[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
volker at greimann.email
Thu Feb 13 09:58:49 UTC 2020
I am a registrant of a .com domain name and work in the domain name
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.
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