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

[Comments-org-renewal-18mar19] Domain registry fees for ORG domains
by Jon F Caudle Jr April 28, 2019

April 28, 2019

I find it unconscionable that an organization with a monopoly on domain names would have the power to charge whatever fee they choose. If there is no competition permitted in this, then they should be strictly regulated as to pricing. In fact, even the presently allowed 10% annual increase in price is more than should be permitted. Jon Caudle 335475 P O Box 1409 Jefferson City, MO 65102-1409

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement incl .biz/.asia etc.
by Foreign Ventures, Inc. April 28, 2019

April 28, 2019

To whom it may concern We would like to comment on the Proposed Renewal of .org Registry Agreement incl .biz/.asia etc. 1. We do not believe that URS should be introduced in .org and the other legacy TLDs. The timing is not right and the actual worth of URS is debatable. 2. Regarding the proposed lifting of price caps in .org and other legacy TLDs The proposal is deeply flawed and riddled with false equivalence. Rather than reiterate each point we refer to the comprehensive analysis by Nat Cohen here: http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminat… The most fundamental point is that operators of legacy extensions do not own the namespaces that they run, they are mere caretakers. What Icann is proposing is to privatize a public resource, to the benefit of registry operators and at the expense of registrants. We cannot agree with this. Icann does not own the legacy extensions and is a caretaker too - therefore it must act as such. We think that the aim being pursued (and logical conclusion) is to ultimately grant the .com registry (Verisign) similar terms, under the guise of equal treatment. The .com contract is hugely profitable and can accurately be described as a perpetual license to print money, granted by Icann to Verisign. Do they really need another windfall ? Icann once more appears to have been captured by the industry that it is supposed to oversee. Who is Icann accountable to ? Quis custodiet ipsos custodes ? It is not the first time that Icann is found to be acting against the interests of the Internet community. Back in 2012 the US Department of Commerce had to step in to protect the interests of registrants and amend the .com contract between Icann and Verisign. Without government intervention Verisign would have been allowed four price increases of up to seven percent over a six-year term. The DNS needs stability. Domain registrants are entitled to reasonable and predictable prices. It is not clear how protections for existing registrants will remain in place. Domain names are not interchangeable assets but extensions of corporate brands in the online realm. The registrants are captive customers. For that reason price caps are completely justified and necessary. You can't get the same domain name from another registry if you don't like the pricing. There is no competition with monopolies. Nat Cohen pointed out that price uncertainty is a factor that is keeping consumers away from new extensions. We can see the so-called tiered (premium) pricing model in action in new extensions, marred with abusive, downright absurd registration and renewal fees. Is this the model that Icann wants to pursue ? It certainly does not demonstrate "maturation of the domain name market". Quite the opposite, it further demonstrates that we cannot expect domain registries to self-regulate and act responsibly. Recent and not so-recent history should serve as a warning and deterrent. We don't want legacy extensions to be allowed to run in Wild West mode. In recent years domain registration fees have increased markedly in gTLDs, well above inflation rates. Current pricing provisions are already generous - and in fact hard to justify barring exceptional circumstances. At the same time hosting, connectivity costs are decreasing. Accordingly registration costs should /decrease/, rather than increase. Why is the trend always up ? Where is the competition ? Other registries are able to offer the same service at a lower cost. This is especially true for the large registries, that are able to realize economies of scale. In our opinion the proposed changes amount to a breach of trust, and a massive transfer of wealth - registrants get nothing in return We the registrants pay a *TAX* on each domain name, and we therefore contribute to Icann funding. We expect that our interests will be adequately represented. What is happening is the exact opposite. Finally, we believe that it's high time for the FCC to investigate the domain industry. Self-regulation has failed. The multi-stakeholder model does not work like it should.

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[Comments-org-renewal-18mar19] Proposed .org changes
by Nigel Callaghan April 28, 2019

April 28, 2019

I wish to object to the proposed changes to the .org TLD agreement, specifically the proposal to remove caps on prices. A domain name is an important part of an organisations activities. It cannot be changed at the flick of a switch - considerable investment has been made by many organisations in their on-line presence, and changing the domain name would expensive and have a considerable impact on their activities. There is no justification for increasing annual costs for using a domain beyond reasonable and justifiable increases in the actual costs incurred by the registrar. In many areas (supply of electricity, brand of car tyre) consumers have the option to take their business elsewhere. That is unlikely to be easy with a .org domain, as all registrars are likely to take advantage of increasing profit at the expense of the customer. Perhaps a reasonable compromise is to continue to cap increases for existing .org registrations and transfers (i.e. those first registered before date X), and remove the cap for new registrations - that way at least people will know they are likely to be gouged before buying a domain, and can decide on the TLD to use accordingly. Regards Nigel A Callaghan Technoleg Taliesin (.org registered holder)

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

April 28, 2019

I am a .org registrant (non-profit). 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] don't drop the caps!
by Hunter Blanks April 28, 2019

April 28, 2019

Hi, I'm the president and main system administrator for Artifex.org. We operate an absolutely shoe-string non-profit internet service; our gross receipts are less than $200 per year. There's no way we could continue to operate with our current budget if we were beholden to unregulated increases in fees. ICANN's done great work for the internet over many years, but this proposed change does the opposite of supporting what's made the internet great for all these years: it's actually going to make it harder for people to use and to maintain sites on it. HJB

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[Comments-org-renewal-18mar19] Org renewal price caps
by Joshua Krasnow April 28, 2019

April 28, 2019

The .org domain is often and by design used by nonprofit and essentially no-income organizations that run very close to the bone financially. Unrestricted price increases may impair their ability to use this traditional domain. Please reconsider continuing the price controls.

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

April 28, 2019

I am a .org registrant (non-profit). ( centertao.org ) 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? Sincerely, Carl Abbott

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

April 28, 2019

Please DO NOT change the limits on PIR price increases of .org domains. If anything, the amount of increase they charge should go down to the inflation rate of a few percent! Sincerely, Carl Abbott CenterTao <https://www.centertao.org/> When answers aren't enough :)

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

April 28, 2019

I am a .org registrant. 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.

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[Comments-org-renewal-18mar19] comments on removal of price cap
by Paul House April 27, 2019

April 27, 2019

I object strongly to the removal of the price cap.One of the reasons I chose a .org domain name was the certainty of fair renewal charges going forward,I see not valid reason why a "not for profit" organisation would need the price cap removed. The organisation purpose should solely be the administrsation of the domain names and nothing more. As such it should not be looking to increase its charges.

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