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

Paul Bertain paul at bertain.net
Mon Feb 10 23:41:13 UTC 2020

To whom it may concern:

I object to the amendment proposed for the .COM Registry agreement with Verisign and as a small business owner, the biggest complaint I have is with the cost increases.  The overall financial impact of this amendment is too generous to the businesses and does not accommodate the increasing requirement for businesses to be online; or another way to put it, this is a forced cost increase on an ever-increasingly vital and required business component.

They are tantamount to a 131% increase in cost over 6 years.  That is a very aggressive estimate of the economic growth for all .COM business owners to meet. While the registration cost is small, the impact is not.  If all cost inputs rose by 131%, we would see a much larger impact on the consumer / customer side of things. If Verisign wants to be the steward of the .COM TLD, they need to operate it in the best interests of the Internet community not in the interests of their corporate executives.  If they cannot do it, we should find another company who will, and there will be willing participants.

One other aspect I am concerned with is the apparent quid-pro-quo (very apropos to current political topics) from the Verisign payment of $20M.  I would like to see a better accounting for what is expected to come from that money.  I understand the specifics of DNS research cannot be determined 6 years in advance but how much is earmarked for the various security, research and other components listed in the amendment.  For $20M, I would expect a better listing than one sentence of vague topics.

Lastly, I do not agree that Verisign should be allowed to be both *THE* operator and a registrar, too.  This again feels like a hand-out to Verisign, who is not entitled to special treatment despite being *THE* long-time operator of the .COM domain.  It is important to maintain a system of checks and balances both as a demonstration of the effectiveness of a distributively managed system that DNS is and to preserve the integrity of it, as well.

I urge you to reject this amendment and request a better one that is just for both the .COM consumers (virtually all businesses these days) and providers.  If Verisign cannot truly act as the steward of one of the original and probably most important TLD, then they should step aside and they, too, can participate as a registrar and let someone else take up that mantle.

Paul Bertain
DNS Administrator & Operator and Small Business Owner for 22 years

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