[Comments-com-amendment-3-03jan20] Opposed to .com price increases

Nat Cohen ncohen at telepathy.com
Fri Jan 17 04:25:05 UTC 2020


Dear Mr. Namazi,

What is ICANN's justification for raising prices on millions of .com
registrants?

Why is Verisign entitled to make hundreds of millions of more dollars on
top of the billion dollars it already makes from running .com?

Why is ICANN allowing a company with market power to increase prices,
without justification, and in the absence of meaningful competition that
would restrain pricing?

Does ICANN have any good answers to these questions?

NTIA says it is ICANN's job to set prices on .com.  ICANN says it is NTIA's
job to set pricing.  Who then is responsible for negotiating reasonable
pricing on behalf of the public?  Is NTIA wrong that it is ICANN's job to
set prices?  Was the DOJ wrong back in 2008 when it said that ICANN was
failing to uphold its responsibility to constrain the market power of
Verisign?

NTIA did not mandate that ICANN increase .com prices, it merely set an
upper limit beyond which prices should not go.  ICANN retains the ability
to freeze pricing while remaining consistent with NTIA guidance.  It would
be odd indeed if a U.S. Government agency was in favor of company raising
prices on consumers without justification.

At what point will ICANN start looking out for the public interest instead
of only acting in the best interests of the registries?

ICANN's preference for harming registrants to benefit registries highlights
the fact that ICANN is unaccountable to the public, that its policy making
structure provides no meaningful way for the public interest to be given
any weight in developing policy, and that it lacks legitimacy.

There is no justification for a price increase.  Verisign is not facing
higher costs that need to be passed along to customers.  Verisign is
already one of the most profitable companies in the world, enjoying
extremely high profit margins and deriving enormous revenues per employee.

ICANN's utter failure to protect the public from being ripped off by
registries with market power setting ever higher prices is a sad reflection
on ICANN.

I urge ICANN to stop the needless transfer of hundreds of millions of
dollars from registrants worldwide into the already overflowing pockets of
Verisign by denying Verisign price increases.

Regards,

Nat Cohen
President
Telepathy, Inc.
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