[Comments-org-renewal-18mar19] Comments on certain changes proposed to the .org Registry Agreement

Ethan Sweet ethan at ethan.pm
Sun Apr 28 03:28:32 UTC 2019

I am a .org registrant and a Company Director. I am additionally a Google Europe Scholar in the EMEA Region a former Internet Society Youth at IGF Fellow. My views do not represent those of Google or the Internet Society, however, these views do represent those of BR28 LTD, a Private Limited Company registered in England and Wales which joins these comments with me.

==Open Access is at the heart of .org==

.org is a Top Level Domain with open access at its heart, managed by Public Internet Registry as created by the Internet Society .org is used by many people for many purposes, while initially not-for-profit restrictions were in place these were quickly lifted, today .org is an open space on which many diverse members of the Internet Community use.

==Open Access is good for the Internet==

Open Access is fundamentally a good thing for the internet as a whole, we want as many people from all over the world to be able to benefit from the Internet, not just by consuming content on it, but creating it, by maximizing the reach of people who can be called members of the Internet Community and enabling their meaningful participation in this unique global network we maximize the benefits for every participate through a multitude of views and perspectives on a range of topics. This is fundamentally a good thing and is why countless bodies work towards increasing access and connectivity to the internet.

==Price Controls enable Open Access==

Price Controls enable those of limited income to be full participants in the Internet Community, sometimes there are costs associated with using the internet, we accept them as a necessary evil to ensure a stable and well functioning internet but I am sure we all agree they should not be higher than necessary. Price Controls ensure this provision is held true, and fundamentally ensure that those of limited income can be full participants in all parts of our shared internet community.

Critics may say "why do we not impose certain controls on other parts of the technical process, such as hosting?" The reason is that hosting is not a natural monopoly whereas DNS is, unless ICANN say otherwise PIR is the only registry that may issue .org domains and therefore there is no economical incentive (although there may be a mission based one) to keep prices low.

==Legacy TLD providers share a unique responsibility==

Legacy TLD providers have been around for many years longer than many others, the exposure of members of the Internet Community to legacy TLD providers is much larger than those of new TLD providers (how many internet users have seen .com versus .sucks?), if a user is looking for a domain name they are likely to look towards the well established legacy TLD providers first before the new TLD providers, this is simply because awareness of these providers is higher, but also places a unique responsibility on these providers to serve these users who may have limited knowledge in good faith and to not place barriers in front of them. If a user sees very high prices on these legacy TLDs, they may assume that this is normal across all TLDs and give up with gaining their own domain name. This en-masse would be a huge loss for the internet and not only increase Internet Consolidation but push back on the open access of the internet as a whole to everyone.

==ICANN's ultimate responsibility is to serve the Internet Community==

TLD management is fundamentally a monopoly, as a community we have agreed that it is for for many many years, I recall when ALTDNS was briefly in existence but was rejected by the majority of the Internet Community, the reasoning why was that a disagreement on standards could fundamentally split the internet, which would be catastrophic, but also because we believed we could create a body accountable to us, the Internet Community, to manage and oversee the Domain Name System in our interests, we created this body as ICANN. ICANN holds a monopoly on the Domain Name System and operates it in our name. ICANN should therefore side with those Internet Users who may no longer be able to afford a domain if prices were to increase.


-Ethan Sweet

-The Directors of BR28 LTD
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