[Urgent] [Public Comment] Proposed Renewal of .org Registry Agreement

[Amr Elsadr]

Hi Michael,

> On Apr 25, 2019, at 9:28 PM, Michael Karanicolas <mkaranicolas at GMAIL.COM> wrote:
>
> Hi Amr,
>
> Thanks very much for this valuable feedback. Just a small point of clarification - any price rises, if they occur, will impact incumbent registrants (though, they have an option of locking in current prices by purchasing a longer term package).

That isn’t my understanding. [Section 2.10 of the base registry agreement](https://newgtlds.icann.org/sites/default/files/agreements/agreement-approved-31jul17-en.html#article2.10) (mainly check out 2.10 b and c) places obligations on Registry Operators for registration renewal prices when they implement changes to pricing of registrations under a gTLD. So incumbent registrants would not need to purchase a longer term package.

> To me, it's less about the status of PIR as a non-profit (which of course we wouldn't want to penalize) and more about the status of .Org as a home for non-profits, which I think distinguishes it from other domains, and which, I think, does support treatment that's different from what we would expect for traditional commercial domains.

OK…, thanks for the clarification on .org’s status as a home for NFPs being more of the issue than PIR’s status as a NFP. I still don’t really agree that this is cause to keep a price cap on the pricing of registrations.

Like I said, I don’t believe there is any significant impact on NFPs, or other registrants (.org registrations are not limited to NFPs, of course) with current registrations, since they are protected under the base registry agreement that PIR would transition to for a pretty decent duration of time. And if the pricing of new .org registrations becomes too unappealing to prospective registrants, there are plenty of other gTLDs out there to choose from. I can’t be sure of this, of course, but if PIR do end up raising the price of new registrations for .org (or .info), I imagine it will not be a very dramatic increase.

> But I agree it's a tough issue, and I think the current language is meant to approach things cautiously from that perspective - recognizing a need to adapt to market forces, while still keeping the door open for some controls, or a review of the impact on registrations.

The current draft does indeed consider reasons that both justify an increase, as well as call for caution and further study. But it does still say that the NCSG believes a price cap should remain in place, even if it is a higher one. I simply do not believe ICANN should make this decision for a Registry Operator (RO). Or at a minimum, ICANN should not be in a position to treat ROs differently, especially where pricing of registrations under their TLDs is involved. And I would hope that the NCSG wouldn’t advocate for this.

Sure, .org is a special circumstance, and its existence predates PIR’s. Still…, for NCSG to encourage policies that discriminate between one contracted party over another, for whatever reason, is not something I believe we should do. If there was only a handful of gTLDs out there, the situation might be different, but that isn’t the case.

My guess is that this is more likely to be an issue for commercial registrants who invest in domain names (domainers) with the objective of making a profit, as any price increase in new registrations might significantly impact their businesses. But they can take that issue up for themselves.

I hope this helps.

Thanks again.

Amr
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