DAGv3 comments (part 2) by Leap of Faith Financial Services Inc.
DAGv3 Comments (part 2) by Leap of Faith Financial Services Inc. Submitted By: George Kirikos Company: Leap of Faith Financial Services Inc. Company URL: http://www.leap.com/ Date: November 22, 2009 In addition to our prior comments of today: http://forum.icann.org/lists/3gtld-guide/msg00085.html we'd like to add a specific comment regarding the pricing caps issue (we did not dissect the guidebook line by line, as the entire set of documents is an abomination that shouldn't have credibility within the community). For prices charged to consumers, the current language is at 2.10 (page 4) of: http://www.icann.org/en/topics/new-gtlds/draft-agreement-specs-clean-04oct09-en.pdf It's still not enough. It still allows unrestricted prices, because there's a loophole "Registry Operator shall offer all domain registration renewals at the same price, unless the registrant agrees to a higher price at the time of the initial registration of the domain name following clear and conspicuous disclosure of such renewal price by Registry Operator." which they put in square brackets for some reason. Namely, the registries will simply have everyone agree that they could change the price at any time in their agreements that no one (except people like me) ever reads. Althernatively, they could raise the price for everyone by the same amount (e.g. make all renewals be $1000, or whatever), but then provide hidden discounts to others under the table, etc. There needs to be *hard caps*, e.g. no more than twice the .com price, for example. Under the current language, for example, VeriSign (using the equitable treatment clause) could uniformly raise the price of all .com domain renewals to $50 or $100. ICANN and the pro-TLD advocates talk about how all this "new competition" is going to benefit consumers through lower prices. Instead of talking the talk, they should "walk the walk" by putting in the hard caps. Hard caps only negatively affect registries that want to *raise* prices. It doesn't hurt those legitimate registries who go into the game telling everyone that they'll be lowering prices for consumers. In other words, the only people who hard caps are going to negatively affect are the pro-TLD advocates who are lying to the public about the benefits of new TLDs, the ones who have their fingers crossed behind their backs and are talking about "lower prices" with a "wink" to their pals at ICANN. Hard caps are a must to maximize benefits to the public, and indeed the registry operations should be regularly tendered through open competition like any other procurement contract (i.e. the concept of "presumptive renewal" for registry operators should be eliminated). The only "presumptive renewal" rights should belong to *registrants* who keep paying their *normal* fees, without being gouged by monopolist registry operators. Sincerely, George Kirikos http://www.leap.com/