[Comments-com-amendment-3-03jan20] Comments on ICANN amendment

[KimSia Sim]

Hi there, 

As a company of one that operates on the internet economy, purchasing domains to test new ideas and subsequently using them is very much part of my operations.

I see that the recent amendment as highly harmful to my business and millions who operate in the internet economy.

The amendments are akin to rent seeking while holding back innovation.

I understand if price increases are required for investment in infrastructure. Without a clear explanation as to how and what the price increments are meant to invest in, I cannot agree to this.

There are 4 main issues with the current amendment and I have quoted them verbatim from my preferred domain registrar namecheap.

My comments are in blue

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1. Price Increases

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Verisign will be allowed to increase the wholesale price to registrars for .COM domains by 7% each year in 2020, 2021, 2022, and 2023. After a two year “freeze”, Verisign can increase prices by 7% annually during 2026-2029, then another two year “freeze”. This cycle will continue, meaning that within 10 years, .COM domains could cost approximately 70% more than the current wholesale price of $7.85 — and the sky is the limit.

It is not clear how much of these price increases registrars will pass along to consumers, but it is likely that most of these increases will be paid by domain name registrants. The contract does allow for other price increases for certain extraordinary situations, so it is possible prices could increase more than anticipated. 

*Is this true? Will there be a 7% increment every year from the wholesaler Verisign without any indication how the increment will benefit investment into the infrastructure?*

*If the increment plan is true, and yet no clear specifics are provided as to how the investments are going to ultimately benefit the members of the internet economy, I'm afraid I cannot support this amendment.*

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2. ICANN Will Receive an Extra $20 Million 

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With the contract changes, Verisign agreed to pay ICANN an additional $20 million dollars over five years to support ICANN’s initiatives regarding the security and stability of the domain name system. There is no explanation why Verisign did this, how ICANN will spend the money, or who will ensure that the funds are properly spent. 

*Is this true? Can ICANN go into details how the 20 million is spent and invested?*

*If the above is true and ICANN cannot give details about how the 20 million is to be spent and invested in a way that ultimately benefits the domain owners, then this looks like the kind of corruption that third world governments engage in.*

*And I'm afraid I cannot agree to the amendment.*

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3. Verisign Can Operate as a Domain Registrar

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ICANN also had rules that the operator of a TLD could not operate a domain name registrar. Although in 2012 ICANN allowed operators of new gTLDs to have domain name registrars, it did not apply to Verisign. The new contract will allow Verisign to operate its own registrar, except for selling .COM domain names itself. To circumvent this, it is also possible that Verisign could act as a reseller of .COM domains, through another registrar.

This result is that the company that controls almost 80% of the registrar pricing for domain names will compete directly with all domain registrars, maximizing its control of domain name pricing to the detriment of other competing registrars. While this might result in lower prices to consumers, fewer registrars will harm competition, choice, and domain name services. 

Verisign’s registrar could also use its dominant position to charge higher prices to consumers, while at the same time raising registrar prices. 

*Is this true? *

*I welcome competition as a consumer who purchases domains for business and hobbies.*

*So can ICANN explain how it intends to prevent monopolistic practices by Verisign to raise prices on the consumers unnecessarily? If ICANN cannot adequately explain, I cannot support the amendments.*

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4. ICANN Ignored Previous Comments

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As detailed on Standing Up to ICANN to Keep Domain Prices in Check ( https://www.namecheap.com/blog/ensuring-icann-keep-domain-prices-in-check/ ) and pricecaps.org ( http://pricecaps.org/ ) , over 3,500 comments were submitted in support of price controls for the .ORG, .INFO, and .BIZ TLDs. Only six comments supported removing price controls. ICANN discounted the comments that were in favor of maintaining price caps. A number of the comments were submitted using an online tool, which caused the comments to be discounted as “spam” by the ICANN Ombudsman. 

ICANN removed the price caps, primarily relying upon a biased preliminary analysis from 2009 by an economics professor that did not reference any data. 

*Is this true? 

* *This sounds like the kind of biased research and lazy administration that incompetent organizations tend to do. And I'm quite sure ICANN does not aim to be that sort of organization.*

*I can understand well-grounded research that backs up unpopular moves such as price increment but it needs to be transparent and well-grounded. I have not seen that, so once again, I cannot support the amendment.*

*Thank you*

KimSia kimsia at oppoin.com https://simkimsia.com ( https://simkimsia.com/ )

P.S. What I'm doing now: https://simkimsia.com/now
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