.org registry concerns

["Michael Gilmour" <mgilmour@xxxxxxxxxxxxxxxxxxx>]

Hi,
I wish to express my concerns regarding the proposed "Lifting of Price
Controls on Registry Services" for the .info registry.
 
I believe that the existing proposal can lead to the following issues in the
domain name market place that are contrary to ICANN's charter:
 
1. I am unsure why this particular clause has been entered into the debate.
The existing domain pricing system is allowing ample business opportunities
for the registries and registrars with no threat to the underlying Internet
infrastructure. If the existing registries are indicating that they are
unable to make a reasonable profit then put the registry agreement out for
tender so that a suitable new registry could be found which is more cost
effective as well as providing the technical expertise.
 
2.  Pricing of domains on a domain by domain basis - By having the registry
able to set the price of domains then individual domain owners could be
extorted to paying higher fees. For example, Google could be told that to
re-register google.biz it will cost $1m while asdfgbcs.biz costs $6. Given
that a domain name is the same product the inconsistent pricing regime will
provide a doorway for extorting large sums of money from valuable trademark
owners. I would not be surprised if both the registry and ICANN come under
intense scrutiny if their "monopolistic powers" are exploited in such a
fashion.
 
3. Retarding growth - Potentially, young Intenet businesses could be
penalised as they become more successful with an increase in their
registration fees. Ultimately, they could be asked to pay a percentage of
the goodwill in their balance sheets to the registry.
 
4. A part of the ICANN charter is to promote the Internet via domains etc.
and to provide an environment that increases the use of domains. How is the
increase in pricing going faciliate this goal?
 
5. The 6 month time window for business to react is irrelevant as an
increase in prices will still be an increase and the uncertainty introduced
into a fundamental layer of the Internet will potentially retard the
investment that has spurred the growth to date.
 
In closing, if the governmental business name registration organisation
decided to increase ICANN's registration fee to $1M/year then how would
ICANN react? I am sure that there would be many legal letters sent out
between the two parties. The facts are everyone expects a business to make a
reasonable profit but businesses that are in a unique position like the
registry and ICANN will come under increasing levels of scrutiny if the
"Lifting of Price Controls on Registry Services" is approved. Domain owners
and Internet businesses will not be able to afford to ignore this issue as
unlike many ICANN decisions it directly impacts the bottom line of their
investments.
 
If you have any questions as to the points that I have raised then please do
not hesitate to contact me.
 
Regards,
 
Michael Gilmour
CEO - Simcast Media
 
-----------------------------------------------
Michael Gilmour
Simcast Media Pty Ltd
Tel: +61 3 9511 8568   Fax: +61 3 9511 8567
Web: http://www.simcastmedia.com.au <http://www.simcastmedia.com.au/>