[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


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 

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.



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