[Comments-cct-recs-27nov17] Registry Monopolies / Expiration Abuse / Consumer Trust

Concerned Registrar anonymous.registrar.concerned at gmail.com
Mon Jan 15 23:58:56 UTC 2018

When ICANN was first created, one of its most important goals was to break
up the Verisign/Network Solutions monopoly. ICANN has failed to accomplish
this goal as both .com and .net are still controlled by that same monopoly.
Additionally, ICANN then extended this monopoly to other TLDs including the
additional monopolies created with the new GTLD program. ICANN was on the
right track by implementing the registrar system, but did not address the
lack of competition at the registry level. The end effect is all profits
are now at the registry level with guaranteed registry price increases
every year. While registrar prices and margins are competitive, registry
prices have consistently increased for no reason even as registry costs
have significantly declined.

Having a separate contracted entity for each TLD serves no purpose other
than to hand a monopoly to that entity - with no competition - so they can
collect an ever increasing annuity (due to decreasing costs and guaranteed
price increases in the contract with ICANN) for no actual work since
ICANN's multi-stake-holder model creates all the policies. This separate
registry entity serves no purpose and is not adding any value to the domain
ecosystem or registrants. Outsourced registry services by large registry
providers can be had for less than $2 per domain per year.

It is our belief that ICANN should take back all GTLDs (new and legacy) by
refunding new GTLD auction proceeds and other actions as necessary and
directly outsource the registry function to the many available registry
providers at a significantly reduced wholesale cost. It can routinely bid
out contracts for registry services for each TLD. This would significantly
simplify the ICANN operating model, would decrease ICANN's footprint,
increase GTLD's stability and resiliency, and would bring competition for
GTLD registry services. It would drastically drop end user domain
registration pricing for all TLDs. There is no reason to grant monopolies
on TLDs (which are a public resource) to select for-profit organizations
(registries) that have arbitrary pricing control.

New TLD registries have engaged in abusive pricing practices including
premium registration/renewal pricing for select popular names, land rush
auctions, expiration auctions, and ongoing significant pricing increases.

Additionally, ICANN has done nothing about most domain registrars that take
ownership of domains at expiration and sell them to the highest bidder for
their own profit. This practice is rampant in the industry with all top
registrars participating. Most end users are unaware of this fact.

ICANN must introduce competition at the registry level to lower pricing and
address domain expiration practice abuse.

Please focus on domain registrants first.

In addition to the registry pricing and competition issue, ICANN has done
nothing on whois privacy for registrants. We believe privacy and audited
access should be built into whois and not by the individual registrars that
may have different policies and access control. A separate Privacy and
Proxy Service Provider Accreditation is completely unnecessary overhead for
ICANN, registries, registrars, registrants, and the public. We insist every
employee at ICANN be required to own a domain name without registrar whois
privacy (since ICANN requires the actual owner to be listed) and across
several registrars. Once every ICANN employee feels the pain of having
their personal / home contact details published publicly and the rampant
abuse of it, they will not need multi-year expensive studies to measure
this abuse. Please fix the massive abuse of the whois system and lack of


A concerned anonymous registrar on behalf of its registrants

Posted anonymously to avoid potential business ramifications as a result of
current registry monopolies.
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