Comment on the .biz/info/org agreement

["Edwin Hayward" <info@xxxxxxxxxxxxxxxxxxxx>]

To the ICANN Board,

I am concerned at the proposed TLD Registry Renewal Contracts for
the .info, .biz, and .org domains. Specifically, the issue that a
given Registry can IF THEY SO CHOOSE set essentially arbitrary
pricing for any given domain registration under their remit.

It is unfortunately naive to believe that, presented with the
opportunity to implement pricing changes implicitly or explicitly
based on putative measures of domain value 
(through traffic and
visitor pattern analysis, keyword/search term research tools,
algorithmic analysis of the genericness and commercial viability
of a given keyphrase composing a domain name, etc.), the
respective Registries involved will somehow choose an artificial
policy of restraint rather than the commercial path of maximizing
their revenue freed from all but the most liberal constraints
on their domain registration operations.

A real-world example illustrates what happens when price controls
on a monopoly commodity (only one Registry has the ability to
manage the registration of domains under a given TLD extension).
Specifically, the .tv domain name extension.

As of August 28, 2006, the following pricing, displayed on the
official .tv registry site, gives just a taste of what may be
in store for .info/biz/org domain name owners and future
registrants if price caps are removed.

In the table below, the quoted price is the ANNUAL FEE required
by the .tv registry to secure the registration of the domain
name in question.

creative.tv US$10,000
usa.tv US$100,000
power.tv US$30,000
cars.tv US$100,000

Since most if not all domains that could be considered "premium"
under a similar system to the one used by the .tv registry
to determine "theoretical" domain name value have already
been registered in the .org/info/biz extensions, the removal of
all price constraints represents an attempt to artifically
"tax" those domain owners that 
had the foresight to register
such domains years or decades ago.

What happens to the small business owner, charity or individual
who has built up a web business or web site around a domain name
which - for traffic analysis, genericness or other reasons - is
suddenly deemed to "cost" hundreds, thousands or even millions
of dollars a year to maintain and renew?

There's a particular irony that, at a time when more and more
people are coming online, and when the cost of a web presence
(hosting, bandwidth costs, server software, web development
tools etc.) is plunging at a faster rate than perhaps at any
previous time in the web's history, that ICANN should be willing
to countenance a fundamental change in the domain name system
that spits in the face of such progress.

If this proposal is passed with the price cap removal clause
intact, it is going to cause a thunderclap of repercussions
around the world that will echo for many years to come, and may
even go down in history as THE pivotal date on which the Web
stopped being an empowering medium for individuals and companies
to reach out to a global audience and became a wasteland of
big business interests and the scattered remains of valuable,
informative sites whose owners could no longer afford the
usurious fees required to maintain them.

Please make the right choice, and maintain the price caps as
they currently are set (with a modest and realistic allowance
for inflation) to protect the rights of tens of millions of
existing domain name owners, and those of the hundreds of
millions to come.

Yours sincerely,

Edwin Hayward
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