[Comments-com-amendment-3-03jan20] Comment in re: Proposed Amendment 3 to the .COM Registry Agreement

Aaron Severson aseverson at ateupwithmotor.com
Tue Feb 11 07:13:17 UTC 2020


As a website owner, I regard the proposed Amendment 3 with considerable
alarm.

 

There has been an ongoing global movement to make the web less accessible,
ranging from attacks on net neutrality and the imposition of onerous
regulations. Now, ICANN proposes to exacerbate that problem with a
substantial price increase on the most commonly used commercial domain while
asserting that this usurious increase is somehow "in the public interest."
That assertion runs directly contrary to any common sense; the net effect of
the change would be to further squeeze small businesses and small operators,
who are already at the greatest risk of loss in the present web climate.

 

I take further issue with the assertion that by structuring the increases to
encourage registrants to register or renew for multi-year periods
constitutes "registrant protection," given that the entities from which
registrants need such protection are the very ones proposing the rate hike.
That is a remarkably cynical framing of what mainly seems like an effort to
drive an increase in short-term revenues. That may be in ICANN's interest,
but it's certainly not in the interests of registrants or the public. Many
small operators, including myself, cannot afford to purchase a decade's
worth of services in advance to secure some discounted rate; the costs of
poverty are a well-known economic reality. It is not that people or
businesses of modest interest don't recognize the opportunity for savings,
it's that they are simply out of reach.

 

The amendment alludes to ICANN's concerns about security and stability,
which are of course worthy goals. If ICANN could demonstrate that certain
price increases would be necessary to achieve specific technical or
regulatory compliance goals, I and the rest of the online community might
regard the proposal with greater sympathy. Instead, the proposed text buries
vague promises in noncommittal language: We are told Verisign and ICANN will
"work in good faith" and "define . requirements" for potential future
improvements. 

 

The way this reads to the layman is that the parties are determined to raise
rates now and will take their time in coming up with reasons to justify it,
with no promises that the substantial increased costs will yield any
tangible benefit. Moreover, the emphasis on encouraging registrants to renew
for multiple years suggests that we can look forward to future rate hikes,
again with only the haziest promise that it will yield any benefits to the
security, stability, or integrity of the web.

 

I think it would be appropriate for ICANN to consider carefully its role and
responsibility in the modern online world. For example, does ICANN believe
it is in the public interest to preserve the accessibility of the web as
well as its technical stability? Does ICANN wish to forestall the danger of
the Internet being steadily reduced to a handful of channels controlled by a
few large corporations, like cable television? If so, you should reconsider
this amendment and the proposed rate increases, because they work directly
against those ends - and against the public interest.

 

 

 

________________________________________________

 

This message was sent by or on behalf of Aaron Severson dba Ate Up With
Motor ( <https://ateupwithmotor.com/> https://ateupwithmotor.com), 11100
National Bl. #3, Los Angeles, CA 90064. If you do not wish to receive future
email messages, please reply with the word "REMOVE" in the subject line or
click here:  <mailto:admin at ateupwithmotor.com?subject=REMOVE>
admin at ateupwithmotor.com?subject=REMOVE. To view the Ate Up With Motor
Privacy Policy, click here:  <https://ateupwithmotor.com/privacy-policy/>
https://ateupwithmotor.com/privacy-policy/. 

 

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://mm.icann.org/pipermail/comments-com-amendment-3-03jan20/attachments/20200210/2968eb94/attachment.html>


More information about the Comments-com-amendment-3-03jan20 mailing list