[Comments-com-amendment-3-03jan20] Comment on proposed .com wholesale cost change

RL Hawkes rhawkes at chignecto.ca
Thu Feb 13 19:44:34 UTC 2020


I would like to take advantage of the opportunity to comment on the proposed amendment to the .com agreement with Verisign in order to implement the proposed 7% pa increase in wholesale registration and renewal costs over the next 4 years of a 6 year contract.  While at first glance 7% may seem like a minor increase, when compounded over a number of years, the 7% increases will be substantial. The net effect will be to weaken the .com as the primary choice for domains around the world, and indirectly harm all of those who have invested in building the strength of the extension.

I realize that most other TLDs are not capped but the situation for .com is quite different. Verisign did not create the .com extension, although they have been worthy stewards of it for many years. They did not take the investment risk of needing to bid and develop it like the new gTLD registries. The economies of scale of .com should make it possible for the per domain wholesale cost not to rise significantly. 

The contract extension was awarded without competitive bid.  Most experts suggest that had it gone to competitive bid, the wholesale cost would be much less than the current cost. It is a unique situation as it could be argued that the value of a year’s .com registration might well be worth 7% more. On the other hand, holding a monopoly as caretaker of the world’s primary TLD, price increases should need to be justified on basis of need for economic viability.  Having gone through Verisign financial statements,  I do not think that there is any support for the need for such an increase. 

I therefore oppose the proposed increase.  Thank you for the opportunity to comment on this matter.

sincerely,

Bob


Bob Hawkes
Domain Analyst, Investor, Writer
Victoria, BC, Canada









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