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<p>To whom it may concern</p>
<p><br>
</p>
<p>We would like to comment on the Proposed Renewal of .org Registry
Agreement incl .biz/.asia etc.</p>
<p><br>
</p>
<p>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.</p>
<p><br>
</p>
<p>2. Regarding the proposed lifting of price caps in .org and other
legacy TLDs</p>
<p>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:<br>
<a class="moz-txt-link-freetext"
href="http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminating_caps_on_legacy_domains/">http://www.circleid.com/posts/20190423_spurious_justifications_for_eliminating_caps_on_legacy_domains/</a></p>
<p>The most fundamental point is that operators of legacy extensions
do not own the namespaces that they run, they are mere caretakers.<br>
What Icann is proposing is to privatize a public resource, to the
benefit of registry operators and at the expense of registrants.</p>
<p>We cannot agree with this. Icann does not own the legacy
extensions and is a caretaker too - therefore it must act as such.</p>
<p>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.<br>
The .com contract is hugely profitable and can accurately be
described as a perpetual license to print money, granted by Icann
to Verisign.<br>
Do they really need another windfall ?<br>
</p>
<p>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 ?</p>
<p> </p>
<p>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.<br>
</p>
<p>The DNS needs stability. Domain registrants are entitled to
reasonable and predictable prices.<br>
It is not clear how protections for existing registrants will
remain in place.<br>
</p>
<p>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.<br>
</p>
<p>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.<br>
</p>
<p>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.<br>
</p>
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 <i>decrease</i>,
rather than increase. Why is the trend always up ? Where is the
competition ? <br>
<p>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.<br>
</p>
<p>In our opinion the proposed changes amount to a breach of trust,
and a massive transfer of wealth - registrants get nothing in
return<br>
We the registrants pay a <b>TAX</b> 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.<br>
</p>
<p>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.</p>
<p><br>
</p>
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