I am a longtime .org domain name registrant. I believe that 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', and not forced from the top down as this proposal seeks to do. I believe that legacy TLDs 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. Domain switching costs are often prohibitively expensive. These legacy TLDs should be operated at the lowest possible pricing. The registry operators for legacy TLDs did not invent the TLDs nor do they "own" them. The registry management contracts should be put out to bid to reduce the price to registrants; they should not be granted indefinitely into the future to one group with unlimited price increases possible. This recent proposal by ICANN staff is the exact opposite of what should be happening. Prices should be going down, not upwards without restraint. 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 group, the Internet Society, with .org registrants receiving zero benefit in return. ICANN should not permit one group 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, and make moves to reduce the pricing of legacy TLDs by opening up the registry management agreements to competitive bidding. Regards, Steven Kennedy SK Creations, Inc. ᐧ