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Objections to Guidebook

  • To: 3gtld-guide@xxxxxxxxx
  • Subject: Objections to Guidebook
  • From: "Michael H. Berkens, Esq." <mike@xxxxxxxxxxx>
  • Date: Sun, 22 Nov 2009 21:26:37 -0500

We hereby endorse the comments and objects of Mr. George Kirikos to the ICANN 
guidebook located at:


More specifically we are against the introduction of new gTLD's without a clear 
and provable demand from consumers and users of the proposed extension.

Simply to add extensions because businesses want to sell them, or registry's 
want to operate them, is not good enough to demonstrate the need or desire for 
these extensions.

Proposed registries should be required to show and prove demand from consumers 
prior the awarding of any extension.

ICANN to date has overseen 21 TLD's.

ICANN not shown it is able to manage hundreds of TLD's.

I would suggest that no more TLD's should be approved than were under ICANN 
management in the previous year.

Moreover the protections for current TLD;s are still not included in the 
guidebook when it comes to the lifting of price caps.

Under the guidebook, Registry Operators must offer all domain registration 
renewals at the same price, unless the registrant agrees to a higher price at 
the time of the initial registration of the
domain name following clear and conspicuous disclosure of such renewal price by 
Registry Operator."

The registries will simply have everyone agree that they could change the price 
at any time in their agreements. 

Alternatively, registrars could raise the price for everyone by the same amount 
(e.g. make all renewals be $1000) to get around this.

There needs to be *hard price caps*  on all domains

Hard caps only negatively affect registries that want to *raise* prices. It 
doesn't hurt those registries who go into the game telling everyone that 
they'll be lowering prices for consumers.

Obviously consumers benefit the most from hard caps.

Likewise TLD themselves should be awarded to the registry will to provide the 
service for the lowest cost to the consumer rather than to the company willing 
to pay the most to ICANN for the privilege.

Michael H. Berkens, Esq.
Worldwide Media, Inc.


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