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

[Comments-org-renewal-18mar19] ICANN must retain some price caps, especially on renewals
by Andrew Allemann April 29, 2019

April 29, 2019

For the reasons stated below, ICANN must reconsider its proposal to remove price caps on .org domain names. Market power at the time of registration It is technically true that there are a lot of choices when it comes to choosing a domain name. If I want to register example.com, I can choose to register a longer .com, opt for a .net or .info domain, a ccTLD or choose from hundreds of new top level domains such as example .xyz. But let’s face it, people usually want .com. It has extraordinary market power. Back in 2008, the U.S. Department of Justice Antitrust Division explained <https://www.icann.org/en/system/files/files/baker-to-dengate-thrush-18dec08…>(pdf) this in a letter to ICANN regarding new top level domain names. It stated: “Our investigation of the proposed .com agreement generated several findings that bear on the likely effect of creating new gTLDs. First, we found that VeriSign possesses significant market power as the operator of the .com registry because many registrants do not perceive .com and other gTLDs (such as .biz and .info) and country code TLDs (“ccTLDS,” such as .uk and .de) to be substitutes… …We also concluded that existing gTLDS would not become a competitive threat to .com registrations because the network effects that make .com registrations so valuable to consumers will be difficult for other TLDs to overcome. Due to a first-mover advantage and high brand awareness, .com registrations account for the overwhelming majority of gTLD registrations… Even with the introduction of hundreds of new top level domains since this letter was written, they have barely chipped away at .com’s market power. Do other TLDs have market power? I’d argue .org does. Charities and non-profits often think of .org first instead of .com. The antitrust department noted: “Finally, our investigation of the .com agreement found evidence that other gTLD registry operators may possess a degree of market power. The market power inherent in other gTLDs is less than the market power in .com, but is still material.” In order of power in the gTLD market, I’d argue that .com is highest and .org is second highest. ccTLDs also have market power in some countries. The presence of market power for initial registrations suggests that prices for some top level domains should be restricted. A non-profit is unlikely to choose .charity over .org unless it is unable to acquire the .org domain. It will usually choose an alternate, longer .org domain before choosing something else. This might not be true in twenty years but it is true in 2019. For top level domains that don’t have market power and are easy substitutes for each other, controlling initial registration prices is not as important. That’s part of the reason people are complaining more about .org price caps than .info. High switching costs and market power at the time of renewal Domain names have immense switching costs. Companies that switch from one domain name to another often spend months planning the move. Some spend years. Some spend hundreds of thousands of dollars. There are two reasons the switching costs are high. First is search engines. Google is the lifeblood of many website’s traffic. Even the best-planned domain name transition can have serious traffic (and thus monetary) impacts. When HomeAdvisor switched its domain from ServiceMagic.com it saw a marked drop in traffic and revenue. On its conference call after switching domains, the company stated <https://domainnamewire.com/2013/05/09/homeadvisor-domain-change/>: HomeAdvisor domestic revenue was negatively impacted by a 20% decrease in accepted service requests due primarily to the domain name change. 20% from a domain name change! It took the company a while to regain the search rankings it had before. Even companies that create and manage websites for a living have to expend significant resources <https://domainnamewire.com/2015/12/04/how-a-creative-agency-switched-from-c…> to change domain names. It can be done but it’s very difficult. The second reason for high switching costs is email. Companies often have thousands of email addresses tied to their domain name. These email addresses are then tied to many online accounts. Switching domain names means updating all the mailboxes technically and all the accounts associated with them. It means emailing all customers and telling them about the new addresses. It undoubtedly means missing some important emails when the switch happens. I have an acquaintance who was offered over $200,000 for a domain name he registered in 1997. He declined because he and his family have email addresses tied to the domain. It would mean changing hundreds of account registrations at websites and countless hours of work. It’s one thing to switch email addresses if the company retains its prior domain name and can forward email to the new one. But if a company has to relinquish an old domain name due to renewal costs, it will miss out on this email forwarding and probably miss important messages. These high switching costs make domain owners hostages to the registries that operate their domains. They simply have to pay whatever they are charged. The cost to switch is too much. For this reason, renewal costs *must* be capped. How domain registration and renewal costs should be managed Some top level domains have market power at the time of registration. All top level domains have tremendous power over registrants at the time of renewal. For this reason, ICANN should consider capping initial registry fees for top level domains that have some level of market power, such as .com and .org. It should limit prices on *all* domains at the time of renewal. The organization has stated that registrants have some protection because they can renew domains for up to ten years at current prices before price hikes take effect. There are two problems with this. First, the registries must notify the registrars of the price increase. It’s up to the registrars to notify customers. Busy customers might overlook these notices or not have the cash to renew for ten years today. Second, and most importantly, this just kicks the can down the road. What does a company do ten years from now when it has to pay the new rates. Regards, Andrew Allemann -- ______________________ www.DNW.com @domainnamewire

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[Comments-org-renewal-18mar19] Comment
by bb120190＠fastmail.fm April 29, 2019

April 29, 2019

Why is it deemed necessary to remove price-increase caps? Are running costs increasing that much from year to year despite no evidence of similar cost increases in other parts of the Internet and IT sectors? Domain rental is expensive enough as it is, and these caps are one of the few things preventing domain registration from potentially turning into a complete free-market free-for-all accessible only to the rich. There are and can be no reasonable grounds for removing these caps. J Gerrard, domain tenant.

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[Comments-org-renewal-18mar19] Comments on .org Registry Agreement
by Tad Delude April 29, 2019

April 29, 2019

Allowing unlimited price increases for domain name registry is insane, even if capped at a maximum of 10% per year. Get Outlook for Android<https://aka.ms/ghei36>

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[Comments-org-renewal-18mar19] Opposed to price-cap removal on .org domains
by Nathan Gibson April 29, 2019

April 29, 2019

Hello, As one of the editors of a non-profit website dedicated to preserving cultural heritage, I am opposed to the change in ICANN regulations removing the price cap on .org domain registrations. This change could seriously limit the ability of websites like ours to provide information at a recognizable domain. Thus, the change could make the mission of non-profits like ours significantly harder to achieve. Thanks for your consideration. Best regards, Nathan Gibson Nathan P. Gibson, Ph.D. <https://www.naher-osten.uni-muenchen.de/personen/wiss_ma/gibson/index.html> Principal Investigator, Communities of Knowledge <https://usaybia.net/>/Wissensgemeinschaften <https://usaybia.net/de/> (usaybia.net <https://usaybia.net/>) Ludwig-Maximilians-Universität München Institut für den Nahen und Mittleren Osten nathan.gibson(a)lmu.de <mailto:nathan.gibson@lmu.de> Associated Projects: Syriaca.org <http://syriaca.org/>, Biblia Arabica <https://biblia-arabica.com/>

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[Comments-org-renewal-18mar19] Ur stupid
by Change ＠ GreenCommunity.org April 29, 2019

April 29, 2019

Scammer association trying to get more moola from us registrants just because the economy is bad u fkn faggits.If u raise renewals u stupid af. They already make enough money every 365 off of doing nothing but saying we still own our domains.

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

April 29, 2019

I am a .org registrant (non-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? Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows 10

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

April 29, 2019

Please drop the proposal. If not, then there should be a balancing counter-proposal that recommends reducing renewal costs. That would be right and proper, if the existing proposal were not struck off. The press has quoted ICANN as saying it is not, or should not, be involved in pricing. Clearly ICANN -is- involved in pricing by virtue of it overseeing a system that has deliberate scarcity. In addition, given that economies of scale do not appear to be passed sufficiently to the end customer, then an investigation into the operation and business behaviour of both ICANN and Public Interest Registry is called for.

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[Comments-org-renewal-18mar19] Business Constituency (BC) comment on Proposed Renewal of Registry Agreement for .ORG
by Steve DelBianco April 29, 2019

April 29, 2019

Attached is the comment of ICANN’s Business Constituency (BC), regarding the Proposed Renewal of Registry Agreements for .INFO and .ORG This comment was drafted by Steve DelBianco, Mark Datysgeld, and Andrew Mack. It was approved in accord with our Charter. -- Steve DelBianco Vice Chair for Policy Coordination ICANN Business Constituency (BC)

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[Comments-org-renewal-18mar19] Proposed .org rule changes
by Chris Gernand April 29, 2019

April 29, 2019

First, I am grateful that after having difficulty submitting my comments, I received a prompt and quickly accessible link for submission from ICAAN. However, as clearly a non-tech user of electronic communications, I wish to express my concern for the proposed rule change allowing removal of price cap provisions for registration of ".org" domain names. While there are many non-profit organizations with large budgets whose operations will not be seriously hampered by a financial hit to keep their electronic communications operating smoothly, there are countless small non-profit organizations operating on shoe-string budgets. Organizations like Lux Cantorum Chicago struggle with increasing costs to meet regulatory requirements to maintain or enhance their non-profit status. The prospect of facing serious cost increases to keep our legitimacy seems unnecessary and counter intuitive to the purposes of non-profit status. I strongly advocate to maintain current restrictions on the renewal price cap for domain name registrations using the legacy ".org" designation. -- Christopher J. Gernand, Board President, Lux Cantorum Chicago

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[Comments-org-renewal-18mar19] Renewal of .org Registry Agreement
by Yehuda Deutsch April 29, 2019

April 29, 2019

Hi, I am a SysAdmin and DevOps engineer for several non-profit organizations who are registrants of .org domains, and I am myself a registrant of some .org domains for community not-for-profit projects. I think that removing the cap on .org domain prices is a bad idea. Yes, I am aware that domain-squatters are a large benefactor of keeping the cap, but so are the organizations I support. Please reconsider this while considering the intended target users of this TLD who are those that don't always have free funds for price increases. Thanks, Yehuda ------------------------------ *Yehuda Deutsch | IT Developer*

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