[Comments-com-amendment-3-03jan20] I oppose this amendment

Jess Jones jesseljones at gmail.com
Mon Feb 10 22:42:06 UTC 2020

As a personal holder of three .COM domains, and the responsible party
for a fourth on behalf of a small business (three employees with
minimal profits, he operates as much as a public service as he does as
a business), I vehemently oppose this quid pro quo cash grab.

1. ICANN was created to operate in the PUBLIC interest. This
"amendment" serves no one but ICANN and Verisign, who do not
collectively constitute "the public".

2. Barring any extenuating circumstances, the entire point of an
AGREEMENT is for both parties to be held to it; freely and privately
amending it on a whim violates the spirit of an agreement.

3. The .COM TLD was not enforced as a commercial-only TLD, and as a
consequence many individuals have registered and built sites upon .COM
domains for their own personal or professional purposes prior to the
proliferation and popularization of other TLDs. If it *were* enforced
as a commercial-only TLD I could see the interest in raising prices as
larger commercial entities do often profit wildly off their domains,
and using such activity to help maintain the domain infrastructure
could be considered in the public interest. This is not the case
though, and as such price increases disproportionately affect
individuals and small businesses.

4. The amendment does not specify how the payment to ICANN is to be
spent, leaving the looming specter of largess and misuse. Had the
amendment laid out strict guidelines for how the money would be used
IN THE PUBLIC INTEREST, I might almost be able to forgive it; but it

If the .COM domain price structure were shifted to a tiered status,
where individuals and small businesses paid a lesser fee for their
domains while larger corporate entities who are profiting
significantly off their domains paid more, I could appreciate this
more; it would reinforce the concept that the fees are for the
maintenance and improvement of the domain infrastructure since the
larger entities of course put a greater load on the system in terms of
DNS queries and such. Even better, base the tiers simply on root
domain traffic; domains that have less than X queries to the root
servers per year (a reasonable amount to be determined by ICANN based
on current traffic) qualify the following year for "small user"
status, and either lump everyone else into a "large user" group, or
create further tiers (10*X, 1000*X, etc) to keep domains affordable
for smaller businesses while larger businesses pay their fair share to
maintain the infrastructure they profit from.

Even if the agreement were better structured, such that the increases
would be limited and reasonable, I could perhaps forgive this.
Instead, the agreement gives Verisign broad leeway to pump prices as
they see fit, giving ICANN a percentage of the forecasted profits in
return. This is utterly unacceptable and completely AGAINST public
interest, and must be stopped.


Jessica Lee Jones
Massachusetts, United States

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