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

[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement
by Larry Gritz April 30, 2019

April 30, 2019

I am a .org registrant -- my .org domain is used as the home base of a not-for-profit open source software project. There is literally $0 budget and as the founding author of the project I pay the bill myself. It seems like a terrible idea to lift caps on registration fees for the original TLDs, especially .org which is so heavily used by non-profit groups. Surely this will result in exorbitant fees that these groups cannot afford, if these legacy TLDs go the way of the rest of the for-extreme-profit internet. ICANN should preserve .org as a digital commons that remains guaranteed to be affordable for non-profit organizations, as well as a living example of what the entire internet was like before the land-grab days began. -- Larry Gritz lg(a)openimageio.org

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[Comments-org-renewal-18mar19] Uncapping Price Seems Like A Bad Idea
by John David Pressman April 30, 2019

April 30, 2019

>*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 I must admit I find this provision concerning. TLD operators have a monopoly, and for legacy TLD's especially the demand is high since users are most familiar with them. If applied as precedent to all legacy TLD's, I could easily see it becoming more expensive for individuals to run their own websites. It could even become prohibitively expensive, as these namespaces are in demand and it's not clear to me the "fair price" a monopoly can charge for a .com isn't $100.

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[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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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 30, 2019

April 30, 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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