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

Andrew Miller andrew at amxl.com
Tue Feb 11 10:40:08 UTC 2020

Dear ICANN staff,

The amendment to section 7.3(d) of the agreement is not reasonable or in
the public interest because:

  * .com is the largest TLD by volume, and plays a key role in the
    dissemination of information on the Internet and in commerce. It is
    such a well established TLD that many people and companies have no
    reasonable alternative to 'vote with their feet', and so ICANN plays
    a key role in ensuring that Verisign does not abuse its position as
  * When similar changes have been made to other registries, for example
    to .org, this has been rapidly exploited by registries for profit
    (for example, by selling of the registry to a company that
    undoubtedly intends to maximise profit unfairly at the expense of
  * New section 7.3(d)(ii) allows for 8 price increases of 7% in the
    next 10 years due to the backdated start date, even in the absence
    of any legitimate increase in expenses. This amounts to a maximum
    increase of a massive 71.8% ((1.07^8 - 1)*100%) even in the absence
    of any increase in costs. For comparison, inflation in the US over
    the last 10 years was 22.3%. Allowing for completely discretionary
    increases on the part of Verisign significantly above inflation is
    not reasonable, nor is it fair to registrants or the broader
    Internet community.

Kind regards,


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