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

Justin Mazzola Paluska jmp at justinmp.com
Tue Feb 11 01:31:34 UTC 2020


To whom it may concern,

I oppose Amendment 3 to the .COM Registry Agreement. I believe that allowing 
wholesale prices for .com domains to rise 72% over 12 years, which is far more 
than the rate of inflation and also far more than Verisign's underlying costs of 
maintaining the registry could possibly increase by, will dramatically hurt the 
internet ecosystem. It will especially hurt small website operators, like 
myself, and will discourage internet users from creating blogs and personal 
pages, with the end result of reducing democratization of the internet.

Verisign reported a 69.4% operating margin in Q1 2019, so they clearly do not 
need the extra revenue from this price hike. ICANN has granted a monopoly over 
.com to Verisign and ICANN has a duty to every internet user on the planet to 
carefully regulate this monopoly to prevent abuse by Verisign. The only 
conscionable thing to do right now is to freeze wholesale .com prices and 
re-evaluate 5-10 years from now. A policy that allows price increases tracking 
the rate of inflation (but no higher) may make sense in the future, but right 
now Verisign is already collecting far more from their .com monopoly than any 
company would be able to in a competitive market. It's simply not right to allow 
them to raise prices at this time.

Sincerely,
     --Justin Mazzola Paluska

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