For the record, I disagree with the statement that Greg prepared, and it doesn't reflect my views (which I linked to in an earlier post). It doesn't even reflect the views expressed by many non-profits who made public comments, including NPR and other high profile ones: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003179.ht... or the Non-Commercial Stakeholders: https://mm.icann.org/pipermail/comments-org-renewal-18mar19/2019q2/003207.ht... If folks wanted to send a letter, they should have sent it in an individual capacity, rather than pretend that this statement is reflective of the views of billions of internet users. Given the overwhelming opposition already expressed in the public comments to date, Greg's statement is more indicative of capture of the At-Large, rather than anything that could reasonably reflect what users think of these contracts. ISOC/PIR is just one of many non-profits, and its mission is no better than any other. Every organization has unlimited wants, but needs to work within a reasonable budget. ISOC/PIR doesn't own .org, and shouldn't pretend it does via unlimited "rent" or taxes payable to it. They'll always be able to spend as much money as they can take in. As I noted in my own comments, nothing would stop ISOC/PIR from selling out to private equity, who could then take the heat for huge price increases, while ISOC/PIR walks away with an enormous multi-billion dollar endowment fund. The statement that "many At-Large Structures are also ISOC Chapters" is consistent with a conflict of interest and capture, rather than being reflective of ordinary users. The base agreement for new gTLDs is different from that of legacy gTLDs for good reason, and should not be adopted by legacy gTLDs which predate ICANN itself, and whose registrants do not agree with unlimited fee increases. That's changing the rules in the middle of the game (whereas registrants of new gTLDs knew all along the risks they take registering with new gTLDs, where the registry essentially "owns" that TLD). The letter quotes Jonathan Zuck's statement about the "desirability" of higher prices almost verbatim, but hasn't done the same for others in the CPWG. Higher prices are not desirable in any way, except by some twisted logic that makes no economic sense (my own personal background is in economics and finance). New entrants always knew that legacy gTLDs had capped prices, before they entered the space. Furthermore, competition generally leads to *lower* prices, not higher prices! Attempting to argue that capped fees contribute to confusion, phising, fraud and abuse is truly a stretch. The most abused TLDs are the new gTLDs, not the legacy ones, e.g. see: https://www.spamhaus.org/statistics/tlds/ If one wants to target phishing, fraud and other abuses, one needs to actually *target* it using effective tools. Raising prices for *everyone* is not an effective tool, as it has more collateral damage than actual benefits. If 1%, for example, of domains are engaged in abused, it makes no sense to raise costs on 100% of registrants. One wants to raise costs only on those engaged in abuse (e.g. through high penalties for abuse, like jailtime, fines, etc.). Raising prices for *everyone* simply enriches the registry, at the expense of the public. Pretending that an "economic study" will be helpful is absurd, as ICANN has in the past commissioned "experts" who simply regurgitated whatever ICANN wanted them to say. Recall that these so-called "experts" (the Carlton report, etc.) were used to justify the new gTLD program in the first place, which has been a failure. Here's a comment from K. Claffy, which talked about those reports: https://forum.icann.org/lists/economic-framework/msg00004.html which also referenced my scathing comments about them at the time (which proved prescient). She concluded her comments with: "Similar to my observations of what's happening in the security and stability discussion of root scaling, ICANN's behavior looks like it's trying to buy rubberstamps of its current plans from commercial consultants, rather than foster what is needed in the long term: a coherent field of objective, peer-reviewed technical, policy, and economic research on Internet naming and numbering, and incentivized data-sharing to support such research." The ICANN contracts do not have any mechanism to "undo" the changes. Once the caps are removed, that genie cannot be put back in the bottle. One should do an economic study *before* lifting any price caps, rather than doing them after the horse has left the barn, and after the damage has already been done. What "problem" is this contract actually trying to solve? If it's not broken (and legacy gTLDs are successful, obviously), one should stick with the status quo. If new gTLDs are the "broken" thing, they can be fixed directly (by adding fee caps, just like the successful legacy gTLDs, or making other changes). In conclusion, Greg, Jonathan, and others should have simply submitted their own personal comments, rather than try to suggest that this statement is reflective of billions of users. Sincerely, George Kirikos 416-588-0269 http://www.leap.com/ On Tue, Apr 30, 2019 at 2:14 AM Greg Shatan <greg@isoc-ny.org> wrote:
All,
I am attaching another, further revised draft public comment on the .ORG renewal, after sifting through the various recent conversations on the list. I will try to circulate a redline in the morning, New York time, but can't right now.
I thought about including something on UA, but for .ORG and in the absence of proposed language, I did not see the obvious hook in this statement to bring that concept in.
Best regards,
Greg
Greg Shatan greg@isoc-ny.org President, ISOC-NY "The Internet is for everyone" _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg