[Comments-com-amendment-3-03jan20] The proposed .COM registration price cap increases are ill-advised and will result in reduced revenue

Paul Rauschelbach paul at palindrome.com
Sat Feb 8 20:39:07 UTC 2020


Registry consolidation and technical improvements should have dramatically reduced the cost of domain registry administration, not increased them. Rewarding the risk to the investor and public of the leveraging used for registrar consolidation with guaranteed high rates of return, with no guarantee of improvement to services (an aspiration to secure DNS is not a promise, and the registrars have been dragging on this already), is irresponsible and against the interest that the ICANN is meant to serve. You will just as likely see a decrease in registration revenue when the speculative registrations decrease as a result of higher registration fees.

This proposal and the similar .ORG TLD changes create a general suspicion and ill-will toward the ICANN, and demand further scrutiny of the management and structure of this public trust.

A 2% annual increase is the most that should ever be proposed, or a better case for any higher increase, with effective oversight of such uses and real consequences for failures or breaches.


Paul Rauschelbach <paul at palindrome.com <mailto:paul at palindrome.com>> SF 415-271-9216

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