[Comments-org-renewal-18mar19] Price Caps Should NOT Be Removed From .ORG gTLD Renewal

Ben Franske ben.mm at franske.com
Wed Apr 24 14:34:35 UTC 2019

I do not support the removal of the price cap provisions from the 
renewal of the .org gTLD agreement. These provisions which limited the 
price of registrations and allowable price increases for registrations, 
are important to allowing small organizations, especially non-profit 
charity organizations to exist on the Internet. Many of these 
organizations have long-held .org domain names and a substantial 
percentage of their meager funding is tied to donors being able to find 
them via those domains. The massive potential price increases (as 
opposed to the moderate ones that are already possible) would prohibit 
smaller organizations and personal projects from having a place on the 

Let me be clear, there is no inherent 'worth' to domain names and no 
registry 'deserves' to profit from the sale of domain names. These are 
in infinite supply and simply a ledger entry. They are not a product 
where the registry provides any innovation nor are they a product which 
costs any substantial amount of money to produce. The costs of domain 
registration must ONLY cover the costs of administering said registry 
which are very minor costs given the automation level possible.

While I understand that legacy gTLD providers are upset that they are 
limited in what they can charge when newer TLD providers are not they do 
have a distinct advantage of being more recognizable and are thus more 
than making up for it in volume. The greed of gTLD providers should not 
be a reason to allow unreasonable price increases. If a legacy gTLD 
provider does not feel they can cover their costs in a price-capped 
arrangement we should instead seek out a new provider for the  gTLD. I'm 
certain that there are many organizations who would be more than happy 
to take over the oversight of these legacy gTLDs while still agreeing to 
the price caps.

Indeed I would support a reverse-auction of qualified bidders for all 
legacy gTLDs where the winner would be the organization which would 
guarantee the lowest price for registrations. THIS competition would 
best serve the users of the Internet, not the opposite which is to 
remove price caps.

Let me quote from an excellent article on this subject which well 
explains why competition is a false idea in this marketplace -- 

"If price caps are eliminated, competition will not keep prices in 
check. Competition is effective in restraining prices only if 
registrants can easily switch one domain name for another. An 
organization's domain name becomes its online brand for the life of the 
organization. Moving to another domain name requires undergoing the 
hugely expensive and disruptive ordeal of rebranding and is to be 
avoided at nearly any cost. Organizations wish to continue using their 
existing domain name, for which there is no adequate substitute. When 
there is a unique product that cannot be easily substituted for any 
other, there is no effective competition.

In the absence of competition, registrants can be protected from 
extortionate pricing only through pricing constraints, such as price 
caps. ICANN as the trustee for the legacy name spaces has the 
responsibility of an owner"


Dr. Benjamin Franske

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