[Comments-org-renewal-18mar19] Proposed Renewal of .org Registry Agreement incl .biz/.asia etc.

Foreign Ventures, Inc. info at foreignventures.com
Sun Apr 28 00:59:09 UTC 2019

To whom it may concern

We would like to comment on the Proposed Renewal of .org Registry
Agreement incl .biz/.asia etc.

1. We do not believe that URS should be introduced in .org and the other
legacy TLDs. The timing is not right and the actual worth of URS is

2. Regarding the proposed lifting of price caps in .org and other legacy

The proposal is deeply flawed and riddled with false equivalence. Rather
than reiterate each point we refer to the comprehensive analysis by Nat
Cohen here:

The most fundamental point is that operators of legacy extensions do not
own the namespaces that they run, they are mere caretakers.
What Icann is proposing is to privatize a public resource, to the
benefit of registry operators and at the expense of registrants.

We cannot agree with this. Icann does not own the legacy extensions and
is a caretaker too - therefore it must act as such.

We think that the aim being pursued (and logical conclusion) is to
ultimately grant the .com registry (Verisign) similar terms, under the
guise of equal treatment.
The .com contract is hugely profitable and can accurately be described
as a perpetual license to print money, granted by Icann to Verisign.
Do they really need another windfall ?

Icann once more appears to have been captured by the industry that it is
supposed to oversee. Who is Icann accountable to ? Quis custodiet ipsos
custodes ?

It is not the first time that Icann is found to be acting against the
interests of the Internet community. Back in 2012 the US Department of
Commerce had to step in to protect the interests of registrants and
amend the .com contract between Icann and Verisign. Without government
intervention Verisign would have been allowed four price increases of up
to seven percent over a six-year term.

The DNS needs stability. Domain registrants are entitled to reasonable
and predictable prices.
It is not clear how protections for existing registrants will remain in

Domain names are not interchangeable assets but extensions of corporate
brands in the online realm. The registrants are captive customers. For
that reason price caps are completely justified and necessary. You can't
get the same domain name from another registry if you don't like the
pricing. There is no competition with monopolies.

Nat Cohen pointed out that price uncertainty is a factor that is keeping
consumers away from new extensions. We can see the so-called tiered
(premium) pricing model in action in new extensions, marred with
abusive, downright absurd registration and renewal fees. Is this the
model that Icann wants to pursue ? It certainly does not demonstrate
"maturation of the domain name market". Quite the opposite, it further
demonstrates that we cannot expect domain registries to self-regulate
and act responsibly.

Recent and not so-recent history should serve as a warning and
deterrent. We don't want legacy extensions to be allowed to run in Wild
West mode.

In recent years domain registration fees have increased markedly in
gTLDs, well above inflation rates. Current pricing provisions are
already generous - and in fact hard to justify barring exceptional
circumstances. At the same time hosting, connectivity costs are
decreasing. Accordingly registration costs should /decrease/, rather
than increase. Why is the trend always up ? Where is the competition ?

Other registries are able to offer the same service at a lower cost.
This is especially true for the large registries, that are able to
realize economies of scale.

In our opinion the proposed changes amount to a breach of trust, and a
massive transfer of wealth - registrants get nothing in return
We the registrants pay a *TAX* on each domain name, and we therefore
contribute to Icann funding. We expect that our interests will be
adequately represented. What is happening is the exact opposite.

Finally, we believe that it's high time for the FCC to investigate the
domain industry. Self-regulation has failed. The multi-stakeholder model
does not work like it should.

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