[Comments-org-renewal-18mar19] The proposed .org agreement will hurt public institutions

Elaine Simon esimon at myhta.org
Thu Apr 25 16:51:59 UTC 2019

I am a .org registrant and a not-for-profit or non-profit organization.

Legacy gTLDs are fundamentally different from for-profit new gTLDs and
should be treated that way. Legacy TLDs are what the internet was built on.
They are essentially a public trust. They are very different than new gTLDs
which were created, bought and paid for by private parties. Registrants of
these legacy extensions should be entitled to price predictability &

Advancements in technology should be driving the cost of operating a
registry down, yet prices keep going up? Removing price caps is unfair to
the millions of domain registrants. They will have no price protections.
Every registrant will be at the complete mercy and whims of the registry.
This could result in a transfer of funds from millions of non-profits to
one non-profit, with no benefits to the domain registrants.

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
non-profits. 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.

*Elaine Simon*
Director of DevOps
Hawaii Technology Academy
Cell: (808) 398-3923

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