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

Andrew Boggeri amboggeri at gmail.com
Tue Feb 11 10:56:26 UTC 2020

Dear ICANN Board of Directors,

Thank you for your continued service and work to support a free and open
internet. ICANN is a large part of why the internet is today a massive
engine for global commerce and information sharing, which has helped to
lift millions out of poverty. The role of the BoD at ICANN shares in the
responsibility for this great achievement. I'm writing to you today to
share my thoughts on the proposed Amendment 3 of the .COM Registry
Agreement which will directly affect the continued success of ICANN and the
internet as an engine of global growth. In short, I am concerned about the
magnitude of the price increases allowed to Verisign as well as the
conflicts of interest that will arrive when Verisign is allowed to operate
as a Registrar. I hope that you will take time from your busy schedules to
consider my comment.

I am roughly the same age as the public internet. I've seen it grow from a
novelty piggybacking on traditional media (remember AOL discs?) to the
dominant mode of information-sharing and communication in the world today.
In the same time period, untold amounts of wealth have been created by some
of the most unlikely people thanks to free or low-cost access to the
internet and associated tools to create a website on it. As a personal user
of the internet, I enjoy the immense amount of websites and information
created by passionate users of the internet. These are all available to me
for free thanks to the ease and low-cost of registering an internet domain
name. I also operate a few websites, one of which is primarily
internet-based and aimed at revenue generation. As a person with a start-up
internet business, the low cost of registering and maintaining a .COM
domain has been a key factor in my pursuit of this business.

It is not unreasonable for Verisign to increase prices as their ongoing
operating costs may change. However, their role in the .COM infrastructure
does not in my opinion warrant the increases in the Proposed Amendment 3.
These price increases are in fact likely to have an extremely deleterious
effect and could very likely lead to static or decreased revenue for
Verisign: if the price increases in the amendment are implemented .COM
registrations will drop precipitously. Not only will this potentially
affect Verisign, but the industry of registrars and companies who provide
value-added services would see a major drop. I urge you to also consider
the implications for global development; many low- and middle-income
countries are projected to "come online" within the next 10 years. With the
centrality of ICT to the development plans of the UN SDGs and these
countries, actions like major price increases could delay the development
of ICT industries across the globe.

As a second point, I would like the BoD to consider the conflict of
interest in allowing Verisign to operate as a registrar. Without proper
constraints and auditing, what is to prevent Verisign from acting in a way
that is contrary to the best interests of a vibrant and diverse internet
registration and service economy? Enabling Verisign to operate as a
monopoly not only violates the founding principles of the internet, but
would likely lead to legal challenges from various countries.

Finally, I would urge the board to take seriously the comments from people
like me. We are highly engaged in the daily operation of the internet as a
platform for global communication and trade and want to see the internet
continue to grow. I think that many of us think that some level of price
increases are reasonable, but what is currently proposed is excessive. We
also want to engage constructively with ICANN and other stakeholders in
this process. We hope to see transparency from Verisign, ICANN, and others
in the negotiations as well as the compensation for changes in the
structure of the internet.

Thank you for your time and consideration.


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