[Comments-com-amendment-3-03jan20] Reasons why .COM amendments should be rejected for both ICANN's and the publics sake

[Bruce and Kris Edwards]

           I am a registrant of a .com domain name for personal use and I wish to comment on these proposed changes.



           The call for comments regarding the proposed changes that could result in (up to) 7% price increases per year for .com
domains purports to be justified by being in the public interest.  The summary fails to expound as to why this would be in the
public interest or why this is necessary.  The comments mentioned in the proposed amendments were vague and without
more detailed supporting reasons, do not rise to a compelling reason. The fact that no compelling reason was given for this
leads me to believe that Verisign has not given one.  From what we can see with other wholesale providers, the cost to the
wholesaler for .COM (In this case, Verisign) to support this should be substantially less  than what they are wholesaling it for.
Even with one 7% price hike on all of the .COM registrants, the extra money would be in the many 10s of millions of dollars
just for that 7% portion of the cost.  It is hard to understand what one 7% price hike would go towards (Let alone several
more hikes in the future that are compounded ).



           Given that this is for a registration function, proposing this type of price increase for this service seems excessive and
that would adversely affect personal and small business registrants in particular as well as set a precedence for open-ended
price increases in general.  This seems to be a poor reason to grant this change.  It should be incumbent for those requesting
this change to demonstrate why this is in the public good and how this would accomplish these goals.  I would have expected
more of an outreach by those proposing this change to those that would be affected by these changes (and price increases).
This would be the transparent and reasonable step to take.  Relying on the company that would benefit for price increases
to set these rates without other relevant parties involved seems to be a poor approach.



           The second troubling aspect of this proposal (especially for ICANN), is allowing Verisign to be both the wholesaler
of .COM domains as well as a Domain Registrar for .COM (directly or indirectly).  Given that the .COM domain is by far the
largest domain, this put Verisign in an anti-competitive position which would not serve those that rely on this service.  The
amendment states that you would rely on Verisign to set the rates and to have them dictating these changes at both the
wholesale level and retail level.   The possible advantages (since they wouldn’t have oversight) at the retail level, would
create an environment that could be abused.  International companies have been brought into court and sanctioned for
similar anti-competitive practices.  This might put ICANN into a position that could damage their reputation (As some might
see ICANN as party to this agreement) as an impartial governing agency which would be something that no one wants to see.



           As a result of reading the summary I have come to the following conclusions.  I have not found compelling reasons
for these possible reoccurring larger price increases and no effort on the parties presenting these changes to justify these
specific changes.  The adverse effects that this could have on personal and small businesses without any documented
positive benefits to the people using this service strikes me as a negative.  The open-ended possible price increases is not a
good model for many services as it bypasses justifying these increases to a larger audience that would be affected by these
changes and finally allowing VeriSign to be both the wholesaler and retailer of the .COM domains without any safeguards
to insure that VeriSign doesn’t have a benefit that other retailers would not have.



           In light of this, I would urge you to reject these amendments.

Bruce Edwards
bkedwards at edwardsbk.com




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