[Comments-org-renewal-18mar19] Opposing the proposed removal of price controls from legacy TLDs

[Peter Law]

Hi,

I am writing to oppose to the proposed removal of price controls from
legacy TLDs.

Removal of price controls would create an environment where the
controlling registry is able to extract disproportionate value from
registrants. Much of the value of the .org domain originates with the
registrants who entrusted their domains within it. This is a
substantial difference to generic TLDs where the value of the TLD can
reasonably be seen as partially originating with the registrar who
created it.

Furthermore, because domain names are not interchangeable (for example
icann.org is not replaceable by icann.com without considerable effort)
there can be no competition at the point of registration. Instead
competition must happen at the point of service provision for the TLD.

As a result of these factors, ICANN must consider its responsibility
to registrants within legacy TLDs and as the entrusted owner of the
legacy TLDs.

Thanks,
Peter Law