[Comments-com-amendment-3-03jan20] Comment on proposed amendment 3 to .com registry agreement
Patrick - PASU Holdings LLC
patrick at pasuholdings.com
Sun Feb 9 00:24:49 UTC 2020
Estimates say that the cost to manage the .com domain registry does not
exceed $3.50 per domain, per year, and the number might really be
significantly lower. Furthermore, other qualified registrars/managers
have proven the ability to operate other domain registries for less than
$1.00 per year. Based on this information, there does not seem to be any
legitimate reason to raise .com domain rates to the proposed levels when
the price is already $7.85 per domain.
If Verasign and ICANN can articulate a valid and evidence-based reason
for needing to raise the price of each .com domain, then I could
understand the request. HOWEVER, I read the proposed amendment and the
only reasons listed for raising the rates are (1) imposition of any new
Consensus Policy, or (2) documented extraordinary expense resulting from
an attack or threat of attack on the security/stability of DNS. I have
not seen any explanation of what these would cost and how that would
compare to the proposed annual increase.
However, based on Verasign's estimate of 144 million .com domain names
currently registered, we know factually that just in the first 7% annual
increase, Verasign would earn an additional $79.2 million.
If an increase in price is inevitable, I ask that ICANN consider a much
lower increase, such as 10 cents ($0.10) per year over the next four years.
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