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

Michael Buckley michael at buckleyisms.com
Mon Feb 10 14:33:21 UTC 2020

I am writing to express my opposition to proposed Amendment 3 of the .COM
Registry Agreement. I am the registrant of multiple .com domains.

Given the current issues with the proposed .ORG takeover, it would be
inadvisable to consider any changes to other TLDs until those issues are

Furthermore, were it not for those issues, the proposed .COM price hike is
unjustified. Although I am not privy to Verisign's financials, I have seen
it estimated that their costs per domain registered range from $1 to $3.50.
This gives them a current profit margin of ~60%.

Given that ICANN is supposed to govern the domain name system in the public
interest, not in Verisign's interest, and that a profit margin of 60% is
extremely high in any indistry, ICANN should instead be proposing to lower
.COM prices.

Michael Buckley
Portland, Oregon
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