[Comments-org-renewal-18mar19] Personal Comments of Ayden Férdeline on the Proposed Renewal of .org Registry Agreement

[Ayden Férdeline]

To Whom It May Concern:

I am submitting this comment in my personal capacity as a domain name registrant.

I have two concerns regarding the proposed changes to the .org Registry Agreement.

Firstly, I strongly oppose lifting price caps on .org domains. I would not object to the current price cap being raised by a reasonable figure of up to 10 percent, however a price cap must remain in place in order to offer registrants protection from exploitation.

I make this comment generally and I am not insinuating that the Public Interest Registry would seek to exploit registrants.

Many registrants of .org domains are tax-exempt organizations or bodies operating on shoestring budgets. Many advocacy-based non-profits, which are out there on the front lines defending civil liberties, have a large portfolio of .org domains which they use to run campaigns and to raise public awareness of important issues. They do a lot with very little and cannot afford to pay significantly more for their domain names. Indeed, many receive free services, such as free web hosting, from large infrastructure providers in recognition of their important societal contributions and difficulties in raising funds. To exploit these organizations and to have them paying substantially more every year to maintain their domain names would have a detrimental impact on the public's ability to obtain information and services, and could see smaller non-profit organizations either stop renewing their domain names altogether or moving away from the Domain Name System to proprietary platforms like Facebook.

Secondly, ICANN staff should not unilaterally impose Uniform Rapid Suspension provisions onto legacy Top Level Domains when that precise issue is what is being examined by the GNSO working group that was chartered to review this issue. ICANN draws its legitimacy through its bottom up, multistakeholder model, and I oppose efforts in the strongest terms to undermine this.

Thank you.

Yours sincerely,

Ayden Férdeline