This is a sad day for the DNS industry. ICANN is not giving any consideration to end consumers (registrants.) This is yet another example of how the ICANN multi-stakeholder model does not work. ICANN chooses time and time again to ONLY act in the very narrow interest of contracted registries, including Pubic Interest Registry (PIR), Verisign and others. What is being proposed here is to give PIR the unrestricted ability to increase prices on its base of 10+ million registrants by any amount, with no restrictions whatsoever. PIR will be able to do this without any type of justification. PIR can wake up one morning and decide to arbitrary increase prices by 30%, 300% or even 3000% and this price hike will be fully permitted under the ICANN new proposed .ORG Registry Agreement between ICANN and PIR. So you have a situation where any price increases will be forced upon by 10+ million end-user registrants -- and nobody will be able intervene and make sure consumers are protected. End-users will have no choice - but to pay the higher, unjustified fees. This is extremely BAD for consumers. This is BAD for the millions of organizations that use a .org domain name. These organizations will have no choice but to pay higher fees and be entirely at mercy to PIR. It is virtually impossible to switch away from a .org domain name and use an alternative extension, simply because of enormous switching costs. Imagine if RedCross.org did not want to pay the higher renewal costs. PIR (the organization ICANN is considering granting unrestricted pricing ability to) will argue that they can switch their Internet web address to use a different domain extension other than .org. However, this is not realistic or possible. Can you imagine how much time and effort it would take to move away from .org to a new domain name? think about all of the branding and marketing RedCross.org has done over the years. Think about all of the 30,000 employees using a RedCross.org email address. They can not give up or abandon their domain name because of all of that lost email and lost contacts with donors, channel partners, vendors, other organizations, etc. Imagine your company abandoning your email address tomorrow. How will all of your existing contacts reach out to contact you? This is why it is impossible for any large organization to switch away from their existing .org domain name. Not to mention re-coding the website, back end technical infrastructure, DNS routing, building up new search engine rankings, PR, marketing, branding and all of the goodwill that RedCross.org has invested into its domain name. The switching cost are extraordinary. This new proposed .ORG Registry Agreement directly harms all non-profit originations who use a .org domain name -- as they will have no choice but be forced to pay higher, unjustified rates. Ironically, the old .ORG registry agreement allows PIR to increase prices by 10% per year. Why remove this restriction? This clause is in place to ultimately protect consumers/registrants. Now you want to remove pricing caps? ICANN is giving absolutely no regard for the public at large and the 10+ million end consumer registrants. It is foolish for ICANN to propose this new .ORG Registry Agreement without considering consumers. Shame on ICANN for acting in the narrow interest of one single entity (PIR) and not even thinking twice about the 10+ million registrants throughout the world. ICANN - We understand your allegiance is to the contracted parties - but why and how did we get to this place? ICANN used to have the public interest litmus test - making sure that every decision ICANN makes was in the public's best interest. Becky Burr said it was very important to include consumers and the public in the multi-stakeholder process. But this is obviously not the case anymore. ICANN has an obligation to act in the public interest and to protect consumers and the public at large. But for whatever reason, ICANN is handing PIR the keys to the treasure chest (which has lots of gold within to milk from end consumers who will be forced to pay higher prices.) There is absolutely no reason for granting one company the unrestricted ability to increase prices. Without any cost justification. Or without a valid and legitimate reason for increasing prices on an extremely captive audience -- who has no choice but to use .org domain names. PIR will not have to provide any rationale for increases in prices. They will not need to show or demonstrate increase in costs. PIR will simply be able to announce a price hike and apply it on their base of 10+ million registrants. Any price hike will be passed along to the end users and ICANN is causing direct and concrete harm to an extremely captive audience. Antitrust experts paying attention? These price hikes will benefit nobody other than PIR, the contracted registry for .org domain names. Keep in mind that the .org Registry Agreement will become the second most lucrative ICANN contract (in terms of dollar amounts) behind the .com Registry Contract. The amount of money at stake is enormous. Why would ICANN want to do this? Let me offer up an explanation. PIR has successfully infiltrated the ICANN multi-stakeholder process over the years. Even today, there remains significant conflicts of interest. Examples: ***Avri Doria -- current ICANN board member. Avri is a sustaining member of the Internet Society and currently holds the position of Steering Committee Chair for North America. The Internet Society is the SAME organization that created PIR in 2002 -- a not-for-profit corporation to manage, enhance and expand the .org domain. According to the Internet Society's website, "The Internet Society is responsible for appointing the PIR Board of Directors." Both the Internet Society and PIR are essentially one in the same. ***Suzanne Woolf -- currently serves as a liaison to the ICANN Board of Directors. She is a member of the ICANN Root Server System Advisory Committee and ARIN Advisory Council and actively participates in NANOG and IETF. In the past, Ms. Woolf has excused herself from being involved in the gTLD program due to her conflict of interest. Suzanne is currently on PIR board of directors. ***Maarteen Botterman -- currently serving on the ICANN board of Directors. Chairman of the Public Interest Registry from 2008 through 2016. ***Matthew Shears -- currently serving on the ICANN board of Directors. Matthew was the Internet Society's first Public Policy Director. ***Roberto Gaetano -- served six years on the ICANN Board, with three as Liaison of the At-Large Advisory Committee (ALAC). Currently on PIR board of directors. ***Ram Mohan -- past ICANN Board member. Also, co-founder of PIR and CTO of Afilias (registry operator for .org) ***Rinalia Abdul Rahim -- past ICANN board member (2014 -- 2017.) She was just named the Senior Vice President of strategy and implementation to The Internet Society on December 2018. Timing is quite coincidental! ***Paul Diaz -- served as the chair of ICANN's Registries Stakeholder Group from 2015--2018. Currently vice president of Policy for PIR. ***Lise Fuhr -- chaired the ICANN Cross Community Working Group for the IANA Stewardship Transition. She also serves on the Internet Society Public Interest Registry Board of Directors & Currently on PIR board of directors. ***Jeffrey Bedser -- member of the ICANN Security and Stability Advisory Council since 2007. Currently on PIR board of directors. ***Narelle Clark -- member of the IANA Stewardship Transition Coordination Group. Currently on PIR board of directors. ***Jay Daley -- member of the ICANN Security and Stability Advisory Committee and the ICANN Customer Standing Committee. Currently on PIR board of directors. ***Andrew Sullivan -- deeply involved in the ICANN and IANA stewardship transition and principal contributor to the Variant Issues Project, undertaken by ICANN. Andrew was part of the team that collaborated with the Internet Society to launch PIR and take over operation of the .org domain extension. Currently Internet Society CEO and President. ***Brian Cimbolic -- part of the Registry Stakeholder Group, is part of the Rights Protection Mechanisms group and Security Framework Drafting team at ICANN. Currently Deputy General Counsel at PIR. ***Jonathon Nevett -- chair of the ICANN Registrars Constituency from 2006 through 2009. Currently President and CEO of PIR and past co-founder of Donuts. PIR is deeply involved with ICANN. ICANN is about to create the second most lucrative TLD contract in the world -- worth hundreds and hundreds of millions of dollars. Did ICANN conduct an economic study? Did ICANN consider the switching cost for end consumers? Or it seems ICANN totally forgot about its mission to serve the public-- and it could care less what the 10+ million registrars are forced to pay for their domain registrations. But who is representing the interest of the 10+ million .org registrants at ICANN? It's sad to truly understand what ICANN has become. ICANN could care less about the public -- its mission today is to enrich the pocketbooks of the contracted registries. Without any cost justification whatsoever. And the irony of this whole thing, PIR is a non-profit, supposed to be acting in the best interest of the public. Put this out for completive bid! What a mess ICANN. -Don