[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
Mark Lavi
mark at lavi.us
Tue Feb 11 02:57:33 UTC 2020
Hello,
I read
https://www.icann.org/public-comments/com-amendment-3-2020-01-03-en. I
believe there is a fundamental flaw in the proposal that shows a simple
motivation on ICANN and Verisign to prevent competition and to introduce
arbitrary price increases through vague, undefined terms.
Firstly, the design of a well operating DNS and domain registry system
should not have any single point of failure. By restricting this
multi-year proposal to a single vendor, ICANN has shown a clear bias in
not allowing any competition. VeriSign surely is a competent vendor, but
there is no reason why the incumbent should proceed without any
justification.
ICANN should take this opportunity to improve domain registry management
by clearly laying out what the current and future needs are for a vendor
to perform, what service level agreements and penalties should be in
place, and finally require cooperation or delegation of domain
registration management of top level domains such as .COM across
multiple vendors.
There is no technical barrier to this requirement to open competition.
Secondly, because ICANN is not defining the responsibilities in terms of
performance SLAs, penalties, and features, there cannot be a cost
associated with a reasonable vendor response to the proposal. This makes
every cost arbitrary and unjustified, something ever well run business
defines in a contract. Any vendor could squander irresponsibly their
management costs, blame it on security, and raise prices the maximum
amount because they can like a monopoly.
There is no barrier to conducting a vendor selection requirements
proposal gathering process, evaluation, and decision made in an open,
transparent fashion: this is how the marketplace is defined and won.
ICANN should adopt proper accumen in pursuing open competition for
services and vendor selection, but this proposal shows little interest
in providing the best possible outcome from the marketplace of vendor or
the very constituents customers of the .COM TLD.
Please consider revising, defining needs, and opening this proposal to
marketplace competition and shared responsibility across vendors to
promote robustness in cost and reliability.
--
Cheers,
--Mark
mailto:mark at lavi.us [ mobile:+1-650-400-2100 ] http://mlavi.github.io/about/
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