[Comments-org-renewal-18mar19] Proposed renewal of .org registry agreement

Steven Kennedy scrsteven at gmail.com
Wed Apr 24 22:04:31 UTC 2019

I am a longtime .org domain name registrant.

I believe that ICANN staff should not unilaterally impose URS in legacy
TLDs when that issue is precisely what is being examined by the volunteer
ICANN Working Group who has been mandated to review this issue. ICANN
policy making is supposed to be a 'bottom up, multi-stakeholder model', and
not forced from the top down as this proposal seeks to do.

I believe that legacy TLDs are fundamentally different from for-profit new
gTLDs. Legacy TLDs are essentially a public trust, unlike new gTLDs which
were created, bought and paid for by private interests. Registrants of
legacy TLDs are entitled to price stability and predictability, and should
not be subject to price increases with no maximums. Unlike new gTLDs,
registrants of legacy TLDs registered their names and made their online
presence on legacy TLDs on the basis that price caps would continue to
exist. Domain switching costs are often prohibitively expensive.

These legacy TLDs should be operated at the lowest possible pricing. The
registry operators for legacy TLDs did not invent the TLDs nor do they
"own" them. The registry management contracts should be put out to bid to
reduce the price to registrants; they should not be granted indefinitely
into the future to one group with unlimited price increases possible. This
recent proposal by ICANN staff is the exact opposite of what should be
happening. Prices should be going down, not upwards without restraint.

Unrestrained price increases on the millions of .org registrants who are
not-for-profits or non-profits would be unfair to them. Unchecked price
increases have the potential to result in hundreds of millions of dollars
being transferred from these organizations to one group, the Internet
Society, with .org registrants receiving zero benefit in return. ICANN
should not permit one group nearly unlimited access to the funds of other

ICANN appears to be entirely catering to registries by removing price caps.
ICANN should stand up for the public interest and registrants, and make
moves to reduce the pricing of legacy TLDs by opening up the registry
management agreements to competitive bidding.

Steven Kennedy
SK Creations, Inc.
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