[Comments-info-renewal-18mar19] Comment on Proposed Renewal of .info Registry agreement
getedit at yahoo.com
Thu Apr 25 15:23:35 UTC 2019
I am writing to urge you to retract your proposal to eliminate price caps for .info domains.
When ICANN accepted the responsibility from the US Dept of Commerce for private sector DNS Management (DNS Project), it committed to principles of Stability, Competition, and Representation of Internet users and their needs. Eliminating price caps goes against that commitment on all three principles.
Stability: Literally countless users have established their Internet presence based on legacy pricing policies upon which they could rely for stable and predictable future pricing. These users would now face a highly disruptive after-the-fact policy change. You stated "the goal of treating the Registry Operator equitably with registry operators of new gTLDs and other legacy gTLDs utilizing the base registry agreement.", but legacy operators made contractual agreements to their best judgement by the terms at that time; it is entirely unfair and destabilizing to allow those agreements to be radically changed after they were made.
Competition: Removing price caps will not stimulate competition. On the contrary, it will remove pressure on new TLDs to remain competitive with legacy TLDs. Although this may well serve the financial interests of new Operators, it flagrantly renounces the DNS Project requirement (and commitment) to internet users needs.
Representation: ICANN has been thus far in its history been admirable in supporting the diversity of internet users and their needs. Despite the vast proliferation of commercial use of the Internet, protections have thus far been maintained for global users whose presence in the global community is based on goals and intentions for the common good, well beyond commercial profit. Please continue to uphold the responsibility to support and foster all Internet users regardless of the strength of their commercial voice.
Thank you for your consideration. Posted below are the principals as directly stated in ICANN's founding agreement in accepting DNS Management responsibility.
MEMORANDUM OF UNDERSTANDING BETWEEN THE U.S. DEPARTMENT OF COMMERCE ANDINTERNET CORPORATION FOR ASSIGNED NAMES AND NUMBERS
C. The PrinciplesThe Parties will abide by the following principles:
1. StabilityThis Agreement promotes the stability of the Internet and allows the Parties to plan for a deliberate move from the existing structure to a private-sector structure without disruption to the functioning of the DNS. The Agreement calls for the design, development, and testing of a new management system that will not harm current functional operations.
2. CompetitionThis Agreement promotes the management of the DNS in a manner that will permit market mechanisms to support competition and consumer choice in the technical management of the DNS. This competition will lower costs, promote innovation, and enhance user choice and satisfaction. 3. Private, Bottom-Up CoordinationThis Agreement is intended to result in the design, development, and testing of a private coordinating process that is flexible and able to move rapidly enough to meet the changing needs of the Internet and of Internet users. This Agreement is intended to foster the development of a private sector management system that, as far as possible, reflects a system of bottom-up management.
4. RepresentationThis Agreement promotes the technical management of the DNS in a manner that reflects the global and functional diversity of Internet users and their needs. This Agreement is intended to promote the design, development, and testing of mechanisms to solicit public input, both domestic and international, into a private-sector decision making process. These mechanisms will promote the flexibility needed to adapt to changes in the composition of the Internet user community and their needs.
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