You can find the entire letter embedded below or a link to the pdf here.
Dear Federal Trade Commission Chair and Commissioners:
The non-profit groups Americans for Financial Reform Education Fund and the Electronic Frontier Foundation urge the Federal Trade Commission to closely scrutinize the proposed private equity purchase of the non-profit .ORG domain registry operator Public Interest Registry (PIR) by Ethos Capital. The proposed transaction would increase the likelihood that the new for-profit PIR LLC could unfairly exercise its monopoly power to disadvantage the millions of non-profit organization consumers by raising prices, reducing service levels, imposing onerous terms of service, or otherwise interfering with their operations.
The financial structure of the proposed $1.135 billion transaction would impose a significant $360 million debt service load on the new company that would create an incentive for PIR LLC to exercise its monopoly power to the detriment of its consumers and the millions more people who visit their websites, access their services through the Internet, or participate as supporters, donors, members, or civic participants.
The .ORG registry serves a unique role for non-profit groups, civil society, foundations, and charitable institutions that benefit from a vibrant internet for non-commercial activity. These organizations with .ORG domain registrations are captive customers of PIR’s monopoly control of .ORG domain names. PIR LLC could impose price hikes or onerous service conditions on its customers, who would have little alternative without losing their branded Internet presence (and facing substantial financial and reputational costs to switch to another top-level domain).