Please rework the proposed contract

[Russ Goodwin <russ@xxxxxxxxxxxxx>]

Dear ICANN Board of Directors, Dr. Paul Twomey, and Edward G. Viltz-

The proposed agreement for the .ORG registry is flawed and should be reworked.

It is irresponsible for ICANN to agree to a perpetually renewing 
contract when ICANN is charged with fostering competition in the 
domain name system.  ICANN must be permitted to solicit competing 
bids from other potential registry operators and be free to award the 
contract to whomever it deems most suitable to operate the 
registry.  The proposed agreement provides only for termination in 
the event Public Interest Registry breaches the agreement and does 
not resolve the breach after arbitration.

This form of renewal affords Public Interest Registry perpetual 
monopoly status over the .ORG gtld provided it honors the terms of 
the proposed agreement.

The existence of other gtld's (no matter how many there are now or 
may be in the future) does not provide sufficient competition, as 
each domain name is unique within its respective gtld and newer 
gtld's are not well recognized or well regarded 
worldwide.  Increasing the number of gtlds only increases the costs 
to businesses that wish to protect their intellectual property in all 
tld's, it does not drive down the prices of existing gtld's (the 
prices of .com, .net, and .org domain names have not fallen since the 
introduction of the .biz, .info namespaces).

Further, ICANN's lack of price control over the monopoly created by 
the proposed agreement is troubling.  For ICANN to award Public 
Interest Registry the unlimited right to set prices would be an 
abdication of its responsibility to all its stakeholders.

In recent years we have seen prices for Internet access and telephone 
service fall in the United States.  Additionally, retail prices for 
domain names have fallen as more registrars have entered the 
marketplace.  Lower prices and greater competition are better for 
consumers and have not resulted in a less-stable telephone, Internet, 
or domain name infrastructure.  Instead they have lead to 
unprecedented growth in consumption of telecommunications and related services.

ICANN must work to keep operation of the .ORG registry open to 
competition and as transparent as possible while maintaining or 
lowering the prices of .ORG domain names to foster competition and 
increase consumption and public acceptance of the gtld.

Thank you for considering my comments.

Sincerely,

Russ Goodwin
President
The Tidewinds Group, Inc.