[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement

[David Riordan]

The company that I work for is a .org registrant and I am against the
proposed changes to the registry agreement.

ICANN seems to be ignoring the differences between legacy extensions that
were created with the support of the US government, predate the existence
of ICANN and have millions of existing users versus the brand new
extensions which were created, bought and paid for by private interests and
started off with a new set of rules, in particular no price controls, and
no existing registrants. They have completely different characteristics,
history, and ownership structure. It is not acceptable for ICANN to
deliberately disregard these differences and to propose that they be
treated the same.

Additionally, 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 current domain registrants. They will have no
price protections. Every registrant will be at the complete mercy and whims
of the registry.  .Org has been working just fine for decades where the
prices maybe go up a little bit each year (and already allowed at rate that
is far above inflation).

Finally, 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’.  This
procedural bypass is completely unacceptable.

ICANN appears to be catering to registries by removing price caps and to
the trademark/IP lobby on the UDRP/URS side. ICANN should stand up for the
public interest and registrants!

Sincerely,
David Riordan
Reflex Publishing, Inc.
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