[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.

Thank you.

Patrick Sullivan

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