[Comments-org-renewal-18mar19] Comments on proposed registry agreement changes for renewal of .org

[Aaron D. Gifford]

 From the ICANN summary:

"*Pricing for Domain Name Registrations and Registry Services (Section 
2.10 of the .org renewal agreement):* In alignment with the base 
registry agreement, the price cap provisions in the current .org 
agreement, which limited the price of registrations and allowable price 
increases for registrations, are removed from the .org renewal 
agreement. Protections for existing registrants will remain in place, in 
line with the base registry agreement. This change will not only allow 
the .org renewal agreement to better conform with the base registry 
agreement, but also takes into consideration the maturation of the 
domain name market and the goal of treating the Registry Operator 
equitably with registry operators of new gTLDs and other legacy gTLDs 
utilizing the base registry agreement"

Legacy TLDs .com, .net, and .org are truly public resources and, as 
such, should be treated distinctly from later added TLDs. Registries for 
these TLDs are providing a service on a limited resource and as such 
should be considered monopolies for providing that service, as legacy 
TLD domains registered with those TLDs cannot be easily or inexpensively 
replaced with a new registration in another TLD.  There is NO 
COMPETITION, and thus costs in legacy TLDs really should be controlled 
tightly in the public interest.

Thus I object strongly to removal of price cap provisions for the 
renewal of the .org agreement.

What would be far better would be for ICANN to propose some sort of 
competition for registries to service the .org (and this would work well 
for .com and .net as well) TLD, perhaps hold a sort of reverse auction, 
where qualified registries would compete to win short-term operation of 
the .org TLD registry.  This would provide TRUE COMPETITION and keep 
costs down.  In all likelihood, costs would decrease significantly from 
where they are today.  If all legacy TLDs were handled this way, perhaps 
costs would come down closer to the costs the .de country-based TLD 
registry charges today.

DO NOT REMOVE PRICE CAPS.  PLEASE ADD TRUE COMPETITION VIA REVERSE 
AUCTION FOR THE .org TLD CONTRACT.

Thank you!

Aaron Gifford
St. George, Utah