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

Michael Scepaniak mike at milestoneinc.com
Tue Feb 11 15:32:31 UTC 2020

I oppose Amendment 3 to the .COM Registry Agreement. I believe that
allowing wholesale prices for .com domains to rise more than 70% over 12
years will dramatically hurt the internet ecosystem. This rate of increase
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. It
will especially hurt small website operators like myself - and will
discourage internet users from creating blogs and personal pages.

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
to carefully regulate this monopoly to prevent abuse by Verisign.

A policy that allows price increases tracking the rate of inflation (but no
higher) may make sense in the future. However, 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.


[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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