To whom it may concern We would like to comment on the Proposed Renewal of .org Registry Agreement incl .biz/.asia etc. 1. We do not believe that URS should be introduced in .org and the other legacy TLDs. The timing is not right and the actual worth of URS is debatable. 2. Regarding the proposed lifting of price caps in .org and other legacy TLDs The proposal is deeply flawed and riddled with false equivalence. Rather than reiterate each point we refer to the comprehensive analysis by Nat Cohen here: http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminati... The most fundamental point is that operators of legacy extensions do not own the namespaces that they run, they are mere caretakers. What Icann is proposing is to privatize a public resource, to the benefit of registry operators and at the expense of registrants. We cannot agree with this. Icann does not own the legacy extensions and is a caretaker too - therefore it must act as such. We think that the aim being pursued (and logical conclusion) is to ultimately grant the .com registry (Verisign) similar terms, under the guise of equal treatment. The .com contract is hugely profitable and can accurately be described as a perpetual license to print money, granted by Icann to Verisign. Do they really need another windfall ? Icann once more appears to have been captured by the industry that it is supposed to oversee. Who is Icann accountable to ? Quis custodiet ipsos custodes ? It is not the first time that Icann is found to be acting against the interests of the Internet community. Back in 2012 the US Department of Commerce had to step in to protect the interests of registrants and amend the .com contract between Icann and Verisign. Without government intervention Verisign would have been allowed four price increases of up to seven percent over a six-year term. The DNS needs stability. Domain registrants are entitled to reasonable and predictable prices. It is not clear how protections for existing registrants will remain in place. Domain names are not interchangeable assets but extensions of corporate brands in the online realm. The registrants are captive customers. For that reason price caps are completely justified and necessary. You can't get the same domain name from another registry if you don't like the pricing. There is no competition with monopolies. Nat Cohen pointed out that price uncertainty is a factor that is keeping consumers away from new extensions. We can see the so-called tiered (premium) pricing model in action in new extensions, marred with abusive, downright absurd registration and renewal fees. Is this the model that Icann wants to pursue ? It certainly does not demonstrate "maturation of the domain name market". Quite the opposite, it further demonstrates that we cannot expect domain registries to self-regulate and act responsibly. Recent and not so-recent history should serve as a warning and deterrent. We don't want legacy extensions to be allowed to run in Wild West mode. In recent years domain registration fees have increased markedly in gTLDs, well above inflation rates. Current pricing provisions are already generous - and in fact hard to justify barring exceptional circumstances. At the same time hosting, connectivity costs are decreasing. Accordingly registration costs should /decrease/, rather than increase. Why is the trend always up ? Where is the competition ? Other registries are able to offer the same service at a lower cost. This is especially true for the large registries, that are able to realize economies of scale. In our opinion the proposed changes amount to a breach of trust, and a massive transfer of wealth - registrants get nothing in return We the registrants pay a *TAX* on each domain name, and we therefore contribute to Icann funding. We expect that our interests will be adequately represented. What is happening is the exact opposite. Finally, we believe that it's high time for the FCC to investigate the domain industry. Self-regulation has failed. The multi-stakeholder model does not work like it should.