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Comments on Section 2.10

  • To: 3gtld-transition@xxxxxxxxx
  • Subject: Comments on Section 2.10
  • From: Dan Schindler <danielmschindler@xxxxxxx>
  • Date: Mon, 23 Nov 2009 17:21:23 -0800

I would like to comment on Section 2.10 of the proposed Registry Operator 

“[Registry Operator shall 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.]”

In my opinion, the parenthetical suffers from inherent flaws rendering it 
problematic, unworkable, and unnecessary for the following reasons.  

- The Registry Operator does not have the relationship with the Registrant and 
consequently cannot provide "Clear and conspicuous" or any kind of  disclosure 
to the Registrant;
- The Registry Operator does not control the price to the Registrant, so such 
disclosure would be useless anyway;
- There may be reasonable reasons why a renewal price in 2020 would be higher 
than an initial registration price in 2010 and besides, how can the distant 
future possibly be predicted anyway?
- Wouldn't  .INFO have been be in breach of this clause when they provided free 
domains and then charged for subsequent renewals?
- Without the proposed clause, existing Registry Operators (e.g. .mobi, .asia, 
.tel, etc.) have not unfairly increased renewal prices to gauge registrants, 
even though they could.  They do not do so, in part, because of marketplace 
protections.  It would not be in their economic interest to gauge their 
end-user customers, as they would suffer in the marketplace.  Who would buy new 
names from that registry? 
As such, I suggest that it be removed from the DAG, with the understanding that 
the consumer protection that it seeks to address, will be addressed through 
market forces as it has been with all of the non-price regulated existing 

Thank you

Dan Schindler

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