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

[Comments-org-renewal-18mar19] Comments of Leap of Faith Financial Services Inc. opposing proposed .org, .info, .biz and .asia contract renewals
by George Kirikos May 3, 2019

May 3, 2019

Submitted by: George Kirikos Company: Leap of Faith Financial Services Inc. Website: http://www.leap.com/ Date: April 29, 2019 We write to oppose the proposed contract renewals posted by ICANN for the .org, .info, .biz and .asia contracts, as posted for public comments at: https://www.icann.org/public-comments/org-renewal-2019-03-18-en https://www.icann.org/public-comments/info-renewal-2019-03-18-en https://www.icann.org/public-comments/biz-renewal-2019-04-03-en https://www.icann.org/public-comments/asia-renewal-2019-03-27-en While our arguments are focused on the .org TLD, to the extent that the contractual terms are similar for the other TLDs, we repeat the same comments for .info, .biz and .org. Indeed, while the majority of the thousands of public comments to date have focused on .org, ICANN should read those comments as also applying to .info, .biz and .org, even if the submitters did not explicitly submit their comments to all 4 email addresses. 1. We support and endorse the great groundswell of opposition as expressed in the thousands of thoughtful public comments opposed to these proposed agreements. It is shocking that ICANN did not learn its lesson from 2006, when similar massive opposition existed for comparable contracts which would have allowed for unlimited fee increases: https://forum.icann.org/lists/org-tld-agreement/ The proposed contracts are simply unconscionable, and ICANN should instead simply extend the existing contracts by another 6 or 10 years, rather than make any other changes. 2. Within the At-Large, we had a video discussion/debate, archived at: https://freespeech.com/2019/04/10/impact-of-the-urs-and-unlimited-fee-incre… https://youtu.be/KW3I1oFGbv0 where many of the points below are discussed, and I include them here by reference. 3. We particularly agree with the comments and/or blogs submitted/posted by: a) Nat Cohen / Telepathy: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003067.h… http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminat… b) NameCheap: https://www.namecheap.com/blog/keep-domain-prices-in-check/ c) Zak Muscovitch / Internet Commerce Association: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/000006.h… d) Jay Chapman / Digimedia: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/002967.h… e) Andrew Allemann: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003091.h… 4. It should be noted that in the past ICANN trumpeted lower fees as one of its main achievements. For example, the testimony of ICANN General Counsel and Secretary John Jeffrey at: https://www.govinfo.gov/content/pkg/CHRG-109hhrg30233/html/CHRG-109hhrg3023… "STATEMENT OF JOHN JEFFREY, INTERNET CORPORATION FOR ASSIGNED NAMES AND NUMBERS (ICANN) ... Among ICANN's main achievements are the following: ... Market competition. Market competition for generic top-level domain registrations established by ICANN has ****lowered domain name cost in some instances as much as 80 percent with savings for both consumers and businesses.****" (emphasis added) It is not consistent with those past statements for ICANN to abrogate its responsibilities, and permit unlimited fee increases by registry operators. Unlimited fee increases are not in the public interest, and do not even attempt to balance the needs of registrants against those of registry operators. ICANN was handed a responsibility to balance the interest of affected stakeholders when it achieved (against our wishes) independence from US government oversight, and it's now clear that it is not living up to those commitments given such one-sided contracts that have been presented here for public comment. Unlimited fee increases are not balanced, and do not promote stability of the internet or competition. ICANN is engaging in corporate welfare and/or crony capitalism through such anti-competitive proposals as are here before us. 5. As has been pointed out by others, under competition the cost of providing registry services (really just the management of a central database plus the operation of various nameservers) would be under USD $1.00 per domain name per year. This is evidenced by the .IN (India) tender, where Neustar beat Afilias with a winning bid of USD $0.70 per domain name per year (70 cents/domain/yr): http://domainincite.com/23364-afilias-sues-india-to-block-12-million-neusta… A similar competitive tender process happened in France: https://www.thedomains.com/2012/08/07/afnic-awarded-new-contract-to-run-fr-… where AFNIC had to lower the wholesale fees for .FR domain names, and the contract was for 5 years. Similar competitions are held for the .US ccTLD: https://www.ntia.doc.gov/legacy/ntiahome/press/2007/Neustar_101907.html You'll note that registry operators do not have presumptive renewal in those ccTLD contracts, yet are more than willing and able to compete effectively and make investments. It was a major policy blunder of ICANN to have agreed in the past to presumptive renewal, a decision that has had a multi-billion dollar negative impact upon registrants, compared to a situation where there are regular competitive tenders. Even the US government has argued for those competitive tenders for both initial agreements and for renewals of agreements: https://www.ntia.doc.gov/files/ntia/publications/icann_081218.pdf (Ms. Garza's analysis begins on the 3rd page of the PDF, after the covering letter by Ms. Baker of the NTIA) The absence of such competitive tenders can only be rectified through the protective fee caps which have been long established, and which the registry operators themselves have agreed to since the times they entered into their respective agreements. If current registry operators are not prepared to renew the existing contracts (which have fee caps in place), then there would be no shortage of other prospective registry operators who would be prepared to step in and replace them (and at a much lower cost, with fee caps in place). Indeed, ICANN themselves have argued (in court) that such caps are *pro-competitive*, see: https://www.icann.org/en/system/files/files/icann-reply-on-cfit-26may06-en.… "....in a single supplier market, price caps are, if anything, procompetitive (Mot. at 13-14);" (line 13, page 6 of 15) 6. We would like to openly make ICANN the following offer: We will run the .org registry for USD $5 per domain name per year, and keep all other existing terms the same. [We would then simply subcontract it to one of the many registry operators who would bid for the job at USD $1 per domain per year or less, and pocket the difference!] This is lower than the $9.93 per domain name per year that PIR currently charges. ICANN cannot of course accept this improved deal, even if it wanted to, because its hands are tied by the foolish decision to agree to presumptive renewal in the past. Looking forward, an agreement to permit unlimited fee increases in the future (far beyond the already generous 10% per year permitted increases) would similarly hamper ICANN's ability to negotiate future "win-win" deals, giving it no negotiating leverage in the future, as it would have already given away the farm if it entered into this proposed agreement. Agreeing to permit unlimited fee increases is like letting the genie out of the bottle, as there's no way that registry operators will ever agree to voluntarily undo such a change in the future. Presumptive renewal means that registry operators can safely ignore any future attempts by ICANN to renegotiate. This is why these contractual changes are so important, because they'll be impossible to fix in the future (without giving up even more to registry operators, e.g. via a buyout or something). This alone should be reason for caution. Given there's no urgency to making a change (i.e. registry operators have *falling* costs, not increasing costs), then the status quo should prevail. 6. Some have suggested that the Internet Society and/or PIR would never raise fees by a large amount. However, "hope is not a strategy." Past performance is no guarantee of the future. Leadership can change, as can priorities/missions. It's clear from section 7.5 of the the draft contract itself: https://www.icann.org/sites/default/files/tlds/org/org-proposed-renewal-18m… that ISOC/PIR could simply sell or assign the registry contract to another entity (e.g. Private Equity, just as registry operator Donuts was sold by its founders), and that new owner/entity could take the heat for future egregious fee increases. ICANN would not be able to stop such a deal. Such a sale would allow ISOC to create a huge endowment for itself worth billions of dollars, given that .org is arguably the second most desirable gTLD, after only .com. 7. The ability to renew a domain name for 10 years is not sufficient protection for registrants. Eventually the bill will come due, and nothing can offset the enormous switching costs. Any goodwill/links/etc. built up will be reduced to zero, totally destroying one's investment in one's web identity that may have been built up over 20+ years (even longer than ICANN has existed, in many cases). URLs that have been printed in offline media such as books, DVDs, etc. can't be updated, thus it's impossible for many to simply stop renewing after 10 years and switch, as some people will still see the old URL. E-mails aren't forwarded by the new registrants to those of past registrants, meaning that all existing email addresses can't easily transition to a new domain name without risk. Business cards would need to be reprinted (and can't be "recalled" from past recipients). Registrants expect URLs to be permanent, not transitory. Registrants of legacy gTLDs like com/net/org own their domain names, and are not temporary tenants (like those in the failed new gTLDs). 8. One of the reasons prospective registrants rationally avoid new gTLDs is the lack of certainty over potential future fee increases. As one submission pointed out, they are "leery" of such one-sided contracts, and for good reason. Those failures of the new gTLDs experiment should not be allowed to contaminate the successful and proven legacy gTLDs like .com/net/org. Indeed, if there is to be any harmonization of contracts, the "base agreement" should be that of the successful .com/net/org TLDs which included fee caps, rather than have the future be modeled on the the failed new gTLDs program. Registrants of new gTLDs knew the problems with the lack of price caps, and foolishly agreed to them before registration. Changing the rules for existing registrants of legacy gTLDs is unacceptable, as this amounts to changing the rules in the middle of the game, rules which would never have been acceptable to most prior to registration. One submission suggested that as each new gTLD matures, or reaches a critical mass, it should then transition to the legacy contracts. That was a wise suggestion, to bridge the failed new gTLD program with the successful legacy gTLDs. 9. Even ISOC/PIR doesn't enter into such one-sided agreements, given that its own supplier/subcontractor (Afilias) had to win a competitive tender to retain the contract for managing the back-end of the registry (presumably at an even lower fee than it agreed to years ago -- fees would be able to be estimated once the relevant IRS Form 990 forms become public). https://domainnamewire.com/2016/02/16/32-million-org-contract-up-for-bids/ https://domainnamewire.com/2016/11/14/org-sticks-afilias-backend/ It's entirely inconsistent that Internet Society doesn't give presumptive renewal and/or permits unlimited fee increases for its own suppliers, yet wants such things for themselves. 10. We oppose the ability for the registry operators to unilaterally create and impose their own mandatory RPMs upon registrants. See, for example: https://www.icann.org/sites/default/files/tlds/org/org-proposed-addendum-18… "Specification 7, § 1 The terms of Section 1 of Specification 7 are hereby amended and restated in their entirety as follows: “Rights Protection Mechanisms. Registry Operator shall implement and adhere to the rights protection mechanisms (“RPMs”) specified in this Specification. In addition to such RPMs, Registry Operator ******may develop and implement RPMs that discourage or prevent registration of domain names that violate or abuse another party’s legal rights.****** Registry Operator will include all RPMs required by this Specification 7 and any additional RPMs developed and implemented by Registry Operator in the Registry-Registrar Agreement entered into by ICANN-accredited registrars authorized to register names in the TLD.” (page 6, emphasis added) This should be left to the GNSO, to develop only policies that have consensus, and which balance the needs of both rights holders and registrants. For example, suppose PIR (or another registry operator) was allowed to unilaterally create a RPM on their own which allowed for complaints to be filed for a fee of $100, but which required registrants post a $1 million bond if they wish to file any response to the complaint. Such a one-sided policy could be created by a registry operator under the proposed terms, and would ignore the requirement that ICANN policies need to balance the concerns of all affected stakeholders (including registrants). 11. We also oppose the searchable WHOIS, which ignores the ongoing EPDP on WHOIS: https://www.icann.org/sites/default/files/tlds/org/org-proposed-renewal-18m… (page 37) "Notwithstanding anything else in this Agreement, Registry Operator must offer a searchable Whois service compliant with the requirements described in Section 1.10 of Specification 4 of this Agreement." as it doesn't properly balance the privacy rights of registrants against those who would go on fishing expeditions. A searchable WHOIS system should only ever be adopted, if and only if the Trademark Clearinghouse (TMCH) equally becomes public and searchable, in return. If the TMCH is kept secret and non-searchable, then the WHOIS should not be searchable either. 12. Additional RPMs that were developed for new gTLDs were the result of bad predictions that were made of massive cybersquatting prior to the adoption of the program. For example, in testimony before the US government: https://www.govinfo.gov/content/pkg/CHRG-112shrg74251/html/CHRG-112shrg7425… "First, the immediate costs imposed on business is likely to be in the multi billions of dollars." "This Program in aggregate has multi-billion dollar implications for all marketers, both in the commercial and the nonprofit sectors, and their brands. It would cause irreparable harm and damage to the entire online business community. It would throw the domain name universe into substantial confusion for both marketers and consumers." "So there are billions of dollars that are going to be spent and it's not going to be providing a use for the economy." "And when we're talking about billions of dollars here, when we're talking about companies with 3,000 or more brands, even big companies will be facing really large expenses. So this is a very, very significant economic issue for this country and for the world." "An unlimited expansion of the TLDs will cost the business community billions of dollars." "The unlimited expansion of TLDs would dramatically increase the cost and complexity for trademark holders to protect their rights. The immediate cost imposed on businesses is likely to be in the billions of dollars." "We believe ICANN's gTLD program would impose billions of dollars in unnecessary costs on the restaurant industry at a time when restaurant operators are looking forward to investing in their businesses and hiring employees after the worst recession in decades." These predictions exaggerated and overestimated the actual risk that was realized by the launch of new gTLDs. Thus, the justification for the adoption of the URS and other RPMs turned out to be false predictions, and should now be undone. They were never intended for, nor should be imposed upon, registrants of legacy gTLDs. Prospective registry operators at the time were willing to accept such terms, as the trademark lobby threatened to thwart and delay the release of new gTLDs unless their demands were met. Registry operators were blinded by dollar signs in their eyes, for example, predictions by Name.Space: "Name.Space, whose business has a potential value of over 1 billion dollars, has been deprived the opportunity to fully launch and operate its portfolio of gTLD properties under what we believe is the most responsible, fair, and ethical practices yet to be employed in the commercial domain name industry." (same link as above for testimony) 13. Given that the RPM PDP of the GNSO is actively reviewing the URS, including determining whether or not it should be a consensus policy, no steps should be taken by ICANN staff and/or the registry operators to unilaterally impose it upon registrants. Indeed, there are numerous proposals to actively change the URS (including a proposal to explicitly eliminate it), see: https://community.icann.org/display/RARPMRIAGPWG/URS+Proposals (click the "Individual URS Proposal" tab to see the 33 individual proposals, 14 of them from us) The current URS is deeply flawed. For example of just one of the defects, currently complaints are required to be in English (unlike the language rules for the UDRP, where complaints must be in the language of the registration agreement, which varies by registrar). Thus, many registrants defending a URS dispute have no idea what the actual URS complaint is about, if they do not understand English. This is particularly egregious, given that new gTLDs are most popular in China. Such flawed RPMs whose creation was rushed before the launch of new gTLDs, and which are tilted in favour of large multinational companies, need to be reviewed and corrected before they are ever adopted for legacy gTLDs like .com/net/org. 14. In conclusion, ICANN's proposed contracts represent a failure of the multi-stakeholder model, and are instead evidence that ICANN has been captured by registry operators. ICANN claims these contracts are the result of a negotiation, yet what did registrants receive in return for these contractual changes? We received absolutely nothing in return, except for higher fees and higher regulatory burdens (via the imposition of the URS), with all the gains being received by the registry operators at the expense of registrants. That's not a negotiation -- that's a giveaway. We expect and demand that ICANN and the registry will simply extend the current contracts, rather than enter into these one-sided arrangements. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/

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[Comments-org-renewal-18mar19] .ORG Price Cap Removal Comment
by Jason Michael May 3, 2019

May 3, 2019

I wasn’t going to submit a personal comment because I feel like this comment process is simply adding insult to injury, but since I have little to nothing to lose now, I'll bite. I do have to wonder what criteria ICANN will use while examining the comments, to determine whether or not there are sufficient "nays" in the comments to overturn their decision, or if this is just an elaborate dog and pony show. A number of questions and thoughts come to mind regarding ICANN's proposed .org (and .info and .biz) tld renewal cap removal. 1. ICANN's justifications for this price cap release are indeed spurious, if not ludicrous. The following is one of ICANN's statements: "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." OK. Aside from the fact that many of us protested these new TLDs to begin with, as they could easily be considered a giant cash cow, there are a number of other problems with this statement. New TLD registry operators knew that they were signing up for this system. They knew that they were going to have to be paying large annual fees to operate them. And they knew they were going to be competing against .coms, .orgs, .infos and .bizs. When I purchased domains and spent a significant amount of money developing them over the last several years, I had no idea whatsoever that in March of 2019 ICANN would flip a switch and destroy thousands of dollars in inherent value in my business overnight. Where is my equitable treatment? Many businesses, including mine, have taken a substantial hit simply with this proposal alone! Who in their right mind would now purchase a .org or .info right now that was purchased for $1000 a year ago? All of this amounts to a massive transfer of wealth from domain owners and website developers into massive registries. The only way now to even hope to amend this is by guaranteeing protection of .orgs and all legacy tlds for many, many years. 2. Another justification I have seen is that ICANN is not responsible or in the business of price fixing. This is just silly. ICANN got into the business of price fixing when it assumed management of the legacy TLDs! Let us look at an example. A large Corporation X buys a smaller Corporation Y for its media and content. Corporation Y has in its portfolio movies, news and sports. In a few years, Corporation X finds that the news segment isn't profitable or as profitable as Corporation X would like. Corporation X lays off the entire news staff and destroys the news piece of their acquisition altogether. They issue a statement along with their actions stating "We are not in the news business". In actuality, Corporation X got into the news business when they acquired Corporation Y. Saying they are not in the news business, while destroying the lives of everyone in the news department, is insulting and hurtful when they knew at the onset of their acquisition that news was part of the deal. 3. How is the registry (PIR in the case of .org) actually going to find fair market value for renewal fees on domains that are currently occupied? For example, say that I bought a .org at a certain price several years ago - one that wasn't being bid on but set high enough that nobody wanted it. I bought it at that price with the assumption that I would be paying renewal fees within a certain range. Now let's say that I have put a website on that domain that offers significant value to the public, and PIR comes along and says "I think the renewal for that domain should be - ah - $300 a year". I will have to shut down my site, and the domain will then be auctioned or released to the public for sale. In this example, let us say that nobody wanted it at $500 except for me, and nobody in their right mind is going to touch it now at $300 a year. The registry, after a year of not selling it, lowers the renewal rate to $200 a year - a bargain! Nobody wants it still. Finally, after several years of trying to get top dollar for it, the registry finally gets it down to $60 a year where a squatter is willing to grab it up. Let's examine the effects of this. You have essentially evicted a property owner off of their property that they believed they owned and could build a lasting and useful site on. You have destroyed end users' ability to access quality information and reduced their access to a higher quantity of information. You have destroyed the integrity of that domain for years - if not forever - once it gets replaced by ads. How does this in any way meet your specified goals of price stability and benefiting the end user? 4. While this price cap removal is egregious, the real fruit is seemingly in .coms. Let's imagine what the renewal fees on the .coms will be in a few years after this proposal has been snuck in on the .orgs, .infos and .bizs. Why, some of the .coms could easily go for thousands of dollars each! Never mind that the above (#3) will happen on a massive scale and alter the internet in mind-boggling ways. In fact, a huge number of small businesses STILL don't have websites because of associated costs! What is it going to look like in 5 to 10 years?? I am a website developer and not a domain squatter unless I need those domains for the site development. I try to build quality sites for the end user - the public. Though it may be difficult to quantify, it is my belief that this proposal has inflicted damage on the value of my and many other developers' businesses. I am attempting to contact as many members of Congress as possible on this issue and would recommend that others that see this message do the same, if by any chance my comments make it to the public forum. Jason C, Arkansas

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[Comments-org-renewal-18mar19] Don't remove price caps
by Mike Thomas May 3, 2019

May 3, 2019

I disagree with the proposed direction of removing price increase caps on .biz, .org, and .info domain registrations. Without price caps, it is likely that the costs associated with owning such domains will significantly rise. I'm the owner of several small online community websites that earn limited income. When they started over 15 years ago, they earned nothing. My experiences creating and operating these websites led me to meet and make friends from around the world, fostered my interest in computer science and software engineering, and in no small part led to my current professional employment at a major U.S. technology company. Without a cheap price on domain names, my websites would have never gotten started and I would not have had the rich experiences that followed. These days, I can absorb additional increases in the cost of domain name ownership, at least to an extent. But today's younger version of me cannot. Please reconsider. Mike Thomas

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[Comments-org-renewal-18mar19] No thanks
by Thomas Paine May 3, 2019

May 3, 2019

Please don’t do this, I can’t imagine it being of benefit to any .org owners

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[Comments-org-renewal-18mar19] do not expire price controls on .org domains
by Jake Watters May 3, 2019

May 3, 2019

it is important that ICANN continue to regulate prices on domain name registrations as it has done. If ICANN ceases to perform this vital function in the interest of profiteering from DNS services, ICANN will have to be replaced by new technology and that will be very disruptive to commerce, as well as to the viability of ICANN. Please write back and confirm that ICANN will not abandon the important duty of regulating registration fees in the public interest. thank you -jake

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Britton McNelis May 2, 2019

May 2, 2019

I am a .org registrant (not-for-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! Sent from my iPhone

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[Comments-org-renewal-18mar19] Pending Ratification: ALAC Statement on Registry Agreement Renewals .org, .biz and .info
by ICANN At-Large Staff May 2, 2019

May 2, 2019

Dear All, Please find attached the ALAC Statement on Registry Agreement Renewals .org, .biz and .info<https://community.icann.org/x/-oSGBg>. The statement is accordingly being submitted to the .org, .biz and .info public comment emails. On 28 April 2019, a formal request for extension to submit the statement was approved by staff, as two of the three Registry Agreement public comments were to close on 29 April, before the CPWG would finalize the statement on its weekly call<https://community.icann.org/x/WIOGBg> (today at 20:00 UTC). The At-Large workspace related to this comment may be viewed here<https://community.icann.org/x/-oSGBg>. In the interest of time, the ALAC Chair requested that the statement be transmitted to the ICANN public comment process with a note that the statement is pending ALAC ratification. Kind Regards, ICANN Policy Staff in support of the At-Large Community Website: atlarge.icann.org<https://atlarge.icann.org/> Facebook: facebook.com/icann<https://www.facebook.com/icannatlarge>atlarge<https://www.facebook.com/icannatlarge> Twitter: @<https://twitter.com/ICANNAtLarge>ICANNAtLarge<https://twitter.com/ICANNAtLarge>

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[Comments-org-renewal-18mar19] Comment on Proposed Renewal of .org Registry Agreement
by Adrian Laurenzi May 2, 2019

May 2, 2019

Hi, I am a .org domain owner and I also work with nonprofits that almost always use .org domains. I want to express my strong opposition to any price increases by PIR that would raise the cost of .org domains. They are already relatively high which is a burden on nonprofits that have limited budgets. Thank you, -- *Adrian Laurenzi * Turn Off The App - *Go Outside* (TOTA-*GO*) turnofftheapp.com || c: 520-971-3241 || adrian(a)totago.co || ᐧ

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[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Daniel Preussker May 2, 2019

May 2, 2019

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[Comments-org-renewal-18mar19] .ORG TLD Price increase
by Mike Wronski May 2, 2019

May 2, 2019

.ORG has been a place for non-commercial entities and other not-for-profit organizations for over 30 years. The prices for many TLDs continue to increase at large rates. This TLD should remain accessible and affordable. Sharp and uncapped price increases will force groups that may already be tight on budgets to spend funds on new domains, transfers, communication of new email addresses etc that could have been used for far more productive operations. Please reconsider plans to allow these uncapped price increases. Operation of the TLD should not be a loss for the registrar but for TLD's chartered like this, they should also not be a massive cash grab.. Something to consider would be a better review of .ORG holders to remove those that may be a better fit for the more commercial domains. Thank You. -Mike Wronski

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