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GoDaddy’s next .xxx contract may not be a done deal

Kevin Murphy, March 18, 2024, Domain Policy

ICANN has published what could be the next version of GoDaddy’s .xxx registry contract, and is framing it as very much open to challenge.

The proposed Registry Agreement would scrap the “sponsored” designation from .xxx, substantially reduce GoDaddy’s ICANN fees, and implement the strictest child-protection measures of any gTLD, as well as make ICANN Compliance’s job a lot easier by standardizing terms on the new gTLD program’s Base RA.

But, as eager as ICANN usually is to shift legacy, pre-2012 gTLDs to the Base RA, this time it’s published the contract for public comment as if it’s something GoDaddy is unilaterally proposing.

It’s “ICM’s proposal”, according to ICANN’s public comment announcement, referring to GoDaddy subsidiary ICM Registry, and “ICM has requested to use the Base Registry Agreement form, as well as to remove the sponsorship designation of the .XXX TLD”.

This is not the language ICANN usually uses when it publishes RA renewals for public comment. Normally, the proposed contracts are presented as the result of bilateral negotiations. In this case, ICANN and ICM have been in renewal discussions for at least three years, but the contract is being presented as something GoDaddy alone has asked for.

The new RA would remove almost all references to sponsorship and to IFFOR, the pretty much toothless “sponsor” organization ICM created to get its .xxx application over the line under the rules of the Sponsored TLD application round that kicked off back in 2003.

Instead, it loads a bunch of Public Interest Commitments, aimed at replicating some of the safeguards IFFOR oversight was supposed to provide, into the Base RA.

GoDaddy would have to ban and proactively seek out and report child sexual abuse material. It would also prohibit practices that suggest the presence of CSAM, such as the inclusion of certain unspecified keywords in .xxx domains or in the corresponding web site’s content or meta-content.

(ICANN notes that these PICs may become unenforceable, depending on the outcome of current discussions about its ability to enforce content-related terms of its contracts).

GoDaddy and IFFOR have both submitted letters arguing that sponsorship is no longer required. The existence of sister gTLDs .adult, .sex, and .porn as unsponsored gTLDs, also in the GoDaddy Registry stable, proves the extra oversight is not needed, they say. Registrants polled do not object to the changes, they say.

GoDaddy’s cost structure would also change under the new deal. Not only would it save $100,000 a year by cutting off IFFOR, but it would also inherit the Base RA’s 50,000-domain threshold for paying ICANN transaction fees.

This likely means it won’t pay the $0.25 transaction fee for a while — .xxx was at about 47,500 domains under management and shrinking at the last count. It hasn’t reported DUM over 50,000 since January 2023.

While the renewal terms may seem pragmatic and not especially unreasonable, they’ve already received at least one public objection.

Consultant Michael Palage, who was on the ICANN board for the first three years of .xxx’s agonizing eight-year path to approval, took to the mic at the ICANN 79 Public Forum earlier this month to urge the board to reject GoDaddy’s request.

Palage said there have been “material violations of the Registry Agreement” that he planned to inform ICANN Compliance about. He added that approving the new deal would set a bad precedent for all the other “community” registries ICANN has contracts with.

The situation has some things in common with the controversy over the proposed acquisition of Public Internet Registry and .org a few years ago, in that the proposal entails ignoring promises made by a registry two decades ago.

Whether .xxx will attract the same level of outrage is debatable — this deal doesn’t involve nearly as many domains and does not talk to the price registrants pay — but it could attract noise from those who believe ICANN should not throw out its principles for the sake of a quieter life.

One place we might look for comment is the Governmental Advisory Committee, which was the biggest reason .xxx took so long to get approved in the first place.

But the timing of the comment period opening is interesting, coming a week after ICANN 79 closed. It will end April 29, about six weeks before the full GAC next meets en masse, at ICANN 80.

It’s not impossible that the new contract could be approved and signed before the governments get a chance to publicly haul ICANN’s board over the coals.

ICANN actually CHANGES Verisign’s .net contract after public comments

Kevin Murphy, June 28, 2023, Domain Policy

ICANN has decided to make a change to the upcoming new version of Verisign’s .net registry agreement in response to public comments, but it’s not the change most commenters wanted.

In the near-unprecedented nod to the public comment process, the Org says it’s agreed with Verisign to change two instances of upper-case “S” in the term “Security and Stability” to lower case.

That’s it.

Some commenters had wrung their hands over the fact that the .net contract includes upper-case “Security and Stability” as defined terms, in contrast to the lower-case “security and stability” found in other gTLD contracts.

Based on a strict reading, this could in some circumstances give Verisign an excuse to avoid implementing ICANN Consensus Policies, commenters including the Business Constituency and Intellectual Property Constituency noted,

It appears that this was an oversight by ICANN and Verisign rather that some kind of nefarious plot. In its public comments analysis and summary (pdf), ICANN writes:

We acknowledge however that the capitalization of the “s” could in theory potentially lead to different interpretations of the applicability of certain future Consensus Policies under Section 3.1(b)(iv)(1) for the .NET RA.

Because in this instance it was not the intent of ICANN org nor Verisign to limit in this manner the applicability of Consensus Policy topics for which uniform or coordinated resolution is reasonably necessary to facilitate the interoperability, security and/or stability of the Internet or DNS, ICANN org and Verisign have mutually agreed to update Section 3.1(b)(iv)(1) of the .NET RA to the lower case “s.”

So there we have it: a rare instance of a public comment period accomplishing something and a confirmed victory for accountability and transparency!

Most of the comments had focused on Verisign’s ability to raise prices and a clause that some domainers thought would allow censorial government regimes to seize domains, but ICANN said that’s all fine.

Everyone hates Verisign’s new .net deal

Kevin Murphy, May 26, 2023, Domain Policy

The public has commented: Verisign’s .net registry contract should not be renewed in its currently proposed form.

ICANN’s public comment period for the renewal closed yesterday and attracted 57 submissions, most of which either complained about Verisign being allowed to raise its prices or expressed fears about domains being seized by governments.

The proposed contract retains the current pricing structure, in which Verisign is allowed to raise the price of a .net domain by 10% a year. They currently cost $9.92, meaning they could reach $17.57 by the time the contract ends.

The Internet Commerce Association, some of its supporters, Namecheap, the Registrars Stakeholder Group, the Cross-Community Working Party on ICANN and Human Rights (CCWP-HR), and TurnCommerce all oppose the price increases.

The RrSG said the price provisions “are without sufficient justification or an analysis of its potentially substantial impact on the DNS”.

These commenters and others who did not directly oppose the increases, including the At-Large Advisory Committee and consultant Michael Palage, called for ICANN to conduct an economic analysis of the domain name market.

The Business Constituency was the only commenter to openly support the increases, though its comment noted that it is opposed in principle to ICANN capping prices at all.

The Intellectual Property Constituency did not express a view on pricing, but called for greater transparency into the side-deal that sees ICANN get an extra $4 million a year for unspecified security-related work. ICANN has never revealed publicly how this money is spent.

In terms of the number of submissions, the biggest concern people seem to have is that the proposed contract contains language obliging Verisign to take down domains to comply with “applicable law, government rules or regulations, or pursuant to any legal order or subpoena of any government, administrative or governmental authority, or court of competent jurisdiction”.

This language is already in the .com contract, but before ICANN clarified this on April 26 several concerned registrants had made comments opposing its inclusion.

Notably, the founder of the controversial troll forum kiwifarms.net, which has been kicked out of registrars after being linked to suicides, submitted his own “ICANN should be destroyed” comment.

Several commenters also noted that the definition of “security and stability” in the .net contract differs to the Base Registry Agreement that almost all other registries have signed in such a way that it is feared that Verisign would not have to abide by future ICANN Consensus Policies under certain circumstances.

As several commenters note, the usual protocol following an ICANN public comment period is for ICANN to issue a summary report, pay lip service to having “considered” the input, and then make absolutely no changes at all.

This time, some commenters held out some hope that ICANN’s new, surprisingly sprightly and accommodating leadership may have a different approach.

The comments can be read here.

Verisign’s .net contract up for public comment

Kevin Murphy, April 13, 2023, Domain Registries

ICANN intends to renew Verisign’s contract to run the .net gTLD and has opened the revised deal for public comment.

At first glance, there doesn’t appear to be anything massively controversial about the proposed changes, so we probably shouldn’t expect the same kind of outrage similar contract renewals have solicited in the past.

A great deal of the changes relate to the sunsetting of the Whois protocol and its replacement with the functionally similar RDAP, something set to become part of all gTLD contracts, legacy and new, soon.

The only money-related change of note is the agreement that Verisign will pay pro-rated portions of the $0.75 annual ICANN transaction fee when it sells its Consolidate service, which allows registrants to synchronize their expiry dates for convenience.

That provision is already in the .com contract, and Verisign has agreed to back-date the payments to May 1, 2020, around about the same time the .com contract was signed.

The controversial side-deal under which Verisign agreed to pay ICANN $4 million a year for five years is also being amended, but the duration and amount of money do not appear to be changing.

The new Registry Agreement also includes Public Interest Commitments for the first time. Verisign has agreed to two PICs common to all new gTLD RAs governing prohibitions on abusive behaviors.

The deal would extend Verisign’s oversight for six years, to June 30, 2029. It’s open for public comment until May 25.

Non-coms want .org’s future carved in stone

Kevin Murphy, December 12, 2019, Domain Registries

ICANN’s non-commercial stakeholders have “demanded” changes to Public Interest Registry’s .org contract, to protect registrants for the next couple of decades.
The NCSG sent a letter to ICANN chair Maarten Botterman this week which stopped short of demanding, as others have, that ICANN reverse its decision to unfetter PIR from the 10%-a-year cap on prices increases it has previously been subject to.
Instead, it asks ICANN to strengthen the already existing notification obligations PIR has when it increases prices.
Today, if PIR wants to up its fee it has to give its registrars six months notice, and registrants are allowed to lock in the current pricing by renewing for up to 10 years.
NCSG wants to ensure registrants get the same kind of advance notification, either from PIR or its registrars, and for the lock-in period doubled to 20 years.
The group is concerned that, now that PIR seems set to become a for-profit venture following its $1.135 billion acquisition by Ethos Capital, there’s a risk the registry may attempt to exploit the registrants of its over 10 million .org domains.
I think it unlikely that ICANN, should it pay any attention at all to the letter, will agree to the 20-year renewal ask, given that the contract only runs for 10 years and that gTLD registries are forbidden from selling domains for periods of longer than a decade.
It would require adjustments with other parts of the contract, such as transaction reporting requirements, and would probably need some industry-wide tinkering with the EPP registry protocols too.
In some respects, the stance on pricing could be seen as a softening of NCSG’s previous position.
In April, it said that price caps should remain, but that they should be increased from the 10% a year level. If that view remains, the letter does not restate it.
The NCSG also wants the oft-criticized Uniform Rapid Suspension policy removed from the .org contract, on the basis that it was only ever supposed to be applied to gTLDs applied for in the 2012 round and not legacy gTLDs.
URS has been incorporated in all but one of the legacy gTLD contracts that have been renewed since 2012.
Finally, NCSG asks that ICANN essentially write the US First Amendment into the .org agreement, writing that it wants:

A strong commitment that the administration of the ORG domain will remain content-neutral; that is, the registry will not suspend or take away domains based on their publication of political, cultural, social, ethnic, religious, and personal content, even untrue, offensive, indecent, or unethical material, like that protected under the U.S. First Amendment.

The fear that a .org in commercial hands will be more susceptible to censorship pressures is something that the Electronic Frontier Foundation has also recently raised.
The basis for the NCSG’s demands are rooted in the original redelegation of .org from Verisign to PIR in early 2003, which came after a competitive bidding process that saw PIR beat 10 rival applicants, partly on the basis of its commitment to non-profit registrants.
You may recall I did a deep-dive into .org’s history last week that covered what was said by whom during that process.
NCSG writes:

The ORG situation is unique because of its origins in a competitive RFP that was specifically earmarked for noncommercial registrants. How ICANN handles this case, however, will have enormous precedential consequences for the stability of the DNS and ICANN’s own reputation and status. Changes in ownership are likely to be increasingly common going forward. Domain name users want stability and predictability in their basic infrastructure, which means that the obligations, service commitments and pricing cannot be adjusted dramatically as ownership changes.

NCSG’s letter has not yet been published by ICANN, but the Internet Governance Project’s Milton Mueller has copied its text in a blog post here.

.org now has no price caps, but “no specific plans” to raise prices

ICANN has rubber-stamped Public Interest Registry’s new .org contract, removing the price caps that have been in effect for the best part of two decades.
That’s despite a huge outcry against the changes, which saw the vast majority of respondents to ICANN’s public comment period condemn the removal of caps.
The new contract, signed yesterday, completely removes the section that limited PIR to a 10% annual price increase.
It also makes PIR pay the $25,000 annual ICANN fee that all the other registries have to pay. Its ICANN transaction tax remains at $0.25.
PIR, a non-profit which funnels money to the Internet Society, is now allowed to raise its wholesale registry fee by however much it likes, pretty much whenever it likes.
But PIR again insisted that it does not plan to screw over the registrants of its almost 11 million .org domains.
The company said in a statement:

Regarding the removal of price caps, we would like to underscore that Public Interest Registry is a mission driven non-profit registry and currently has no specific plans for any price changes for .ORG. Should there be a need for a sensible price increase at some point in the future, we will provide advanced notice to the public. The .ORG community is considered in every decision we make, and we are incredibly proud of the more than 15 years we have spent as a responsible steward of .ORG. PIR remains committed to acting in the best interest of the .ORG community for years to come.

That basically restates the comments it made before the contract was signed.
The current price of a .org is not public information, but PIR has told me previously that it’s under $10 a year and “at cost” registrar Cloudflare sells for $9.93 per year.
The last price increase was three years ago, reported variously as either $0.88 or $0.87.
ICANN received over 3,200 comments about the contract when it was first proposed, almost all of them opposed to the lifting of caps.
Opposition initially came from domainers alerted by an Internet Commerce Association awareness campaign, but later expanded to include general .org registrants and major non-profit organizations, as the word spread.
Notable support for the changes came from ICANN’s Business Constituency, which argued from its established position that ICANN should not be a price regulator, and from the Non-Commercial Stakeholders Group, which caps should remain but should be raised from the 10%-a-year limit.
There’s a bit of a meme doing the rounds that ICANN has been hit by “regulatory capture” in this case, following a blog post from ReviewSignal.com blogger Kevin Ohashi last week, which sought to demonstrate how those filing comments in favor of the new contract had a vested interest in the outcome (as if the thousands of .org registrants filing opposing comments did not).
But I find the argument a bit flimsy. Nobody fingered by Ohashi had any decision-making power here.
In fact, the decision appears to have been made almost entirely by ICANN employees (its lawyers and Global Domains Division staff) “in consultation with the ICANN board of directors”.
There does not appear to have been a formal vote of the board. If there was such a vote, ICANN has broke the habit of a lifetime and not published any details of the meeting at which it took place.
After the public comment period closed, ICANN senior director for gTLD accounts and services Russ Weinstein prepared and published this comment summary (pdf), which rounds up the arguments for and against the proposed changes to the contract, then attempts to provide justification for the fait accompli.
On the price caps, Weinstein argues that standardizing .org along the lines of most of the other 1,200 gTLDs in existence fits with ICANN’s mission to enable competition in the domain name industry and “depend upon market mechanisms to promote and sustain a competitive environment”.
He also states:

Aligning with the Base gTLD Registry Agreement would also afford protections to existing registrants. The registry operator must provide six months’ notice to registrars for price changes and enable registrants to renew for up to 10 years prior to the change taking effect, thus enabling a registrant to lock in current prices for up to 10 years in advance of a pricing change.

This appears to be misleading. While it’s true that the new contract has the six-month notice period for price increases, so did the old one.
The new contract language takes several sentences to say what the old version did in one, and may remove some ambiguity, but both describe the notice period and lock-in opportunity.
If there’s a problem with how the new .org contract was signed off, it appears to be the lack of transparency.
It’s signed by GDD senior VP Cyrus Namazi, but who made the ultimate decision to sign it despite the outrage? Namazi? CEO Göran Marby? It certainly doesn’t seem to have been put before the board for a formal vote.
What kind of “consultation” between GDD and the board occurred? Is it recorded or noted anywhere? Was the board briefed about the vast number of negative comments the price cap proposal elicited?
Are public comment periods, which almost never have any impact on the end result, just a sham?
In my view, .org (along with .com and .net) are special cases among gTLDs that deserve a more thorough, broad and thoughtful consideration than the new .org contract received.
UPDATE: This article was updated at 1600 UTC to correct information related to .org’s current wholesale price.

Non-coms say .org price cap should be RAISED

Kevin Murphy, April 30, 2019, Domain Registries

With the entire domain name community apparently split along binary lines on the issue of price caps in .org, a third option has emerged from a surprising source.
ICANN’s Non-Commercial Stakeholders Group has suggested that price caps should remain, but that they should be raised from their current level of 10% per year.
In its comments to ICANN (pdf), NCSG wrote that it would “not object to the price cap being raised by a reasonable level”, adding:

Rather than removing price caps from the agreement entirely, these should be retained but raised by an appropriate amount. In addition, this aspect of the contract should be subject to a review midway through the contract, based on the impact of the price changes on non-profit registrants.

The NCSG does not quote a percentage or dollar value that it would consider “reasonable” or “appropriate”.
The letter notes that Public Interest Registry, which runs .org, uses some of its registration money to fund NCSG’s activities.

The NCSG disagrees with the decision to remove price cap provisions in the current .org agreement. On the one hand, we recognize the maturation of the domain name market, and the need for Public Interest Registry to capitalize on the commercial opportunities available to it. Public Interest Registry, as a non-profit entity, supports many excellent causes (including, it is worth noting, the NCSG). On the other hand, as the home for schools, community organizations, open-source projects, and other non-profit entities that are run on shoestring budgets, this registry should not necessarily operate under the same commercial realities that guide other domains. Fees should remain affordable, with domains which are priced within reach of everyone, no matter how few resources they have. Consequently, we support leaving the price cap provisions in place. We would not object to the price cap being raised by a reasonable level.

Basically, the ICANN community group nominally representing precisely .org’s target market doesn’t mind prices going up, just as long as PIR doesn’t get greedy.
It’s slightly surprising, to me, to find NCSG on the middle ground here.
There are currently over 3,250 comments on the renewal of PIR’s registry contract with ICANN — coming from domainers, individual registrants, and large and small non-profit organizations — almost all of which are firmly against the removal of price caps.
The only comments I’ve been able to find in favor of the scrapping of caps came from the Business Constituency. Intellectual property interests had no opinion.
I don’t believe the registries and registrars stakeholder groups filed consensus comments, but Tucows did file an individual comment (pdf) objecting to the removal of caps.

ICA rallies the troops to defeat .org price hikes. It won’t work

Kevin Murphy, April 25, 2019, Domain Registries

Over 100 letters have been sent to ICANN opposing the proposed lifting of price caps in .org, after the Internet Commerce Association reached out to rally its supporters.
This is an atypically large response to an ICANN public comment period, and there are four days left on the clock for more submissions to be made, but I doubt it will change ICANN’s mind.
Almost all of the 131 comments filed so far this month were submitted in the 24 hours after ICA published its comment submission form earlier this week.
About a third of the comments comprise simply the unedited ICA text. Others appeared to have been inspired by the campaign to write their own complaints about the proposal, which would scrap the 10%-a-year .org price increase cap Public Interest Registry currently has in place.
Zak Muscovitch, ICA’s general counsel, told DI that as of this morning the form generates different template text dynamically. I’ve spotted at least four completely different versions of the letter just by refreshing the page. This may make some comments appear to be the original thoughts of their senders.
This is the original text, as it relates to price caps:

I believe that legacy gTLDs are fundamentally different from for-profit new gTLDs. Legacy TLDs are essentially a public trust, unlike new gTLDs which were created, bought and paid for by private interests. Registrants of legacy TLDs are entitled to price stability and predictability, and should not be subject to price increases with no maximums. Unlike new gTLDs, registrants of legacy TLDs registered their names and made their online presence on legacy TLDs on the basis that price caps would continue to exist.
Unrestrained price increases on the millions of .org registrants who are not-for-profits or non-profits would be unfair to them. Unchecked price increases have the potential to result in hundreds of millions of dollars being transferred from these organizations to one non-profit, the Internet Society, with .org registrants receiving no benefit in return. ICANN should not allow one non-profit nearly unlimited access to the funds of other non-profits.

The gist of the other texts is the same — it’s not fair to lift price caps on domains largely used by non-profits that may have budget struggles and which have built their online presences on the old, predictable pricing rules.
The issues raised are probably fair, to a point.
Should the true “legacy” gTLDs — .com, .net and .org — which date from the 1980s and pose very little commercial risk to their registries, be treated the same as the exceptionally risky gTLD businesses that have been launched since?
Does changing the pricing rules amount to unfairly moving the goal posts for millions of registrants who have built their business on the legacy rules?
These are good, valid questions.
But I think it’s unlikely that the ICA’s campaign will get ICANN to change its mind. The opposition would have to be broader than from a single interest group.
First, the message about non-profits rings a bit hollow coming from an explicitly commercial organization whose members’ business model entails flipping domain names for large multiples.
If a non-profit can’t afford an extra 10 bucks a year for a .org renewal, can it afford the hundreds or thousands of dollars a domainer would charge for a transfer?
Even if PIR goes nuts, abandons its “public interest” mantra, and immediately significantly increases its prices, the retail price of a .org (currently around $20 at GoDaddy, which has about a third of all .orgs) would be unlikely to rise to above the price of PIR-owned .ong and .ngo domains, which sell for $32 to $50 retail.
Such an increase might adversely affect a small number of very low-budget registrants, but the biggest impact will be felt by the big for-profit portfolio owners: domainers.
Second, letter-writing campaigns don’t have a strong track record of persuading ICANN to change course.
The largest such campaign to date was organized by registrars in 2015 in response to proposals, made by members of the Privacy and Proxy Services Accreditation Issues working group, that would have would have essentially banned Whois privacy for commercial web sites.
Over 20,000 people signed petitions or sent semi-automated comments opposing that recommendation, and ICANN ended up not approving that specific proposal.
But the commercial web site privacy ban was a minority position written by IP lawyers, included as an addendum to the group’s recommendations, and it did not receive the consensus of the PPSAI working group.
In other words, ICANN almost certainly would not have implemented it anyway, due to lack of consensus, even if the public comment period had been silent.
The second-largest public comment period concerned the possible approval of .xxx in 2010, which attracted almost 14,000 semi-automated comments from members of American Christian-right groups and pornographers.
.xxx was nevertheless approved less than a year later.
ICANN also has a track record of not acceding to ICA’s demands when it comes to changes in registry agreements for pre-2012 gTLDs.
ICA, under former GC Phil Corwin, has also strongly objected to similar changes in .mobi, .jobs, .cat, .xxx and .travel over the last few years, and had no impact.
ICANN seems hell-bent on normalizing its gTLD contracts to the greatest extent possible. It’s also currently proposing to lift the price caps on .biz and .info.
This, through force of precedent codified in the contracts, could lead to the price caps one day, many years from now, being lifted on .com.
Which, let’s face it, is what most people really care about.
Info on the .org contract renewal public comment period can be found here.

GoDaddy renewal revamp “unrelated” to domainer auction outrage

Kevin Murphy, November 21, 2017, Domain Registrars

GoDaddy has made some big changes to how it handles expired domain names, but denied the changes are related to domainer outrage today about “fake” auctions.
The market-leading registrar today said that it has reduced the period post-expiration during which registrants can recover their names from 42 days to 30. After day 30, registrants will no longer be able to renew or transfer affected names.
GoDaddy is also going to start cutting off customers’ MX records five days after expiry. This way, if they’re only using their domain for email, they will notice the interruption. Previously, the company did not cut off MX records.
The changes were first reported at DomainInvesting.com and subsequently confirmed by a GoDaddy spokesperson.
One impact of this will be to reduce confusion when GoDaddy puts expired domains up for auction when it’s still possible for the original registrant reclaim them, which has been the cause of complaints from prominent domain investors this week.
As DomaingGang reported yesterday, self-proclaimed “Domain King” Rick Schwartz bought the domain GoDaddyBlows.com in order to register his disgust with the practice.
Konstantinos Zournas of OnlineDomain followed up with a critique of his own today.
But the GoDaddy spokesperson denied the changes are being made in response to this week’s flak.
“This is unrelated to any events in the aftermarket,” he said. “We’ve been working on this policy for more than a year.”
He said the changes are a case of GoDaddy “optimizing our systems and processes”. The company ran an audit of when customers were renewing and found that fewer than 1% of names were renewed between days 30 and 42 following expiration, he said.
GoDaddy renews about 2.5 million domains per month in just the gTLDs it carries, according to my records, so a full 1% would equal roughly 25,000 names per month or 300,000 per year. But the company spokesperson said the actual number “quite a bit less” than that.
How many of these renewals are genuinely forgetful registrants and how many are people attempting to exploit the auction system is not known.
The changes will come into effect December 4. The news broke today because GoDaddy has started notifying its high-volume customers.

Telco billed $2.7 million for failing to renew domain

Kevin Murphy, October 2, 2017, Domain Tech

A US telecommunications provider has agreed to pay $2.7 million after an emergency service went offline because it forgot to renew a domain name.
According to the Federal Communications Commission, Utah-based Sorenson Communications saw its “video relay service” go offline for two days in June 2016 after a domain was not renewed.
The service is basically a 911 emergency calls replaced designed for people with hearing or speech problems.
The settlement (pdf) describes the scenario like this:

Sorenson.com is a domain name Sorenson uses to provide access to SVRS. On the morning of June 6, 2016, Sorenson experienced a VRS Service Interruption that resulted from a preventable, internal operational failure.10 This failure led the domain registration for Sorenson.com to expire and be deactivated. After the deactivation occurred and before Sorenson could correct the situation, some Internet Service Providers (ISPs) updated their records to reflect that the domain was expired. If a user’s ISP updated its records while the domain was shown as expired, that user could not make or receive calls routed through Sorenson.com — including VRS, 911, Dial-Around, and Point-to-Point calls — during at least part of the outage.
Upon discovery of the VRS Service Interruption, Sorenson took immediate steps to correct the problem and notify callers. Once the domain name was reactivated, each caller’s ISP had to take certain steps to ensure that calls were routed through Sorenson.com. To expedite this process, Sorenson reached out to multiple large ISPs, such as Verizon and Comcast, and posted information about the VRS Service Interruption on its website11 and social media outlets. The VRS Service Interruption continued for some callers through the morning of June 8, 2016.

The $2.7 million charge is a repayment of a reimbursement of the same amount paid out by the nation Telecommunications Relay Service Fund.
Sorenson has agreed to pay a more modest $252,000 in formal penalties to the FCC for its indiscretion.
Still, as domain renewal fumbles go, it’s got to be one of the biggest facepalms we’ve seen for a while.