[Comments-com-amendment-3-03jan20] Proposed price increases on .com

Geoff Kuenning geoff at cs.hmc.edu
Tue Feb 11 06:34:13 UTC 2020


To whom it may concern,

I am the owner of a number of .com domains, including one that 
dates back to the origins of the Internet (it is in the top 50 
oldest continuously held domain names).  Thus, I am thoroughly 
familiar with the history of the Domain Name System, ICANN, and 
domain pricing.

The current proposal to increase .com prices is unsupported by 
either history or economics.  It is also unsupported by any 
director indirect customer of domain wholesalers.

Furthermore, the amount of the increase is utterly unreasonable. 
Inflation is currently running at around 1.5-2% per year, and has 
been at that low level for the past several years.  Thus, it is 
absurd to suggest annual increases of 7%, far above the inflation 
rate.  ICANN and Verisign have offered zero evidence to suggest 
that their per-domain costs have increased at all, let alone at 
such an inflated rate.

Verisign has a monopoly on the .com top-level domain.  If 
unrestrained, it will unquestionably use its monopoly power to 
raise prices arbitarily.  It is ICANN's job to prevent such 
monopolistic behavior; if ICANN fails in its duty, it is certain 
that the government will eventually step in.

Verisign's contract should be renegotiated so that price increases 
are limited to more than the general inflation rate.  Domain names 
are a public good, and should be treated as such.
-- 
    Geoff Kuenning   geoff at cs.hmc.edu 
    http://www.cs.hmc.edu/~geoff/



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