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

Andrew shield007-AndrewICANN at yahoo.com
Tue Feb 11 15:10:34 UTC 2020

Since the 1990s, I am and have been a registrant of many .com domain names.
I strongly oppose the proposed Amendment 3 to the .COM Registry Agreement. 
As a California nonprofit public-benefit corporation, ICANN is required to act in the public's best interests while pursuing its mission to ensure the stable and secure operation of the Internet's unique identifier system.
Increasing the wholesale rate for .com domain name registrations from the current rate of $7.85 is not in the public's best interest and not necessary for ICANN to pursue its mission.
The proposed amendment to allow annual price increases of 7% has no reasonable basis and is not associated with anticipated cost increases on the part of Verisign. While the current rate of $7.85 has been frozen since 2012, the costs of domain name registry operators and domain name registrars has been decreasing. If anything, the freeze should be made into a permanent rate cap and the rate should DECREASE. 
By all appearances, Verisign will be paying $20M USD to ICANN as a bribe to persuade ICANN to allow Verisign to significantly increase the wholesale .com rate and, thereby, significantly increase Verisign's profits.
Over the years, I have served as a board member on multiple nonprofit boards. If this amendment is approved, ICANN's board of directors should be ashamed of themselves.
Sadly, ICANN's relationship with Verisign and other registry operators appears to be a classic case of "regulatory capture", where the organization (or government agency) that is supposed to regulate an industry ends up being "captured" by that industry and serving the interests of the industry rather than the public interest.
If ICANN and its Board of Directors truly cared about the public interest, ICANN should take a close look at its relationship with Verisign and evaluate whether Verisign is the best organization to continue serving as the .com domain name registry operator. I would be shocked if a competitive RFP process did not result in identifying another, reputable organization that would commit to providing a better level of service than Verisign at a lower .com wholesale rate. In fact, if ICANN is seeking additional capital (under the belief that ICANN needs additional funding to pursue its mission), I expect the organization identified in such an RFP process would even agree to make ongoing financial contributions to ICANN that exceed the $20M payment Verisign would be making under the proposed amendment.

Sincerely,Andrew Hanna
Commonwealth of VirginiaUnited States of America
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