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Comments on TLD Registry Renewal Contracts

  • To: <biz-tld-agreement@xxxxxxxxx>
  • Subject: Comments on TLD Registry Renewal Contracts
  • From: "David Blackwood" <dblackwood@xxxxxxxxxxxxxxx>
  • Date: Mon, 28 Aug 2006 15:46:53 -0400

To the ICANN Board:


The proposed TLD Registry Renewal Contracts for .info, .biz, and .org domains 
are seriously flawed. Allowing scaled pricing on a per-domain basis would be 
extremely poor policy, and would leave owners of established domain names 
vulnerable to unfair pricing practices. Scaled pricing, would, in essence, 
allow the registry to "tax" the brand equity and goodwill built up in a 
web-based business, and this would be tantamount to extortion. Scaled pricing 
might make sense for a new TLD upon launch, where would-be domain holders know 
the rules upfront and can make decisions accordingly, but certainly not for 
established TLDs where substantial investment has already taken place. The 
.org, .info, and .biz TLDs have been in operation for years, and allowing a 
structural pricing change at this stage would be an unacceptable breach of 
public trust.


In perusing responses, Verisign appears to the sole supporter of the contract 
drafts as written. While disappointing, this is hardly surprising given their 
track record of attempting to lever their own monopoly position. The notion 
that registries compete with one another in any non-trivial way is patently 
absurd; that absurdity is evidenced by the fact that Verisign is demonstrating 
solidarity with its "competitor" registry on this issue, years in advance of 
its own contract renewal. Undoubtedly, Verisign would relish the opportunity to 
foist the scaled pricing disaster on .com and .net domain owners as well. Once 
again, this is a fox offering advice on how to regulate the henhouse. Such 
advice should be dismissed out of hand, because it is a blatant conflict of 


The only thing worse than a monopoly is an unregulated monopoly. ICANN needs to 
do its job as regulator, maintain the public trust, and not allow the 
introduction of scaled pricing to established TLDs.


David Blackwood

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