[Comments-org-renewal-18mar19] .org renewal agreement - Public Comments

Jeffrey L. Chalkley chalkley at gmail.com
Wed Apr 24 17:52:18 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
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 like mine (the
Indiana High School Swimming and Diving Hall of Fame: ihssdhof.org) from
having a place on the Internet.

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

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"


Jeffrey Chalkley
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