[Comments-org-renewal-18mar19] Proposed ".org" Registry Agreement Changes

[Lynn Brinkley]

To whom it may concern:

I work at a nonprofit and very much disagree with the proposal to allow for removing price caps for .org registrants like my own organization. Removing price caps is essentially creating an unstable environment with little to no price stability.

Domain names are a product that has experienced few noteworthy innovations, and therefore has not had an inherent increase in its value, other than automation that has actually driven down the overhead costs of administering and running a registry.



Conversely, the costs of maintaining a website by the owner continue to rise from this already expensive variety of 21st century overhead, e.g. compliance with various laws about data privacy and accessibility, not just within one's local jurisdictions but enacted from abroad as well.



Removing price caps will not foster healthy competition, because many organizations (especially nonprofits) would not be able to afford to switch domain providers. Rather, removing price caps is tantamount to price gouging on a good for which there is no substitute (since the domain name often has been or became the brand of the organization for the lifespan of that organization).



Nonprofit organizations in particular could not afford the social costs of moving domains, since online donors would have greater difficulty finding that organization online. Indeed, limiting the prices of, and limiting the allowable price increases for, .org registrations is one of the main contributing factors in allowing small charity/non-profit organizations to have an online presence. By increasing the prices of holding a domain name, all that is done is increase nonprofit organizations' expenses for trying to conduct online fundraising, and at a time when the 2018 federal tax cuts laws have reduced the incentive for charitable individual giving-a double blow.



In short, allowing un-capped price increases beyond the standard maximum of 10% per year would effectively force organizations holding .org domains to endure the money-grabbing whims of registries (whose greed could easily go unchecked) and likely place unfair burdens on small organizations, individual projects, and nonprofits without increasing the value of the product for which the registry is charging.

ICANN is supposed to represent a "bottom up, consensus-driven multistakeholder model". ICANN 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 should be looking out for the .org registrants, in particular the nonprofits. There is no "public benefit" justification to these changes. It is just a handout to business at the expense of registrants' rights and protections. Where are the protections for the millions of domain registrants that this could effect in a negative way? These changes would give way too much power to the registry. This is not acceptable for a "public benefit" organization that exists to represent many stakeholders.
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