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

[Comments-org-renewal-18mar19] CHUT SHEL CHESSED'S PUBLIC COMMENT SUBMITTED BY RABBI SHALOM ARUSH ON PROPOSED RENEWAL OF .ORG REGISTRY AGREEMENT
by RUBIN INTERNATIONAL LAW FIRM AND NOTARY April 29, 2019

April 29, 2019

Hi, Please find enclosed the Public Comment regarding the Proposed Renewal of .org Registry Agreement, of the Chut Shel Chessed Institutions submitted by Rabbi Shalom Arush, Head of the Institutions. Regards Jean-Philippe Naftali Rubin, International lawyer since 1992 LLM BA MA Licensed in Israel and in Europe Member of the forums of international law and cyber law of the Hebrew University of Jerusalem Rubin International Law Firm & Notary Avinoam Yelin 11 St., POB 5552 Jerusalem, Israel Tel: +972-(0)2-6422295 - Fax: +972-(0)2-6311227 Cellular: +972-(0)544-705-200 Website: <http://www.advrubin.com/> www.advrubin.com Email: <mailto:naftali.rubin@gmail.com> naftali.rubin(a)gmail.com info(a)advrubin.com <mailto:info@advrubin.com>

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[Comments-org-renewal-18mar19] Comments on. Org
by Dazza April 29, 2019

April 29, 2019

Allowing uncapping of charges will kill the smaller NGOs, not to mention lead to all other domains going up and up to the point where we users are essentially blackmailed into paying what we are told to pay for something we have built our brands on. Not to mention it will likely discourage the registrars to allow the mobility of domains between registrars. Please don't do it.

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

April 29, 2019

I believe that the abrupt removal of price caps on the .org registry after several decades of fairly steady prices would be bad for the registry and those who register their domains there. .org registrants genrally are not for-profit entities, but tend to be non-profits and individuals who may not have a large budget for such things. I know that while computer and communications capacity tend to fall in price over time, there are other costs incurred by registries and I can see the need for increased prices over time. I recommend that price increases be made part of the renewal agreement and that they should not, in general, exeed the rate of inflation in developed contries. Thank you for your time, Mark Gajda

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

April 29, 2019

I am a .org registrant (not-for-profit). 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] .org RA Renewal
by Alan Greenberg April 29, 2019

April 29, 2019

This comment regarding .ORG price caps is submitted solely on my own behalf. In my mind, there are two salient issues: 1. ICANN's determination to have uniform Registry Agreements: this is reasonable from a purely administrative point of view. I will point out that this desire/requirement is an administrative and contract issue and has never, been subject to a community decision. The .NET agreement that just came into in 2017 did NOT follow this pattern of alignment with the new "standard" RA, which demonstrates that there are other viable options that ICANN sanctions. 2. .ORG is targeted (if not limited) to organizations that generally are in the public interest. There are somewhat over 10 million .ORG domains and it is reasonable to presume that many million of them are public-service type organizations that have registered under .ORG based on its perceived focus area but may well have presumed that the price they paid to start would not increase radically. PIR has regularly raised prices in the past. Although they have not raised prices recently, they now have a new CEO and a new Chair of the Board. Given that, past behaviour is NOT necessarily a predictor of future actions. ICANN should take the prudent and public-interest path and preserve caps on allowed price increases. Alan

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

April 29, 2019

I am a domain name registrant that supports non-for-profits. 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. The opposite should become the standard that after a new gTLD has become well established (such 10+ years in operation) that it starts to be restrained from wild price increases well beyond inflation. This is a key thing required to help those new gTLDs to become acceptable as a primary domain for an organization. My recommendation on the new gTLDs is to not use them as a primary identifier (what a domain name essentially is after all) until we can be sure we don't have any issues of volatility of that name space, including pricing. ICANN appears to be entirely catering to registries by removing price caps. ICANN should stand up for the public interest and registrants! -- Andy Konecny Consulting Inc.

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

April 29, 2019

As a registrant of a .org and .info domain, I find it appalling that ICANN is attempting to remove price caps and allow a private organization to reap profits from a system that our tax dollars funded. It seems that ICANN has lost their way and no longer recognizes the differences between gTLDs that were fully funded by a private organization and the legacy extensions created in partnership with the United States government. ICANN was not a part of this process and should not try to retroactively apply their desire to line the pockets of private enterprise with their "modern" ideals of domain ownership. It is absolutely unacceptable for ICANN to ignore the differences between these domain names and try to pull a fast one on the people. Removing capped pricing and price increases is going to lead to yet another system being taken advantage of by a corporation who has no right to be doing so. Increased prices only benefit the bulk buyers and resellers that sit on domain names for years that somehow don't have to pay the same fees as the rest of us. Interesting, ain't it? Why doesn't ICANN spend their time sticking their nose into those matters? Signed, Yet Another Disgruntled Gentleman

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Enock Kiprono 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? Thanks, Enock Kiprono, Infoken Team Leader

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[Comments-org-renewal-18mar19] comments org renewal
by Gretta Hansen April 29, 2019

April 29, 2019

Please do not remove price increase limitations on .org. We are funded by grants and it would add another concern. Gretta Hansen Administrative Assistant The Mentoring Network www.MentoringNetworkID.org One hour a week changes lives The information transmitted (including attachments) is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521, is intended only for the person(s) to which it is addressed. This electronic message transmission contains information that may be confidential or privileged. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient(s) is prohibited. If you received this electronic transmission in error, please notify the sender and delete the copy you received.

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[Comments-org-renewal-18mar19] .org is different, and it should be operated that way
by Jonathan Romano April 29, 2019

April 29, 2019

I am a contributor to an academic project which is hosted under a .org domain. Legacy TLDs such as .org are fundamentally different in both how they were created and how they are utilized, and should be operated accordingly. They were created with US government support, and represent a standard meaning - in the case of .org, organizations, specifically charitable and other public benefit organizations. They have a distinct meaning to the public at large, beyond just aesthetic. Additionally, many .org registrants in particular operate on limited budgets, and unbound price increases would affect their ability to serve their organization's purposes, and switching TLDs is not only undesirable but would actively handicap their abilities. I find the potential implications of these changes greatly concerning. Sincerely, Jonathan Romano

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