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Summary of Public Comments

  • To: "pro-tld-amendment@xxxxxxxxx" <pro-tld-amendment@xxxxxxxxx>
  • Subject: Summary of Public Comments
  • From: Craig Schwartz <craig.schwartz@xxxxxxxxx>
  • Date: Sat, 18 Jul 2009 08:00:53 -0700

Summary of public comments for:

RegistryPro Proposed Fee Amendment

Comment period opened: 17 June 2009

Comment period closed: 17 July 2009


The public comment period was created to provide an opportunity for the 
Internet community to comment on RegistryPro's proposed fee amendment that 
would reduce the fees it pays ICANN.

In its 17 June 2009 letter to ICANN (see, 
RegistryPro stated, "The .PRO TLD currently has nearly 36,000 registrations and 
we feel the number will continue to increase if RegistryPro is better 
positioned to invest in various growth strategies that might make .PRO names 
more accessible to the community. However, the current fee structure is 
burdensome given the size of the TLD and is disproportionally high compared to 
the fees other registries pay to ICANN. A lower fee would enable the registry 
to invest in marketing and branding initiatives that will make us competitive 
with other similarly sized registries. Further, resources that would be 
available for these new initiatives would enable RegistryPro to continue to 
grow in its ability to answer to the demands of the community of registrars 
(e.g., promotions and end-user marketing campaigns, etc.), potential 
registrants and ICANN."

The proposed contract amendment provides for a fee structure that is similar to 
what is currently in the draft new gTLD Registry Agreement. The proposal 
includes an annual fixed fee of US$10,000 year and US$0.20 per billable 
transaction after the registry has 50,000 domain registrations.

The .PRO Registry Agreement is due to expire on 27 May 2010 and the renewal 
agreement will contain a provision for the registry to come in line with the 
fees structure proposed for new gTLDs. The current draft new gTLD Registry 
Agreement provides for an annual fixed fee of US$25,000 and US$0.25 per 
billable transaction after the registration has 50,000 domain registrations.


A total of four comments were received and one was a duplicate entry. Of the 
three unique comments, two were supportive (Andrew Campbell and Thomas Barrett) 
and one was not supportive (George Kirikos). Public comments in their entirety 
can be viewed at http://forum.icann.org/lists/pro-tld-amendment/.

Andrew Campbell commented that the annual charge to RegistryPro (US$121,900) is 
excessive for a registry of 36,000 names and should be brought in line with 
terms being offered to new gTLDs. He further commented that there is interest 
in the .PRO TLD which is evidenced by the five-fold increase in registrations 
in the past 10 months and that a reduction in fees would enable RegistryPro to 
invest in marketing the TLD. Lastly, Mr. Campbell noted "ICANN should not be 
introducing new gTLD's while existing gTLD's like .pro are still lightly 
registered and burdened with uncommercial restrictions and fee structures."

Thomas Barrett's comment included publicly available information about other 
registries' fees structures and their registration levels to demonstrate that 
RegistryPro's fees are excessive relative to the size of the .PRO TLD. He 
remarked that, "Changing the fee model that RegistryPro uses to pay ICANN will 
help level the playing field for the .pro gTLD compared to the other ICANN 
TLD?s and provide for a more competitive TLD marketplace."

George Kirikos stated he "Opposes the contract amendment for .pro to 
unilaterally lower their fees." Mr. Kirikos challenges the demand for and 
viability of .PRO and stated that ".pro is a failed registry, with only 36,000 
registrations after six years." He further commented that "If RegistryPro can't 
meet their obligations, they should go out of business, or have the TLD 
delegated to another registry operator." Similarly to Andrew Campbell, Mr. 
Kirikos challenges the viability of new TLDs stating "new gTLDs are a bad idea."


This summary of public comments will be used to inform the ICANN staff's 
recommendation about the proposal to the Board of Directors. The proposed 
contract amendment is to be considered by the Board of Directors.

Craig Schwartz
Chief gTLD Registry Liaison

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