[Comments-com-amendment-3-03jan20] comments on Amendment 3

Alexey Titov al.titov at gmail.com
Thu Feb 13 20:26:45 UTC 2020

Dear ICANN Staff:

I oppose Amendment 3 to the .COM Registry Agreement. I believe that
allowing wholesale prices for .com domains to rise 72% over 12 years, which
is far more than the rate of inflation and also far more than Verisign's
underlying costs of maintaining the registry could possibly increase by,
will dramatically hurt the internet ecosystem. It will especially hurt
small website operators, like myself, and will discourage internet users
from creating blogs and personal pages, with the end result of reducing
democratization of the internet.

Verisign reported a 69.4% operating margin in Q1 2019, so they clearly do
not need the extra revenue from this price hike. ICANN has granted a
monopoly over .com to Verisign and ICANN has a duty to every internet user
on the planet to carefully regulate this monopoly to prevent abuse by
Verisign. The only conscionable thing to do right now is to freeze
wholesale .com prices and re-evaluate 5-10 years from now. A policy that
allows price increases tracking the rate of inflation (but no higher) may
make sense in the future, but right now Verisign is already collecting far
more from their .com monopoly than any company would be able to in a
competitive market [1]. It's simply not right to allow them to raise prices
at this time.

- Alexey

[1] For example, Alphabet, a highly successful player in a very high-margin
industry, has an operating margin of around 25%. Verisign's operating
margin is over 2.75 times that.
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