[Comments-com-amendment-3-03jan20] Verisign as Domain Registrar

[Evan Barr]

I strongly disagree with your plan to allow Verisign to become a domain
registrar and to allow them to increase prices on .com domains.

First, the majority of the management of the domain registry is automated.
As a result, the cost of this management is going down.  Verisign should be
allowed to benefit from improvements in efficiency but any increase in the
current prices amounts to gouging.

Second, prohibiting Verisign from selling .com domains but not prohibiting
them from acting as a reseller of .com domains through another registrar
still amounts to an unfair advantage.  Allowing Verisign to compete with
their customers while also controlling the price of the product gives them
an unfair advantage.  As the owner of multiple domains going back to 1998,
I recognize that this change could result in a short-term reduction in
renewal fees.  But as other registrars get knocked out of the market, there
is nothing to keep the prices down and less reason for any registrar to
innovate.

It is not true that .com will be affected by competition from other TLDs.
Not owning the .com version of your business name means being OK with
phishing attacks against your customers.  In many markets, customers expect
and assume that your domain is a .com.  Also, the marketing cost of
changing your domain name tends to be prohibitively large.

Please do not go forward with this plan to allow Verisign to increase .com
prices or to become a domain registrar.

Evan Barr
CTO: Project InVision (ebarr at projectinvision.com, ebarr at wellcycle.com)
CTO: Brooklyn Minds (evan.barr at brooklynminds.com)
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