<div dir="ltr"><p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">Friday, February 14, 2020</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif"> </span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">The Honorable Senator Elizabeth
Warren, Senate Office Building, Washington DC 20510</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">The Honorable Senator Amy Klobuchar,
Senate Office Building, Washington DC 20510</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">The Honorable Representative Steny
Hoyer, 1705 Longworth House Office Building, Washington, D.C. 20515<br>
The Honorable Representative Nancy Pelosi, 1705 Longworth House Office
Building, Washington, D.C. 20515<br>
Bureau of Consumer Protection, FTC</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">Bureau of Competition, FTC</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">ICANN</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif"><br>
Re: <a href="https://www.icann.org/public-comments/com-amendment-3-2020-01-03-en">https://www.icann.org/public-comments/com-amendment-3-2020-01-03-en</a><br>
<br>
To whom it may concern:<br>
<br>
</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">A few days ago, I was contacted by
my domain name registrar advising that Verisign was asking for pricing increases
(about 30%) that would substantially
increase the cost of holding the small portfolio of domain names I own
(10-20). I think everyone should own a few because ownership of the
internet, its value, should derive from users, mainly the people (real people,
not corporations doing business as persons for purposes of business law).
I am not looking to flip mine for a profit. I have no websites up.
The only websites I have put online were for teaching and research purposes,
paid for out of my personal income. It is expensive enough merely to put
up, protect, and maintain a website. To reach an audience requires a
campaign war chest to pay for social media and search engine advertising.
I, like most Americans, am not wealthy nor a fundraiser. The cost of
owning a few domain names is not a cost of doing business for me since I don't
own one or have any plans in that direction.<br>
<br>
The internet should be first and foremost a resource that enhances public
speech, the internet should belong to the people. But, so that the
internet remains open and free, I understand we must rely on both private and
government, or quasi-governmental agencies to manage <br>
necessary infrastructure. Unfortunately, it seems that the internet is
plagued with potholes, worse than our highways. <br>
<br>
Until I was contacted by my registrar 2 days ago, I had never heard of Verisign
and was only vaguely familiar with ICANN. I recall paying ICANN fees to
my registrar that are very low. What I did not know is that a substantial
part of the substantial annual cost paid to my registrar just to own them,
whether I do anything with them or not, goes to Verisign. Amendment 3
will increase those costs dramatically and also change the structure of the
internet to increase the monopoly Verisign holds over the internet.
Verisign already has no competitors, already is a monopoly contractually.
On the other hand, there are very many <br>
domains and domain registries. These compete on price; but, from what I
can see, are highly constrained in doing so because all of them must pass on
considerable fixed (Verisign) fees to consumers and other owners of domain
names.<br>
<br>
</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">Verisign is publicly traded and has
outperformed all stock markets substantially. Most public comments are
going to complain that Verisign already makes too much money and has not
specified why they need to make more. That's easy to predict because
that's pretty much all the public knows and has been told. The only
reason Verisign gives to demonstrate the need, is a generalized, vague
statement about the need to safeguard internet security. I would think
that if they had specific plans for improvements to what they already do--since
protecting the internet <br>
essentially is also Verisign's mission statement--they would have a specific
budget and that they would be pitching these plans through the roof because
they are publicly traded--it's both in their interest to disclose and required
by accounting standards and the SEC.<br>
<br>
Verisign has already bullied the same for .org and other domain types.
Thousands of public comments objected. Only a few voiced in favor, which implies
almost all those who would personally profit from these price increases did not
even bother to submit a letter voicing their <br>
approval. Why? Because like the present case, the old public comment
process was merely an excuse going through the motions, not a serious
solicitation and consideration of public comments. I am told the public
comments against were all dismissed as "spam" for the earlier
case. I think there was a little more to it. The usual reason most
public comments against are dismissed is that they do not rise to the technical
and legal standards necessary to require explanation and/or
reconsideration. You have to be an expert in the field or a lawyer
to <br>
submit comments that matter these days, especially in this case of a high-tech
company that acts in the background of the internet, in the shadows of our
lives. <br>
<br>
The only comments likely to stop this process, or most any other process from
Keystone to health and safety regulations are lawsuits or credible threats to
sue submitted in comments in the absence of sincere federal, indeed
international, regulation and oversight. I don't see that
happening. We don't have a public union. Registrars are not well
organized. And, I doubt anyone could recover the substantial legal
fees. <br>
<br>
ICANN is supposed to regulate Verisign but seems to be surrendering their
responsibilities. Verisign gave ICANN a considerable sum of money to make
these changes happen. This, I presume, was to pay ICANN's costs but the
amount seems more like paying for all of ICANN's bonuses and new corporate
memberships at Mar-A-Lago. <br>
<br>
As a monopoly, Verisign minimizes risk by definition. In a free market,
stock values are supposed to reflect risk. High tech firms generally earn
more because they face the added risk of the technology itself. The
internet has been around for Verisigdecades now. I don't see there being all <br>
that much risk to the internet failing. Verisign's only risk has been and
is keeping the internet secure but in a very limited way. <a>What</a></span><span class="gmail-MsoCommentReference"><span style="font-size:8pt"><a class="gmail-msocomanchor" id="gmail-_anchor_1" href="#_msocom_1" name="_msoanchor_1">[</a></span></span><span style="font-size:12pt;font-family:"Times New Roman",serif">do they plan to do different? Build a Wall around the
internet? Overall, I don't judge the internet a safe place.
I don't believe and Verisign has <br>
not convinced me as a member of the public that the internet is going to be
safer if Verisign gets these price increases.<br>
<br>
Verisign has extremely (abnormally) high operating profits and net
incomes. I am not going to go into those specifics because I am objecting
to the process itself. The public has not been given adequate knowledge
or time to make credible objections. Essentially, <u>the <br>
Amendment 3 public comment process is fraudulent</u>. There is reason to
suspect ICANN has been paid off and will not see to the public interest.
We have been given no reason to justify the price increases. They know
the public can only object to the price increase itself and <br>
that objecting to price increases will be easily dismissed by free market
reasoning. The problem is that the public, average folks, have no other
place to go. They used to say the crooks were in the banks because that's
where the money is. Today, the crooks seem to camp out <br>
in Verisign and ICANN. I ask that the
price increase be denied due to unfair process according <br>
to principles of the free market, free internet, and free speech. ICANN
should require and publish a detailed review explaining what they want to do
that requires this price increase and what they want to achieve by it besides
jacking up their stock price before the next heist. </span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif"> </span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">The US Department of Commerce should
have gotten off its soup can and seen that it was so instead of conspiring with
Verisign and ICANN to further usurp the internet. Since I do not think public
comments are being solicited with sincere intents, I am forwarding my own to
above members asking Congress to hold hearings on the past and present process
by which these price increases and encroachment on our freedoms have been
conducted by US Department of Commerce, Verisign, and ICANN. That’s the only way the public is going to
have the information necessary to judge and comment. <br>
<br>
Thank you for your consideration and assistance,<br>
Dr. Susan Grogan</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">Professor of Political Science</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">St. Mary's College of Maryland</span></p>
<p class="MsoNormal" style="margin:0in 0in 0.0001pt;line-height:normal;font-size:11pt;font-family:Calibri,sans-serif"><span style="font-size:12pt;font-family:"Times New Roman",serif">St. Mary's City, MD 20686</span></p>
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