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<p>I am a registrant of a .com domain name and work in the domain
name industry. <br>
</p>
<p>The new registry agreement contains various concerning issues
that must be addressed before the agreement can proceed. </p>
<p>The way that increases in registry fees are negotiated between
ICANN and the Registry operator is anti-competitive and violates
the rights of the parties that will ultimately have to pay these
fees. Change in registry fees should be subject to negotiations
between the parties to the registry-registrar agreement, e.g.
Verisign and the accredited registrars and subsequently subject to
review and approval by ICANN (to compensate any inequalities in
negotiation powers). <br>
</p>
<p>ICANN unilaterally agreeing to changes to registry fees without
consulting the parties subject to those fees is anti-competitive
and essentially disenfranchises registrars of their negotiation
powers.</p>
<span style="font-family:"Arial",sans-serif;color:black">I
also am concerned about the proposed changes to the
registry-registrar agreement that are included as part of the
amendment of the registry agreement. Essentially this amounts to
creating new obligations for contracted parties and registrants
through the back door without policy. ICANN is proposing to create
new obligations for parties that are not even at the table in
these negotiations. Any changes to the Registry-Registrar
agreement that create new obligations for either side cannot be
unilaterally imposed by ICANN or the registry operator, but must
be negotiated and/or approved by the parties to that agreement,
subject to ICANN approval.</span>
<p>Sincerely,<br>
</p>
Volker Greimann<br>
Saarbrücken, Germany
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