[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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