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

Rob rob.comments at gmail.com
Tue Feb 11 16:27:43 UTC 2020

I'm concerned about the proposed changes for a three primary reasons:

1. No transparency into use of the $20 million ICANN will receive
If ICANN needs $20 million, then share a plan on what the needs are and how
it's going to be used. As ICANN is a non-profit organization, information
should be shared openly. If this is for hefty raises for ICANN upper
management, I strongly recommend that you reconsider.

2. The large price hikes over the next four years
Increasing wholesale prices 7% each year will cause .com domain prices to
become prohibitive to a large segment of individual and small business
domain owners. This should not be a money-grab, and ICANN should ensure
that the for-profit companies they work with are not price-gouging
customers. This looks exactly like a way to pad Verisign's bottom line
numbers, to the tune of upwards of $800 million. Compared to the $20
million ICANN will get, this is a bargain for Verisign. As stewards for
TLDs, ICANN should re-evaluate the rate hikes.

3. Allowing Verisign to act as both .com TLD operator and domain registrar.
This is clearly a conflict of interest, and allows Verisign to effectively
run in a monopoly-like fashion. This shouldn't be allowed. Period.

I hope these comments are taken into account, and weighted accordingly.
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