[Comments-com-amendment-3-03jan20] Changes to .COM domains

[Max Davies]

Dear Sirs,

The announcement that ICANN has agreed new terms behind closed doors with
Verisign without the input from registrars and the wider internet community
is something of a concern.  The agreement announced, amongst other things,
also appears to ignore a significant conflict of interest by not denying
Verisign, through the possibility of investment through a 2nd company, to
act as both gatekeeper for the dotCOM domains and to become a registrar in
it's own right.

Further, pricing changes allowed in the agreement would permit Verisign to
increase wholesale pricing year on year (as well as allowing other price
increases) and thus make the domain suffix far less accessible and more
expensive for everyone at a time when the technical costs of management are
in fact reducing - it could in effect act to enable Verisign as a monopoly
for the TLD.  This move is ultimately bad for consumers and registrars,
though is clearly a windfall for Verisign investors at the expense of
everyone else.  Additionally, the sum that has been agreed to be paid by
Verisign, some $20M also appears to be absent of the proper clarity of
investment receipts one might expect of ICANN and there is little if any
information on who is to provide the appropriate governance and how this
funding will used to benefit domain infrastructure.

All in all, this agreement seems to run counter to the transparency and
engagement principles upon which ICANN is supposed to be based and as such,
it would be improper other than to suggest that ICANN needs to carefully
reconsider the amendment, publish what guidance formed part of the
discussions with Verisign, and incorporate the views of the wider community
and registrars who appear to have been entirely absent from the forum.

Yours faithfully,

D. Maxwell
CTO, Xenon Design Group
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