ICANN continues to ignore the public that overwhelmingly disapproves of new gTLDs (comments of Leap of Faith Financial Services Inc.)
- To: "6gtld-guide@xxxxxxxxx" <6gtld-guide@xxxxxxxxx>
- Subject: ICANN continues to ignore the public that overwhelmingly disapproves of new gTLDs (comments of Leap of Faith Financial Services Inc.)
- From: George Kirikos <gkirikos@xxxxxxxxx>
- Date: Sun, 15 May 2011 07:09:18 -0700 (PDT)
By: George Kirikos
Organization: Leap of Faith Financial Services Inc.
Date: May 15, 2011
Leap of Faith Financial Services Inc. owns and operates a network of some of
the leading websites in the world, including Math.com. We continue to invest in
the internet space, having recently acquired School.com.
ICANN should abandon its current approach, and instead go back to basic
principles, including maximization of benefits to consumers. It should follow
the approach advocated by Ms. Deborah Garza in the 2008 NTIA/DOC/DOJ letter to
ICANN, and also listen to concerns of experts like Tim Berners-Lee who oppose
We have commented in every new gTLD comment period that ICANN has created. We
do so again for this 6th Draft Applicant Guidebook. However, ICANN has not
listened to the concerns of ourselves and others, and instead has placed its
own interests ahead of the public.
We reiterate our most recent comments at:
and the comments to the 4th, 3rd, 2nd and 1st Draft Applicant Guidebooks.
This latest guidebook does nothing to address our concerns. We also endorse the
comments of the many other critics of ICANN's programs, including those of K
who even noted:
"From reading the public comments it looks like everyoneis getting pretty weary
of reposting their same concerns after they've been repeatedly ignored by
ICANN, but i guess i'll join the growing club."
We also share the concerns of the elected representatives who grilled Kurt
Pritz in Washington, DC recently over ICANN's rush to implement a plan that is
not supported by the public. To be blunt, while ICANN is suggesting to the
public that this guidebook is moving towards perfection, the public is pushing
back to say that ICANN is simply "polishing a turd". No matter how much ICANN
attempts to polish it, it is what it is, and will not be palatable to the
public no matter how much wax it employs.
It's time for ICANN to go back to first principles, and reboot the new TLD
program in its entirety. Experts like Tim Berners-Lee had argued that new TLDs
were considered harmful:
and it's time to realize they were absolutely correct. ICANN's own economists
did not show that the benefits of new TLDs would outweigh the costs to the
public. Furthermore, ICANN's own economists were not given proper instructions,
to explore what mechanisms would *maximize* the benefits to the public, while
minimizing the costs upon the public. Had ICANN done so, we have no doubt that
maximization of consumer welfare (i.e. benefits to end-users) would have been
realized only through fixed-term registry contracts, awarded via
competitively-bid tender processes. This is exactly what the DOC, NTIA and DOJ
were advocating in 2008, see:
See the last two pages of that document, for example:
"Finally, ICANN should require competitive bidding for renewals of a gTLD
registry agreement, rather than granting the incumbent operator a perpetual
right to renew without competition.........competitive bidding has resulted in
lower domain prices and higher operating specifications....ICANN's approach to
TLD management demonstrates that it has adopted an ineffective approach with
respect to its obligation to promote competition at the registry level. We
respectfully suggest that the DOC refrain from expressing satisfaction with
ICANN's progress toward the goal of promoting competition among TLDs unless and
until ICANN develops a credible and effective policy that compels it to employ
tools such as competitive bidding to manage TLDs in a manner that safeguards
the interests of registrants in obtaining high quality domains at the lowest
possible prices. To date, we believe that ICANN has not come close to
fulfilling its obligations to employ competitive
principles in its management of TLD registry operations."
This letter was dated December 3, 2008, yet it remains true today. ICANN has
done the exact *opposite* of that letter said should be required of ICANN.
Indeed, ICANN has recently put forth a renewal of the .NET agreement with
which guarantees price increases for VeriSign, instead of requiring a
competitive tender in order to maximize benefits for consumers. This is a slap
in the face to the DOC, DOJ, NTIA and to the public. In these difficult
economic times, ICANN's bad policies translate into higher costs for consumers
on the order of several hundred million dollars per year (i.e. higher costs for
com/net alone, compared to competitive tenders). That directly translates into
lost jobs, as the savings could be used by companies to reinvest in productive
pursuits, rather than being wasted on monopolistic fees paid to VeriSign.
ICANN's record in TLD management remains appalling, and we call upon the DOC,
NTIA, DOJ and GAC to compel ICANN to go back to the drawing board. In the
alternative, if ICANN does not demonstrate a willingness to do so, it's time to
end the ICANN "experiment", end the outsourcing of TLD management to ICANN, and
instead restore the management of TLDs to the DOC/NTIA.