OPPOSES proposed .ORG agreement changes

[Adam Strong <strongvisuals@xxxxxxxxx>]

To the ICANN Board, 

The proposed TLD Registry Renewal Contracts for .info,
.biz, and .org domains have a  
seriously flawed component whereby the registries will
be able to operate without price 
controls.  It is my belief that this proposed lifting
of price caps will create a potential 
scenario that would be financially devasting to my
business and to the business models 
of millions of business owners that own domains, not
to mention the millions of non-
profits and individual domain name owners who don't
use the internet for a business 
profits. 

The impact will be especially damaging to .org and
.info domain owners and site  
operators who for the most part use .org and .info
domains for non-profit, charitable  
organizations, and educational purposes. 

Hundreds of billions of dollars have been invested
into the core domain name 
infrasctructure of the Internet with the secured
expectation that acquiring, owning and  
maintaining domains would always be affordable and
make economic sense for a long  
term investment.  Under the proposal, a domain owner
is left with no sense of security 
in the stability of the DNS system. The contract
proposal allows one company, the 
registry, at their whim, the ultimate control of what
price each individual domain is 
charged. So suddenly every user of domains is faced
with the inevitable consequences 
that this proposed contract will create, the domain
name they own might suddenly 
become unaffordable.  

For ICANN to enable, facilitate and create such an
obvious way for registries to 
financially exploit and gouge the marketplace would
not only be a business tragedy, but 
it goes against the grain of all the base principles
upon which the Internet, and to my 
knowledge, ICANN was conceived.  The lack of certainty
on pricing will surely deter 
entrepreneurs and small businesses from investing and
innovating their businesses 
online.  No company or individual would build their
business on this "shaky foundation" . 
Additionally, the vast multitude of current domain
owners and web site operators could 
inevitably be run out of business if the expected
costs of doing business skyrocketed 
on every domain they own.  

Removing price caps not only creates an unstable
market, it also creates a 
marketplace where extortion and bribery would be left
to occur without recourse.  It is 
clear that the registries have become educated about
the value of that which they 
control, domains.  Left with no pricing control they
will inevitably seek to maximize the 
revenue of the domain space they are controlling. What
benefit does this provide to the 
internet users ?

Obviously, the flaw in allowing the registry to set
prices would give an unfair economic 
advantage to individuals and corporations who have
substantial capital resources who 
could outbid  less fortunate and startup entrepreneurs
with limited capital.  
Hypothetically under this proposal, my competition
could approach the registry and 
propose that they are willing to pay an exorbitant
amount of money to take over 
ownership of the domain name I currently own upon the
renewal date. What is to stop 
the registry from deciding that my domain name is now
going to cost this amount ?  
What choice do I have but to pay ?  The lack of price
controls creates a monopolistic 
empire where small businesses and individuals are left
to "do or die" . 

Inevitably the progress and innovation that we've seen
accomplished since the creation 
of the internet by many of these same small
businesses, entrepreneurs and individuals 
will be quickly halted under this proposal. The growth
and success of the internet as we 
continue in to the future should be based on "stable
ground" and security of price 
controls.  The functions of maintaining the dns and
registry are utiltarian functions and 
should be controlled in the same way, with price caps
that are regulated and approved 
by ICANN or another oversight group.  

Without a wholesale price, the registry will be free
to "innovate". The innovation they will 
come up with first will be determining what specific
domains are worth and basing their 
fees accordingly on a domain by domain basis. This is
the first innovation that will come 
out of this contract and it in no way will be
"practicable and beneficial in the public 
interest."

Therefore, I respectfully request that you reconsider
and reconstruct the contracts to 
completely remove the clause pertaining to no price
caps . 



Adam Strong
President, Strong Inc
www.strong.net
 






__________________________________________________
Do You Yahoo!?
Tired of spam?  Yahoo! Mail has the best spam protection around 
http://mail.yahoo.com