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

[Volker Greimann]

I am a registrant of a .com domain name and work in the domain name 
industry.

The new registry agreement contains various concerning issues that must 
be addressed before the agreement can proceed.

The way that increases in registry fees are negotiated between ICANN and 
the Registry operator is anti-competitive and violates the rights of the 
parties that will ultimately have to pay these fees. Change in registry 
fees should be subject to negotiations between the parties to the 
registry-registrar agreement, e.g. Verisign and the accredited 
registrars and subsequently subject to review and approval by ICANN (to 
compensate any inequalities in negotiation powers).

ICANN unilaterally agreeing to changes to registry fees without 
consulting the parties subject to those fees is anti-competitive and 
essentially disenfranchises registrars of their negotiation powers.

I also am concerned about the proposed changes to the registry-registrar 
agreement that are included as part of the amendment of the registry 
agreement. Essentially this amounts to creating new obligations for 
contracted parties and registrants through the back door without policy. 
ICANN is proposing to create new obligations for parties that are not 
even at the table in these negotiations. Any changes to the 
Registry-Registrar agreement that create new obligations for either side 
cannot be unilaterally imposed by ICANN or the registry operator, but 
must be negotiated and/or approved by the parties to that agreement, 
subject to ICANN approval.

Sincerely,

Volker Greimann
Saarbrücken, Germany
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