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<p>Dear ICANN staff,</p>
<p>The amendment to section 7.3(d) of the agreement is not
reasonable or in the public interest because:</p>
<ul>
<li>.com is the largest TLD by volume, and plays a key role in the
dissemination of information on the Internet and in commerce. It
is such a well established TLD that many people and companies
have no reasonable alternative to 'vote with their feet', and so
ICANN plays a key role in ensuring that Verisign does not abuse
its position as registry.</li>
<li>When similar changes have been made to other registries, for
example to .org, this has been rapidly exploited by registries
for profit (for example, by selling of the registry to a company
that undoubtedly intends to maximise profit unfairly at the
expense of registrants).</li>
<li>New section 7.3(d)(ii) allows for 8 price increases of 7% in
the next 10 years due to the backdated start date, even in the
absence of any legitimate increase in expenses. This amounts to
a maximum increase of a massive 71.8% ((1.07^8 - 1)*100%) even
in the absence of any increase in costs. For comparison,
inflation in the US over the last 10 years was 22.3%. Allowing
for completely discretionary increases on the part of Verisign
significantly above inflation is not reasonable, nor is it fair
to registrants or the broader Internet community.</li>
</ul>
<p>Kind regards,</p>
<p>Andrew<br>
</p>
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