[Comments-com-amendment-3-03jan20] Opposition to Price Increase

Rob Davis rob at intelliname.com
Wed Feb 12 19:42:42 UTC 2020

Concerning: .com Price Increase Opposition


I voice my opposition to your very existence in terms of the way that it is
being organized, operated upon, and managed in a biased method by
individuals that seemingly have too many connective compromises as it
relates to their positioning assignments and the duties they are entrusted
to uphold.


The naked and transparent weaponization of this organization and platform is
in fact seen by those who exist both in and outside of the operating
realities that you take for granted. The special fund assignments, luxurious
participation benefits, unscrupulous transitional planning, and mechanisms
by which you work to achieve your long term objectives are on the wrong side
of positive transformation. It should force intelligent reflection on
exactly why past actions of the US Department of Commerce and its respective
leadership chose to follow the path they did for oversight relinquishment. I
would also bring attention to the notable absence of resistance and public
opposition from some of the key leaders in the domaining sector. Especially
those that we have again entrusted and helped loyally build over two


There is no glory in the intentional creation and manufacturing of
additional burden to the millions of people who have been subjected to rely
on the internal ethics and integrity of your management. Compounded by the
fact that the subject Party that would benefit most from price increases was
but an extension of critical infrastructure assurance in the first place,
operating outside of transparent inclusion for free and open market
participation. They cannot and should not be integrated into your
organizational actions to produce added liquidity that is ultimately then
distributed to a select few individuals.


The handling alone of many of the facets related to thousands of new
registry creations should bring further light onto your management
competencies. Specifically your inability to forecast the need for any form
of protective guidelines regarding recommended price increase thresholds as
the most basic consumer protection mechanism. Or to rationally anticipate
what free reign of operation would do in stimulating literally millions of
new domain creations each year - issued at free or low cost to private users
- who would then utilize them in wholesale fashion to grossly expand an
already unprecedented rate of hostile attacks that can achieve outbounds as
high as 15 billion individual spam attacks daily.


This adds to a long and growing list of egregious deficiencies being
coordinated under your watch.


Including changes by which you would directly protect and limit the
responsibilities of active registrars, especially those involved in the
routine provision of domain privacy services to the worst of repeat
offenders. Your actions illogically increased response times in the fight
against denial-of-service and spoofing attacks being deployed against
responsible business owners. They also extend and compound the rate of
effectiveness for mass coordinated attacks that would utilize web addresses
as an active delivery method. Your management and decisions made there would
reduce the actions registrars are required to take, at the same time you
drive more mandatory privacy allowances.


In a world where every second of delay counts, your continued policy actions
reveal a great many things as it relates to where your priorities rest. Your
leadership direction has in turn also handicapped many of the world's
intelligence services to react quickly and swiftly against digital threats.
This impact of gross oversight and managerial negligence leads to millions
of dollars of compounded damages against a global productivity basis every
hour of every day. Yet your priority looks to satisfy shareholders, long
term colleagues, and even direct friendships as you would serve to let
profiteering further damage small business owners, hobbyists, collectors,
and the millions of individuals who have freely participated together to
build one of the greatest resources and collectives in human history. Shame
on you.


If you really feel the need to experiment with social engineering
constructs, may I recommend two concepts for you that can be easily employed
for short, mid, and long term improvements.


1.            Eliminate privacy services all together, as they serve little
functional use accept to protect against mass spam and attack campaigns by
abusers. Transparency of ownership details will in turn lead to more
efficient options to greatly reduce the level of spam attacks already in
existence. The concept of transparency is already being addressed and
implemented as a logical baseline for many social media platforms, as in
some cases millions of false accounts have already been identified and
deleted. Transparency to reduce harmful activities should be the minimum
standard and expectation that we set for ourselves digitally, especially in
our efforts to marginalize and help prevent billions of attempts of fraud,
phishing, spoofing, and the harmful delivery of many levels of threats and
viral distributions that happen each and every day. The alternative is to
see fraud-centered spam grow to the point of needing more radical solutions
to contain it.


                The Internet has been weaponized by a small handful of bad
actors, who recognize that sending 10-15 billion threatening emails a day is
reducing our ability to tackle real problems that exist. It impacts us
emotionally, reduces productivity, elevates stress and anxiety, products a
steady drip of individuals that reflect an image of theft and corruption,
and unfortunately aids to diminish (and bury!) the real encouragements,
messages, and connections we should be reviewing.


                An option for highly outspoken opponents who have the right
to demand for privacy freedom, and feel that open transparency in itself is
something they cannot support: make it available to them with two-step
authentication for initial setup. The objective here is to cut down the
millions of attempts made every minute to defraud others, and ultimately a
high ratio of success is better than spending precious moments focused on
enhancing Verisign's liquidity. Innovation and creativity will open much
greater doors in the long run than lobbyist influence.


2.            The second not-so-radical approach that should be implemented
immediately as a point of logical common sense: run a simple deep index
across every domain registration that exists. It is a number, it is a simple
exercise, and one that can be coordinated with basic keyword overlays as
well as secondary link extractions to build models that are directly being
used (by the millions) as delivery agents to threaten online users in this


                In plain terms: if there are roughly 400 million domain
names in existence, you can identify 25 million of them within a month that
are being used illegally to harm our world at the costs of billions of
dollars in gross productivity losses every week. Identify them. Double
authenticate the nefarious purposes of their use. Delete them.


                Then take a look at the small number of registrars who are
at large used as facilitation points to conduct this harmful activity, and
how ICANN's policy adjustments have actually compounded the rate of abusive
users online, not detracted from them.



If I had two other points I would share:


1.       If Verisign is in trouble and needs the boost, have one of our
super billionaires write a check for 115 million domains x the increase
proposal, place it in a trust, and let it pay out over the proposed
implementation period as an offset to help 80 million people who trusted
smart policy makers. 


2.       Then ask the major email platforms out there to spend some of their
vast gross riches and fortunes to invest into instant, accessible, and
intelligent methods to counter fraud and corruption being implemented almost
in majority through their singular email provisions. There is no reason that
spoofed emails (by the millions daily!) leading back to active Gmail
addresses should ever exist longer than 30 seconds from reporting. I don't
care who's uncle died and left them a fortune.



Robert Davis | Intelliname | twitter.com/Intelliname



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