[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement

Frank Michlick (DC2) frank at domaincocoon.com
Fri Feb 7 21:34:09 UTC 2020


Thank you for the opportunity to provide comments to the proposed
amendment to the .COM registry agreement.

My company is the registrant of about 250 .COM domains and consults
registrars, registries, marketplaces and DNS companies.

Considering the origin of the price increases that have made their way
into many registry agreements, I'm opposing any potential price
increases, especially for .COM. The increases were originally allowed
due an out of court settlement between ICANN and Verisign, that was
decided without any community input and should have been time limited.

Being quite technical myself, I do not see any obvious reason for the
cost to run the registry and the DNS servers to increase. Technology
gets cheaper in scale and the number of registrations is still
increasing. Many other potential operators have made credible statements
(and bids) that show that the registry can be run at a lower price.
Thus, the rate should remain fixed at $7.85, or even be lowered.

As a public company, Verisign's biggest obligation is to their
shareholders, which means they need to increase their profit as much as
possible. This does not align with the interest of the community and
stakeholders in the ICANN process. ICANN's goal is to keep the internet
technically stable, this is not done by granting arbitrary price increases.


Sincerely,
Frank Michlick
DomainCocoon Inc.
Montreal, Quebec Canada





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