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

[Comments-org-renewal-18mar19] Opposition to elimination of price caps for .org domains
by Henry Tian April 28, 2019

April 28, 2019

Dear ICANN, I strongly oppose the elimination of price caps for .org domains. Many organizations rely on affordable .org domains to conduct operations, and removing the price caps would make it more expensive for them to maintain an Internet presence. As one of the original top-level domains, .org pricing should maintain their current pricing caps to ensure that all organizations have ample opportunity to be represented online. Henry Tian

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[Comments-org-renewal-18mar19] Price caps on .org domains
by Antoine Latter April 28, 2019

April 28, 2019

I don't think it makes sense for ICANN to remove the price-caps on registration of .org domains. The registry-service-providers are contractors operating the .org registry at the hire of ICANN (and for the public good). It does not make sense to allow the contractor to set any price they want. The operation of the .org domain is significantly different in nature to an entity which requests, markets, and operates a new gTLD. It does not make sense to treat the operator of the .org domain "equitably" with operators of a gTLD, as the operator of a gTLD is not being given the gift of a top-level-domain with large cultural, social, and economic value. The operator of the .org domain operates a monopoly with a large amount of value, and ICANN should continue to intervene in the pricing of the monopoly good to arrive at an economically fair outcome. It does not make sense to treat the service-provider of the .org domain the same as the operators of gTLDs as the operator of a gTLD has invented, marketing, and branded the gTLD. The .org domain is a fixture of the public internet, not something that requires actual investment or marketing on the part of the service-provider. I am against this proposed change in the service agreement: - *Pricing for Domain Name Registrations and Registry Services (Section 2.10 of the .org renewal agreement):* In alignment with the base registry agreement, the price cap provisions in the current .org agreement, which limited the price of registrations and allowable price increases for registrations, are removed from the .org renewal agreement. Protections for existing registrants will remain in place, in line with the base registry agreement. This change will not only allow the .org renewal agreement to better conform with the base registry agreement, but also takes into consideration the maturation of the domain name market and the goal of treating the Registry Operator equitably with registry operators of new gTLDs and other legacy gTLDs utilizing the base registry agreement Thanks, Antoine

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[Comments-org-renewal-18mar19] Opposed to .org price increase
by Emma April 28, 2019

April 28, 2019

I am writing in opposition to increases to the .org domain name. The domain name is relatively core and vital for the not-for-profit community. It faces no relative competition at the same gravity and depth as the PIR's market foothold. A policy allowing for .org price has a disproportionate impact for the global south, when taken in conjunction with .com price caps being removed. Many non-profit organizations in the global south already face barriers to accessing an online presence. Furthermore, the existing .ngo TLD is significantly more costly than .org. Many ccTLDs are either not well adopted, face restrictions in access or are significantly more costly than global TLDs such as .org. Sincerely, Emma Smith

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[Comments-org-renewal-18mar19] Retain 10% cap on .org domain prices
by Paul Higgins April 28, 2019

April 28, 2019

I have used the Internet (and its predecessors) since 1983 (prior to the introduction of the .org TLD) and have watched as Internet access moved from the few to the many. I have also managed .org domain names for over twenty years. I'm concerned about the proposal to eliminate the 10% annual cap on price increases by the Registry Operator for .org. The intended customers of .org domain names are not-for-profit organizations who are often tightly constrained for resources. In a perfectly free market, the elimination of the 10% cap would make sense, as competition would keep domain prices in check. While there is a competitive market for registrars (which has produced healthy price competition), there is no competitive market for the Registry Operator's function. Allowing the Registry Operator to raise prices with no cap could create an unfortunate and extreme environment of extreme price increases. There is no appropriate substitute for the purchase of .org domain names. One can't simply switch domain names to a TLD with a lower price, particularly if that not-for-profit organization has years of brand familiarity associated with the .org domain name. While that may be technically feasible, to do so could introduce great risk to a not-for-profit domain holder. Paul Higgins

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[Comments-org-renewal-18mar19] Please Cap the price of .Org domains
by Derrel Fincher April 28, 2019

April 28, 2019

As described, the Pricing for Domain Name Registrations and Registry Services (Section 2.10 of the .org renewal agreement) indicates that there will be no regulation of price, but there is only one Registry Operator. That constitutes a monopoly, and it will be seen and lobbied against as such. There is a reason monopolies are regulated; please consider doing so here to contain prices. Derrel Fincher -- Representative - Oklahoma House District 11 Vice-Chair, Hgher Ed and Career Tech 2300 N Lincoln Blvd., Rm 329, Oklahoma City, OK 73105 derrel.fincher(a)okhouse.gov<mailto:derrel.fincher@okhouse.gov> | (405) 557-7358 NOTICE: The information in this email is confidential, legally privileged, and exempt from disclosure under law. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and unlawful. The Oklahoma House of Reps does not warrant any e-mail transmission received as being virus free, and disclaims any liability for losses or damages arising from the use of this e-mail or its attachments. Recipients of e-mail assume the risk of possible computer virus exposure by opening or utilizing the e-mail and its attachments, and waive any right or recourse against the House by doing so.

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Ali Capo April 28, 2019

April 28, 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? Ali

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Good Omen Goodeze April 28, 2019

April 28, 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. Mary Good Omen Goodeze

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[Comments-org-renewal-18mar19] (no subject)
by Mustafa Gezen April 28, 2019

April 28, 2019

Hello! Regarding the renewal of the .org registry agreement, there has been proposed a new pricing model. The new pricing model removes the upper pricing limit, which can lead to PIR (Public Internet Registry) drastically increasing the prices without any consequences from ICANN. Legacy TLDs like .org should not have the same freedom (regarding to pricing) as the new gTLDs. The reason being that the legacy TLDs is very imprinted into peoples daily lives and serves a different purpose. One can say that they are “official” in a way. If there is an increase in operational cost which absolutely requires a pricing increase on .org domains, then that should be discussed and an absolute percentage (maximum) should be reported to the public beforehand and that percentage should take place in the new registry agreement. If this new registry agreement takes effect without any pricing cap, legacy domains, SMBs and large .org holders all would be affected by this. What separates new gTLDs from legacy gTLDs is that many businesses rely more on the legacy gTLDs for production systems rather than gTLDs because of their stability. Both operational and in pricing. Legacy gTLDs have way more registrants to account for their operational cost than new gTLDs Removing the price cap for legacy gTLDs is nothing more than imposing a cash grab for their respective registries as those legacy gTLDs already have many (many more) registrants than the new ones. *Mustafa Gezen* Bycrates AS, NO 920 348 017 www.bycrates.com

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Sean Mansell April 28, 2019

April 28, 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] Please don't remove the price cap
by Donald L April 28, 2019

April 28, 2019

Dear ICANN, Please don’t remove the price cap because it may cause unreasonable price increase for end customers. Thank you. Best regards, Donald Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10

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