[Comments-com-amendment-3-03jan20] Comments on ICANN Amendment 3-03Jan20

[solsante vicepresident]

Good Evening,

It has come to my attention that ICANN has announced significant changes to
the contract it has with Verisign, Inc. that will result in increased
charges to organisations' costs to register their Top Level .COM Domain
names.  It has been suggested that wholesale prices could increase by 70%
over the next decade.

I am writing on behalf of The Sol Sante Club to express my dismay at this
prospect.  We are a non profit organisation staffed entirely on a volunteer
basis and work very hard to contain all of our operating costs.  I have
little doubt that there are thousands of such organisations facing the same
concern.

The information provided to me was separated into 4 areas and I have
commented on each of these below.


   1. *Price Increases*

   As noted above these increases will place a significant burden on a Non
   Profit organisation and I would urge that consideration be given to this
   fact in structuring future price increases.

   2. *Additional $20 Million*

   The information provided to me indicates that ICANN will receive an
   additional $20 million from Verisign Inc yet there is no information
   provided regarding how these funds will be used, why they are required or
   what kind of oversight, if any, will be implemented to ensure good use of
   the funds.

   This is simply poor business practice and is not at all aligned with the
   transparency you promote on your website with regards to your Privacy
   Policy.

   3. *Verisign Inc. may now operate as a Domain Registrar*

   I understand that this change will now allow Verisign Inc. to have a
   significant degree of control over the pricing of Domain Name registration
   and the reduced  number of competitors will potentially lead to higher
   prices to consumers.

   Not only does this seem unfair to the entire Domain Registrar business
   sector but, again, it is of great concern to non profit organisations such
   as The Sol Sante Club.

   4. *Dismissal of Comments on Previous Price Changes*

   I understand that when similar changes were being made to other Domain
   Names, such as .ORG, .INFO and .BIZ, some 3,500 comments were submitted but
   ignored.  In particular, a large number of comments were dismissed as
   "spam" solely because they were submitted via an online tool.  That fact
   alone should not be sufficient reason to dismiss comments without further
   investigation as to their veracity.

   I also understand that this, in turn, resulted in the decision to remove
   the price caps primarily relying upon a biased preliminary analysis from
   2009 by an economics professor that did not reference any data.

   Simply poor science / data collection / analysis and, again, poor
   business practice to reach a decision based on such poor and unsupported
   analysis.

*IN SUMMARY*:

I urge ICANN to review their position and revise their plans based on good
business practice and defendable decisions while also considering the
financial impact on non profit organisations.

Kind Regards,

*Tom Mitchell*
*Vice President*
*The Sol Sante Club*
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://mm.icann.org/pipermail/comments-com-amendment-3-03jan20/attachments/20200211/dca033cf/attachment.html>