[Comments-com-amendment-3-03jan20] Public Comment from David Spector

[David Spector]

To whom it may concern:

I am a reasonably intelligent adult, having retired after a 40 year 
career in software and Web programming. I have worked in companies large 
and small, including owning my own consulting company. I have attempted 
to read "THIRD AMENDMENT TO THE .COM REGISTRY AGREEMENT" and find that 
it uses legal language to such a degree that it is difficult to 
understand its full effects.

However, one thing is clear: it further moves ICANN into alignment with 
the for-profit objectives of VeriSign, Inc., a Delaware-based 
corporation well-known for its high prices and poor service.

The management of domain names is, in essence, a simple process based on 
the Domain Name System, which uses a mixture of a few dedicated 
computers and a very large number of shared, private, and public 
computers to maintain a simple distributed database of Authoritative 
Zone records and DNS caches that define the association between IP 
addresses and human-readable domain names.

This basic, low-cost system was extended to become a large system of 
Domain Name Registries who participate to further increase the cost of 
maintaining Zone records with very little added functionality beyond 
what could have been provided directly by ICANN through a public and 
secure automated interface.

In addition, ICANN does nothing to prevent large blocks of IP addresses 
to be allocated to countries and individuals having criminal or 
malicious intent.

I wish to raise my voice in protest to this Agreement, which appears to 
allow (and perhaps mandate) price increases of 7% per year for the next 
8 years.

Instead of prices increasing, they should drop dramatically, and 
management of the Domain Name System should be transferred to a public 
agency or other truly nonprofit and economically disinterested 
organization. Prices should be calculated based on the actual costs to 
maintain the TLD computers, their Internet connections, and the actual 
cost of an automated public interface and a small trained human staff 
for most activities associated with maintaining domain names.

Regardless of whether reasonable proposals for reducing the price of 
domain name management, making the current insecure Domain Name System 
secure, and eliminating the wasteful Domain Name Registries are adopted, 
this THIRD AMENDMENT TO THE .COM REGISTRY AGREEMENT should be canceled 
in its entirety, thus protecting the Web from the self-interested greed 
and collusion of financial interest of both ICANN and VeriSign, Inc.

If this Amendment does go into effect, opposing the interest of all 
Internet stakeholders including the general public, I hope that legal 
action will be taken against it. I would contribute what I can afford to 
such legal prosecution.

/s/ David Spector
56 Yale St.
Portland, ME 04103-3526
icann at springtimesoftware.com