[Comments-com-amendment-3-03jan20] Deny passing Proposed Amendment 3

[Dale]

The proposed amendment 3 should not be passed in current form.

1. While the pricing allowances are in line with Amendment 35, it is a loss
to ICANN to take a $20M USD flat payment in this exchange.  To create a
stable source of funding for initiatives ICANN must consider a fixed rebate
percentage tied to all wholesale domain transactions on .COM through
registry operators.  Decoupling the payment from the service serves only
one party: the for-profit entity Verisign.

2. Verisign should NOT be able operate its own registrar or act as a
reseller in which direct profits are obtained by line item domain
registration.  Combined with the price controls this is a severe conflict
of interest.  The language must specifically bar Verisign from engaging in
domain registrar activities, directly or indirectly.

-Dale Liszka
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