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

[Comments-org-renewal-18mar19] Retain the price-cap on domain renewals
by Andrew April 29, 2019

April 29, 2019

Speaking as a non-commercial .ORG owner, of over 18 years standing, I am appalled by the suggestion that the cost of domain renewals should now become unrestricted. This will not be "competition", it is sure to become a "protection racket" pure and simple! "Nice domain you've got there. Shame if anything should happen to it." In the beginning, the .ORG domain was, I believe, aimed specifically at those non-profit organisations (and individuals) who are, by definition, those least able to afford the inevitable price rises which will now be imposed on a captive market at the mercy of a monopoly supplier. It may, or may not, be reasonable to go head to head with .TV (and the other baby-boomer domains) for new .ORG registrations, but please do not open a milking parlour for your existing .ORG domain owners. Regards,

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[Comments-org-renewal-18mar19] .org Renewal Price Comments
by Andrew Rowat April 29, 2019

April 29, 2019

Just adding my voice - allowing .org TLDs to have arbitrary increases will be net harm to the individuals and businesses who operate these sites. .orgs specifically are often non-profits and performing a greater good. Subjecting them to new regulations which have the potential for huge price increases does not serve the public good. - Andrew.

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Desmond Flood 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. Sent from Mail for Windows 10 --- This email has been checked for viruses by Avast antivirus software. https://www.avast.com/antivirus

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

April 29, 2019

I am writing to oppose the terms of the proposed .org renewal agreement for the reasons offered in the comment submitted by the Internet Commerce Association at https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/000006.h… 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 .org over to an organization, that no matter how worthy its mission, will have the unchecked ability to extract vast sums from the base of .org registrants, many of which are non-profits with worthy missions in their own right. 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 domain names as online brands, means that once established there is no substitute for that domain name and the registrant is locked into continued use of that domain name 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 charge a trademark owner whatever price it wishes for continued use of its trademark or else the trademark owner would be forced to abandon the rights to that 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… The proposed agreement is not pro-competitive. It is a set up for extortion. This approach should be rethought with appropriate price safeguards established.

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Arnau Vàzquez 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.

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[Comments-org-renewal-18mar19] Potential Price Cap Removal on ORG Domains
by Greg Galloway April 29, 2019

April 29, 2019

The .org TLD is frequently used to represent non-profit organizations. It is imperative that access to use of this TLD remain accessible and affordable and that profiteering in this area be prevented. -- Greg Galloway | Director of ABA Technology greg(a)bookweb.org | www.BookWeb.org | www.IndieBound.org Direct: 914.406.7568 Main:914.406.7500 American Booksellers Association 333 Westchester Avenue, Suite S202 White Plains, NY 10604 *Please consider the environment before printing this email*

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[Comments-org-renewal-18mar19] NO to the proposed removal of caps on legacy TLDs
by Michael Neuffer April 29, 2019

April 29, 2019

The proposed removal of the caps on the gTLDs (biz/info/org) would only drive up prices for all users and line the pockets of ICANN and the owners of the privatized registries while ignoring the long history of those TLDs. The gTLDs are are common resource the current registries are just their stewards. So this is a resounding NO to this proposal. Instead the new TLDs should receive a cap as well once they reach a certain size. Kind regards Michael Neuffer

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[Comments-org-renewal-18mar19] .org price increases
by Brian McDonald April 29, 2019

April 29, 2019

We own multiple .org domains and as non-profits we cannot withstand price increases. You should be looking at efficiencies to lower pricing to zero for non-profits and charities. Thank you, Brian McDonald DTM Past District Director Toastmasters District 61 Lead Technical Consultant Archieboy Holding LLC Greentree Hosting LLC Lead FreeToasthost Support https://support.toastmastersclubs.org

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[Comments-org-renewal-18mar19] Changing the .ORG domain names
by Udi Keshet April 29, 2019

April 29, 2019

Hello, The idea to take ORG domain names pricing o TOP Level put our users in risk. We deal with people over 45 years old who want or need to maintain their career. It’s a fragile moment in life while you thought your career is secured and now everything changes. Many business people target that opportunity while people are vulnerated. We run an NGO organization. we chose it in order to make them feel comfortable, letting them express themselves freely. We could highlight our intention by using our website as ORG domain. If you're going to extend the registration fees, it will push us to choose cheaper alternative and the users might lose their confidence. Please reconsider your proposal. regards, Udi Keshet Gray-Haired Club (GHC) -- Regards, Udi Keshet +972 54 6263341

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[Comments-org-renewal-18mar19] .org renewal agreement
by Nick Aked April 29, 2019

April 29, 2019

Dear ICANN, We are a small charity based in UK and the owners of the domain cambriancentre.org . We are concerned that the proposed changes to the agreement, notably the removal of price caps, will expose us to additional costs on domain renewal and could even force us to change our domain, with consequent disruption to our clients. Given that, like ourselves, many .org domain owners are not-for-profit, please retain price caps. regards Nick Aked Trustee Cambrian Community Centre

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