[Comments-com-amendment-3-03jan20] Concerns regarding TLD rule changes

[Greg Malone]

Hello,

I've been made aware of two rule changes recently made concerning the
".com" TLD.

One would allow or impose a yearly increase schedule for wholesale domain
pricing. As in any other industry, price increases are required from time
to time to keep pace with inflation and business requirements. But the
schedule seems particularly aggressive here - moreso considering the
etherial nature of the product. Have rates been stagnant for so long that
such a steep increase schedule is truly warranted? This will accumulate to
a 72% increase over ten years on a product with over a hundred million
units - what costs of operation is the additional $300 million+ in revenue
intended to fund?

Second is the rule change that would allow the ".com" TLD holder to
participate in the domain registrar business. Not directly, but as a
registrar with the ability to purchase generic TLD domain names from a
partner this would open another revenue stream that profits from both sides
of the sale of the product. This is not the type of arrangement any
regulated industry player should be involved in, and not one that the
regulator should take lightly given the market position of VeriSign
operating the largest Certificate Authority and the wholesaler of 3/4 of
generic domain names.

Thank you for your time and consideration,
Greg Malone
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