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

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

April 29, 2019

Hello, I am a .org registrant. I've read about a lot of bad decisions under the UDRP. The URS seems even worse. I heard that the URS is very new and is being reviewed now to see if it is working properly. It is too soon to include an untested policy on .org domains where for a few hundred dollars anyone could try to shut down someone else's website. Telling the .org registry that it can charge any price it wants for renewing a domain name is a terrible idea. Why would you allow them to set a crazy high price? They could try to force the domain owners to pay a very high price each year to renew their domain name, and if the domain owner either won't or can't, then the .org registry could take away their domain name, set a high registration price on it, and then try to find someone else who is willing to pay a high price for it. This is very unfair to long time .org domain owners who may see their prices raised sky high for no reason. You let the new domain extensions charge any price they want, but that hasn't gone so well. Lots of people got burned when the new registries offered low rates for the first year, and then after people registered the domain names and some built web sites on them, some of the prices were raised through the roof. .Org has been working just fine for decades where the prices maybe go up a little bit each year. Allowing huge price increases from one year to the next could ruin .org for everybody. I think you should pay more attention to what is good for the owners of .org domain names. The registries are doing fine. They don't need your help as they are already making plenty of money. Sincerely, Richard Dobson

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

April 29, 2019

I am a .org registrant (not-for-profit). I've read about a lot of bad decisions under the UDRP. The URS seems even worse. I heard the URS is very new and is being reviewed now to see if it is working properly. It is too soon to include an untested policy on .org domains where for a few hundred dollars anyone could try to shut down someone else's website. Telling the .org registry that it can charge any price it wants for renewing a domain name is a terrible idea. Why would you allow them to set a crazy high price? They could try to force the domain owners to pay a very high price each year to renew their domain name, and if the domain owner either won't or can't, then the .org registry could take away their domain name, set a high registration price on it, and then try to find someone else who is willing to pay a high price for it. This is very unfair to long time .org domain owners who may see their prices raised sky high for no reason. You let the new domain extensions charge any price they want, but that hasn't gone so well. Lots of people got burned when the new registries offered low rates for the first year, and then after people registered the domain names and some built web sites on them, some of the prices were raised through the roof. .Org has been working just fine for decades where the prices maybe go up a little bit each year. Allowing huge price increases from one year to the next could ruin .org for everybody. I think you should pay a little more attention to what is good for the owners of .org domain names. The registries are doing fine. They don't need your help as they are already making plenty of money. Sincerely, Julia Lord

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

April 29, 2019

I am a .org registrant (not-for-profit). Legacy gTLDs are fundamentally different from for-profit new gTLDs and should be treated that way. Legacy TLDs are what the internet was built on. They are essentially a public trust. They are very different than new gTLDs which were created, bought and paid for by private parties. Registrants of these legacy extensions should be entitled to price predictability & stability. 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. This could result in a transfer of funds from millions of non-profits to one non-profit, with no benefits to the domain registrants. 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. ICANN should be looking out for the .org registrants, in particular the non-profits. 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. This is not acceptable for a "public benefit" organization that exists to represent many stakeholders. Get Outlook for Android<https://aka.ms/ghei36>

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

April 29, 2019

I am a domain name registrant, and I respectfully request that ICANN retain its existing pricing agreement for .org domains, and NOT implement the ability for PIR to raise prices without restriction. Rather than try to completely rephrase it, I offer selected passages from Zak Muscovitch's comment of Apr. 10, 2019, which highlight the main reasons behind my request: "So, other than conveniently "aligning" registry agreements to purportedly treat all registries alike despite their respective and dramatically different mandates, registrant base, and histories, what justification is there for unlimited price increases? There is no evidence whatsoever that the .org registry requires unlimited additional funds to maintain reliable operations. There is no evidence that the .org registry requires unlimited additional funds to finance the goods works of the Internet Society. There is no evidence that the .org registry needs unlimited funds in order to "compete" with other for-profit registries, particularly when the current operator, PIR, is a not-for-profit organization. In short, there is simply no justification for permitting the .org registry operator to raise prices at all, let alone with a sky-is-the-limit approach.... "The .org registry is simply too important to be permitted to be the subject of its operator's discretion, even if well meaning." Sincerely, Jonathan B. Harms

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

April 29, 2019

I am a domain name registrant. Legacy gTLDs are fundamentally different from for-profit new gTLDs and should be treated that way. Legacy TLDs are what the internet was built on. They are essentially a public trust. They are very different than new gTLDs which were created, bought and paid for by private parties. Registrants of these legacy extensions should be entitled to price predictability & stability. 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. This could result in a transfer of funds from millions of non-profits to one non-profit, with no benefits to the domain registrants. 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. ICANN should be looking out for the .org registrants, in particular the non-profits. 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. This is not acceptable for a "public benefit" organization that exists to represent many stakeholders. <http://polymesh.nwcolor.com>

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

April 29, 2019

I am a .org registrant. Legacy gTLDs are fundamentally different from for-profit new gTLDs and should be treated that way. Legacy TLDs are what the internet was built on. They are essentially a public trust. They are very different than new gTLDs which were created, bought and paid for by private parties. Registrants of these legacy extensions should be entitled to price predictability & stability. 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. This could result in a transfer of funds from millions of non-profits to one non-profit, with no benefits to the domain registrants. 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. ICANN should be looking out for the .org registrants, in particular the non-profits. 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. This is not acceptable for a "public benefit" organization that exists to represent many stakeholders.

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[Comments-org-renewal-18mar19] Comments on Decision to Remove Price Caps on Legacy gLTDs
by Michael DeLong April 29, 2019

April 29, 2019

To whom it may concern, Attached are the comments of Mr. David A. Balto on the decision to remove price caps on legacy gTLDs. This is largely a competition question, as competition disciplines markets and protects consumers from monopoly prices. Market regulations, especially price regulations, are best used in markets in which there is “market failure” that market forces can not lead to a competitive result or in markets that tend towards natural monopolies. Mr. Balto does not believe this to be the case in the gTLD market. Please let us know if you have any questions. Sincerely, Michael DeLong Law Offices of David Balto

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Hampton Moore 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!

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[Comments-org-renewal-18mar19] ICANN must retain some price caps, especially on renewals
by Andrew Allemann April 29, 2019

April 29, 2019

For the reasons stated below, ICANN must reconsider its proposal to remove price caps on .org domain names. Market power at the time of registration It is technically true that there are a lot of choices when it comes to choosing a domain name. If I want to register example.com, I can choose to register a longer .com, opt for a .net or .info domain, a ccTLD or choose from hundreds of new top level domains such as example .xyz. But let’s face it, people usually want .com. It has extraordinary market power. Back in 2008, the U.S. Department of Justice Antitrust Division explained <https://www.icann.org/en/system/files/files/baker-to-dengate-thrush-18dec08…>(pdf) this in a letter to ICANN regarding new top level domain names. It stated: “Our investigation of the proposed .com agreement generated several findings that bear on the likely effect of creating new gTLDs. First, we found that VeriSign possesses significant market power as the operator of the .com registry because many registrants do not perceive .com and other gTLDs (such as .biz and .info) and country code TLDs (“ccTLDS,” such as .uk and .de) to be substitutes… …We also concluded that existing gTLDS would not become a competitive threat to .com registrations because the network effects that make .com registrations so valuable to consumers will be difficult for other TLDs to overcome. Due to a first-mover advantage and high brand awareness, .com registrations account for the overwhelming majority of gTLD registrations… Even with the introduction of hundreds of new top level domains since this letter was written, they have barely chipped away at .com’s market power. Do other TLDs have market power? I’d argue .org does. Charities and non-profits often think of .org first instead of .com. The antitrust department noted: “Finally, 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.” In order of power in the gTLD market, I’d argue that .com is highest and .org is second highest. ccTLDs also have market power in some countries. The presence of market power for initial registrations suggests that prices for some top level domains should be restricted. A non-profit is unlikely to choose .charity over .org unless it is unable to acquire the .org domain. It will usually choose an alternate, longer .org domain before choosing something else. This might not be true in twenty years but it is true in 2019. For top level domains that don’t have market power and are easy substitutes for each other, controlling initial registration prices is not as important. That’s part of the reason people are complaining more about .org price caps than .info. High switching costs and market power at the time of renewal Domain names have immense switching costs. Companies that switch from one domain name to another often spend months planning the move. Some spend years. Some spend hundreds of thousands of dollars. There are two reasons the switching costs are high. First is search engines. Google is the lifeblood of many website’s traffic. Even the best-planned domain name transition can have serious traffic (and thus monetary) impacts. When HomeAdvisor switched its domain from ServiceMagic.com it saw a marked drop in traffic and revenue. On its conference call after switching domains, the company stated <https://domainnamewire.com/2013/05/09/homeadvisor-domain-change/>: HomeAdvisor domestic revenue was negatively impacted by a 20% decrease in accepted service requests due primarily to the domain name change. 20% from a domain name change! It took the company a while to regain the search rankings it had before. Even companies that create and manage websites for a living have to expend significant resources <https://domainnamewire.com/2015/12/04/how-a-creative-agency-switched-from-c…> to change domain names. It can be done but it’s very difficult. The second reason for high switching costs is email. Companies often have thousands of email addresses tied to their domain name. These email addresses are then tied to many online accounts. Switching domain names means updating all the mailboxes technically and all the accounts associated with them. It means emailing all customers and telling them about the new addresses. It undoubtedly means missing some important emails when the switch happens. I have an acquaintance who was offered over $200,000 for a domain name he registered in 1997. He declined because he and his family have email addresses tied to the domain. It would mean changing hundreds of account registrations at websites and countless hours of work. It’s one thing to switch email addresses if the company retains its prior domain name and can forward email to the new one. But if a company has to relinquish an old domain name due to renewal costs, it will miss out on this email forwarding and probably miss important messages. These high switching costs make domain owners hostages to the registries that operate their domains. They simply have to pay whatever they are charged. The cost to switch is too much. For this reason, renewal costs *must* be capped. How domain registration and renewal costs should be managed Some top level domains have market power at the time of registration. All top level domains have tremendous power over registrants at the time of renewal. For this reason, ICANN should consider capping initial registry fees for top level domains that have some level of market power, such as .com and .org. It should limit prices on *all* domains at the time of renewal. The organization has stated that registrants have some protection because they can renew domains for up to ten years at current prices before price hikes take effect. There are two problems with this. First, the registries must notify the registrars of the price increase. It’s up to the registrars to notify customers. Busy customers might overlook these notices or not have the cash to renew for ten years today. Second, and most importantly, this just kicks the can down the road. What does a company do ten years from now when it has to pay the new rates. Regards, Andrew Allemann -- ______________________ www.DNW.com @domainnamewire

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[Comments-org-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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