[Comments-com-amendment-3-03jan20] Reject proposed amendments to .COM TLD management and fees

[Michael Chupa]

The details provided on the ICANN.org site indicate that wholesale pricing
for .COM TLD registry services has been static at $7.85 since 2012. CPI
data shows that the aggregate inflation index since 2012 was 255.657 (avg.
CY 2019) / 229.594 (avg. CY 2012) or a total of 11.4% over eight years, for
an annual rate of ~1.4%.

The proposed changes provide that, "..., among other things, Verisign and
ICANN may agree to amend the .COM Registry Agreement to permit an increase
to the price for .COM registry services, up to a maximum of 7 percent in
each of the final four years of each six-year period (the first six-year
period commenced on October 26, 2018). The proposed Amendment 3 to the .COM
RA reflects this change, essentially restoring the pricing structure from
the 2006 .COM Registry Agreement." As an illustration, a 7% increase in
2020, 2021, and then in each of 2024-2027 inclusive would yield an
aggregate price increase for .COM domains of 50.1%, for an annual rate for
2020-2027 of ~5.2%. Clearly, this is an excessive price increase, based on
the past eight years of inflation data. Unless ICANN, Verisign and the U.S.
DOC and DOJ can provide details justifying cost increases outpacing
inflation by nearly a factor of four, this proposed amendment must be
rejected as unfairly burdensome to .COM registrants.

Coupled with the fact that Verisign is benefitting from decades of U.S.
taxpayer-funded research and development, leading to the existence of the
.COM TLD, prior to any cost increases associated with the operation of the
.COM TLD, there should be a full audit of the actual costs of operating
.COM, along with any proposed changes or enhancements of DNS as outlined in
the proposed amendment. Any cost increases passed on to consumers and
wholesalers of internet domain name services must be tied directly to
actual costs, and not hidden in yearly "cost-of-services" increases without
justification. Further, a U.S. DOC and DOJ inquiry should be initiated to
assess whether a core network provider such as Verisign has an innate
conflict of interest in managing any TLDs, much less securing
hyper-inflationary cost increases with the cooperation of ICANN.

Sincerely,
Michael A. Chupa <chupa at acm.org>
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