[Comments-com-amendment-3-03jan20] Opposition to amendment 3
Emile Fugulin
contact at efugulin.com
Tue Feb 11 00:39:43 UTC 2020
I oppose Amendment 3 to the .COM Registry Agreement. I believe that
allowing wholesale prices for .com domains to rise 72% over 12 years,
which is far more than the rate of inflation and also far more than
Verisign's underlying costs of maintaining the registry could possibly
increase by, will dramatically hurt the internet ecosystem. It will
especially hurt small website operators, like myself, and will
discourage internet users from creating blogs and personal pages, with
the end result of reducing democratization of the internet.
Verisign reported a 69.4% operating margin in Q1 2019, so they clearly
do not need the extra revenue from this price hike. ICANN has granted a
monopoly over .com to Verisign and ICANN has a duty to every internet
user on the planet to carefully regulate this monopoly to prevent abuse
by Verisign. The only conscionable thing to do right now is to freeze
wholesale .com prices and re-evaluate 5-10 years from now. A policy that
allows price increases tracking the rate of inflation (but no higher)
may make sense in the future, but right now Verisign is already
collecting far more from their .com monopoly than any company would be
able to in a competitive market [1]. It's simply not right to allow them
to raise prices at this time.
Emile
[1] For example, Alphabet, a highly successful player in a very
high-margin industry, has an operating margin of around 25%. Verisign's
operating margin is over 2.75 times that.
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