ICANN ICANN Email List Archives


<<< Chronological Index >>>    <<< Thread Index >>>

Opposed to Proposed .BIZ Registry Agreement

  • To: biz-tld-agreement@xxxxxxxxx
  • Subject: Opposed to Proposed .BIZ Registry Agreement
  • From: "Dan C. Rinnert" <dcr@xxxxxxxxxxxxxxxxxx>
  • Date: Sun, 27 Aug 2006 01:29:45 -0400

Sunday, August 27, 2006

To the ICANN Board of Directors:

As a domain name registrant and web site developer, I am opposed to the new .BIZ Registry Agreement as currently proposed.

First, I am opposed to the elimination of pricing controls. I support free markets, but when a single registry has control over a specific gTLD, such as .BIZ, there is no free market. Competition normally helps to regulate pricing, but here there is no competition. If you want a .BIZ domain, or want to keep one you already have, you have no other choice but Neulevel.biz.

There is no competition in the .BIZ name space, except by the choice of registrar. But, when the .BIZ registry operator determines the base price of a domain on variable-by-domain pricing, your choices may be limited to a registrar charging $5,008.95 or a registrar charging $5,034.99, which is really little choice at all.

Businesses need to be able to be able to anticipate, as accurately as possible, and budget for their expenses in a quarter or year. Price increases based on inflation, cost of living, etc. can, to some degree, be predicted and planned for. However, if domain name renewals jump from $10 per year to $10,000 per year, that's an extraordinary price increase that can not easily be predicted. Even the price of oil does not fluctuate to those degrees.

What incentive is there for a small business to build a web site, to develop compelling content, to create new innovative applications and so on, when they can lose their domain name when the registry decides that their domain name is more valuable than another? The registry operators should not be in the business of valuating domain names! The registry operators do not promote the domain name, they do not add value to the domain name, they provide the same service for a standard domain name as they do for a "premium" domain name. Why should they be entitled to any portion of the value that the domain name registrant created either by developing useful content or by simply choosing a valuable domain name that no one else thought to register?

If a registry operator wants to be in the domain name speculation business, then they should first drop out of the registry operation business.

Second, I am opposed to the traffic data provision. The traffic data provision allows the registry operator to collect "traffic data regarding domain names or non-existent domain names for purposes such as, without limitation, ... promoting the sale of domain names...." This would seem to allow registry operators to calculate renewal rates based on traffic. What other use would this data have for them?

If traffic data were to be used for such purposes, what would preclude a business from artificially driving up a competitor's web site traffic to raise their renewal rates? They could send poor quality traffic. And, even if the traffic does convert, a big business could afford a temporary drop in sales if it meant the possibility of driving a small competitor out of business.

Third, I am opposed to presumptive renewal. Renewal needs to be explicit. It is also troubling that, as mentioned in GoDaddy.com's comments, the new agreements omit provisions that the registry be able to provide a "substantial service to the Internet community" and that they are "qualified to operate the Registry TLD during the renewal term." Under the current .COM registry agreement (section 25.B (b) and (c)), the registry operator is considered in breach of the agreement if they fail to meet those qualifications. The proposed .BIZ, .INFO and .ORG agreements as currently written do not contain those provisions. This would seem to indicate that, even if the registry operator failed to meet those conditions, their agreement would still be renewed for another term.

The aforementioned provisions fail to live up to ICANN's mission statement to "promoting competition" and "to achieving broad representation of global Internet communities." These provisions do not promote competition, but instead allow for big businesses to dominate the .BIZ domain space, as small businesses may find they can no longer afford to renew their "premium" domain names. These provisions fail to achieve "broad representation of global Internet communities." Small businesses in poorer countries or in countries with devalued currency will also no longer afford to renew their "premium" domain names.

The proposed .BIZ registry agreement as currently written should not be approved.


Dan C. Rinnert

<<< Chronological Index >>>    <<< Thread Index >>>

Privacy Policy | Terms of Service | Cookies Policy