules, in particular no price controls, and no existing registrants. They have completely different characteristics, history, and ownership structure. It is not acceptable for ICANN to ignore these differences and to propose that they be treated the same. Removing price caps is not fair to .org domain owners. Many of them have websites that they have used for years. If price caps are removed, the cost to renew their domain names may become too expensive, and they could be forced to give up websites that are important to them. The Uniform Rapid Suspension policy is too new and untested to apply on domain names that may be 20 years old or more. With the URS, the domain names could be taken down in a matter of days with little notice. ICANN should be doing more to protect owners of .org domain names. Why is ICANN trying to remove price protections for .org domain owners, so many of which are non-profits, so that they can be overcharged for their domain names? ---------------------------------------------------------------------- Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) to which it is addressed and may contain information that is confidential, privileged or exempt from disclosure under applicable law. Any unauthorized review, use, disclosure, printing, storing, copying or distribution is prohibited. If you are not the intended recipient, or if you have received this email in error, please contact the sender by reply e-mail and delete all copies of the original message. Unless specifically stated otherwise, nothing in this email is intended to serve as an electronic or digital signature.

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