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

[Chad Fullerton]

Dear ICANN stakeholders,

I own many .com domain names and I am against Proposed Amendment 3 to the
.COM Registry Agreement in its current form.

While I am not opposed to a price increase every 3-6 years in order to
cover increased costs due to maintaining infrastructure, a 7% increase cap
is too high. 28% cost increase every six years is unreasonable. It should
be lowered to something more reasonable between 2-3% every few years
(unless Verisign can justify otherwise needing the funds).

Any increases need to be substantiated with costs detailed specifically for
the public to see why such an increase is taking place.

How did Verisign come to conclude that this level of increase is acceptable
to the .com owners without consulting the public first?

What specifically are the "security, stability and resiliency enhancements"
that Verisign claims the increase is necessary for?

In the ICANN press release dated January 3, 2020, you state that "ICANN is
not a price regulator", and that you defer to the Department of Commerce
for the "regulation of pricing for .COM registry services", yet this
Proposed Amendment appears to be strictly about pricing. It is strange to
me that you're making a decision about price changes while also stating you
don't regulate pricing. If you don't deal with pricing changes, then
shouldn't ICANN dismiss this amendment request and instead have the
Department of Commerce make the final decision and consult the public in
their own process?

It is also being reported that ICANN is receiving $20 million dollars over
five years from Verisign with no explanation why they are all of a sudden
giving this money to ICANN or what it is to be used for. If this is true,
the optics of the situation look really bad to the public. It makes it
appear Verisign paid to get rules passed through ICANN that only benefited
themselves. Verisign has a monopoly over .COM wholesale pricing, they give
ICANN $20 million and at the same time try to push through an amendment to
let them increase prices upwards of 28% every 6 years. It comes across as a
corrupt system. The timing is very suspect.

Price increases are a big deal to the average individual and small business
owner. The .COM TLD is universally recognized. It isn't one that is purely
used by commercial entities. Individuals purchase .COM domains for personal
use as well. Small increases in the cost may not seem like a lot to large
companies, but for individuals and small businesses - especially if they
have many .COM domains to secure and renew each year - every increase is
compounded and adds up to be a lot.

Please find a common ground and fair balance between the demands of
Verisign, and what the owners of .COM domains are voicing opinions about
this proposed change. I hope when making this very important decision about
the .COM TLD that you read all comments and take them seriously into
consideration.

Thank you,

Regards,
Chad
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