[Comments-com-amendment-3-03jan20] Don't go ahead please!!

[Joe Burrill]

*This amendment is a bad idea, Increasing prices of .coms by 70% over 10
years is a joke and is clearly a money grab. Don't go ahead!*

I agree with all of the points Namecheap have highlighted in their article:

There are four main concerns with ICANN’s decision:

1. Price Increases
Verisign will be allowed to increase the wholesale price to registrars for
.COM domains by 7% each year in 2020, 2021, 2022, and 2023. After a two
year “freeze”, Verisign can increase prices by 7% annually during
2026-2029, then another two year “freeze”. This cycle will continue,
meaning that within 10 years, .COM domains could cost approximately 70%
more than the current wholesale price of $7.85 — and the sky is the limit.

It is not clear how much of these price increases registrars will pass
along to consumers, but it is likely that most of these increases will be
paid by domain name registrants. The contract does allow for other price
increases for certain extraordinary situations, so it is possible prices
could increase more than anticipated.

2. ICANN Will Receive an Extra $20 Million
With the contract changes, Verisign agreed to pay ICANN an additional $20
million dollars over five years to support ICANN’s initiatives regarding
the security and stability of the domain name system. There is no
explanation why Verisign did this, how ICANN will spend the money, or who
will ensure that the funds are properly spent.

3. Verisign Can Operate as a Domain Registrar
ICANN also had rules that the operator of a TLD could not operate a domain
name registrar. Although in 2012 ICANN allowed operators of new gTLDs to
have domain name registrars, it did not apply to Verisign. The new contract
will allow Verisign to operate its own registrar, except for selling .COM
domain names itself. To circumvent this, it is also possible that Verisign
could act as a reseller of .COM domains, through another registrar.

This result is that the company that controls almost 80% of the registrar
pricing for domain names will compete directly with all domain registrars,
maximizing its control of domain name pricing to the detriment of other
competing registrars. While this might result in lower prices to consumers,
fewer registrars will harm competition, choice, and domain name services.

Verisign’s registrar could also use its dominant position to charge higher
prices to consumers, while at the same time raising registrar prices.

4. ICANN Ignored Previous Comments
As detailed on Standing Up to ICANN to Keep Domain Prices in Check and
pricecaps.org, over 3,500 comments were submitted in support of price
controls for the .ORG, .INFO, and .BIZ TLDs. Only six comments supported
removing price controls. ICANN discounted the comments that were in favor
of maintaining price caps. A number of the comments were submitted using an
online tool, which caused the comments to be discounted as “spam” by the
ICANN Ombudsman.

ICANN removed the price caps, primarily relying upon a biased preliminary
analysis from 2009 by an economics professor that did not reference any
data.

Cheers
Joe
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