[Comments-com-amendment-3-03jan20] Verisign

Grogan, Susan segrogan at smcm.edu
Fri Feb 14 17:43:49 UTC 2020

Friday, February 14, 2020

The Honorable Senator Elizabeth Warren, Senate Office Building, Washington
DC 20510

The Honorable Senator Amy Klobuchar, Senate Office Building, Washington DC

The Honorable Representative Steny Hoyer, 1705 Longworth House Office
Building, Washington, D.C. 20515
The Honorable Representative Nancy Pelosi, 1705 Longworth House Office
Building, Washington, D.C. 20515
Bureau of Consumer Protection, FTC

Bureau of Competition, FTC


Re: https://www.icann.org/public-comments/com-amendment-3-2020-01-03-en

To whom it may concern:

A few days ago, I was contacted by my domain name registrar advising that
Verisign was asking for pricing increases (about 30%)  that would
substantially increase the cost of holding the small portfolio of domain
names I own (10-20).  I think everyone should own a few because ownership
of the internet, its value, should derive from users, mainly the people
(real people, not corporations doing business as persons for purposes of
business law).  I am not looking to flip mine for a profit.  I have no
websites up.  The only websites I have put online were for teaching and
research purposes, paid for out of my personal income.  It is expensive
enough merely to put up, protect, and maintain a website.  To reach an
audience requires a campaign war chest to pay for social media and search
engine advertising.  I, like most Americans, am not wealthy nor a
fundraiser.  The cost of owning a few domain names is not a cost of doing
business for me since I don't own one or have any plans in that direction.

The internet should be first and foremost a resource that enhances public
speech, the internet should belong to the people.  But, so that the
internet remains open and free, I understand we must rely on both private
and government, or quasi-governmental agencies to manage
necessary infrastructure.  Unfortunately, it seems that the internet is
plagued with potholes, worse than our highways.

Until I was contacted by my registrar 2 days ago, I had never heard of
Verisign and was only vaguely familiar with ICANN.  I recall paying ICANN
fees to my registrar that are very low.  What I did not know is that a
substantial part of the substantial annual cost paid to my registrar just
to own them, whether I do anything with them or not, goes to Verisign.
Amendment 3 will increase those costs dramatically and also change the
structure of the internet to increase the monopoly Verisign holds over the
internet.  Verisign already has no competitors, already is a monopoly
contractually.  On the other hand, there are very many
domains and domain registries.  These compete on price; but, from what I
can see, are highly constrained in doing so because all of them must pass
on considerable fixed (Verisign) fees to consumers and other owners of
domain names.

Verisign is publicly traded and has outperformed all stock markets
substantially.  Most public comments are going to complain that Verisign
already makes too much money and has not specified why they need to make
more.  That's easy to predict because that's pretty much all the public
knows and has been told.  The only reason Verisign gives to demonstrate the
need, is a generalized, vague statement about the need to safeguard
internet security.  I would think that if they had specific plans for
improvements to what they already do--since protecting the internet
essentially is also Verisign's mission statement--they would have a
specific budget and that they would be pitching these plans through the
roof because they are publicly traded--it's both in their interest to
disclose and required by accounting standards and the SEC.

Verisign has already bullied the same for .org and other domain types.
Thousands of public comments objected.  Only a few voiced in favor, which
implies almost all those who would personally profit from these price
increases did not even bother to submit a letter voicing their
approval.  Why? Because like the present case, the old public comment
process was merely an excuse going through the motions, not a serious
solicitation and consideration of public comments.  I am told the public
comments against were all dismissed as "spam" for the earlier case.  I
think there was a little more to it.  The usual reason most public comments
against are dismissed is that they do not rise to the technical and legal
standards necessary to require explanation and/or reconsideration.   You
have to be an expert in the field or a lawyer to
submit comments that matter these days, especially in this case of a
high-tech company that acts in the background of the internet, in the
shadows of our lives.

The only comments likely to stop this process, or most any other process
from Keystone to health and safety regulations are lawsuits or credible
threats to sue submitted in comments in the absence of sincere federal,
indeed international, regulation and oversight.  I don't see that
happening.  We don't have a public union.  Registrars are not well
organized.  And, I doubt anyone could recover the substantial legal fees.

ICANN is supposed to regulate Verisign but seems to be surrendering their
responsibilities.  Verisign gave ICANN a considerable sum of money to make
these changes happen.  This, I presume, was to pay ICANN's costs but the
amount seems more like paying for all of ICANN's bonuses and new corporate
memberships at Mar-A-Lago.

As a monopoly, Verisign minimizes risk by definition.  In a free market,
stock values are supposed to reflect risk.  High tech firms generally earn
more because they face the added risk of the technology itself.  The
internet has been around for Verisigdecades now.  I don't see there being
that much risk to the internet failing.  Verisign's only risk has been and
is keeping the internet secure but in a very limited way.  What[
<#_msocom_1>do they plan to do different? Build a Wall around the
internet?    Overall, I don't judge the internet a safe place.  I don't
believe and Verisign has
not convinced me as a member of the public that the internet is going to be
safer if Verisign gets these price increases.

Verisign has extremely (abnormally) high operating profits and net
incomes.  I am not going to go into those specifics because I am objecting
to the process itself.  The public has not been given adequate knowledge or
time to make credible objections.  Essentially,
*the Amendment 3 public comment process is fraudulent*.  There is reason to
suspect ICANN has been paid off and will not see to the public interest.
We have been given no reason to justify the price increases.  They know the
public can only object to the price increase itself and
that objecting to price increases will be easily dismissed by free market
reasoning.  The problem is that the public, average folks, have no other
place to go.  They used to say the crooks were in the banks because that's
where the money is.  Today, the crooks seem to camp out
in Verisign and ICANN.  I ask that the price increase be denied due to
unfair process according
to principles of the free market, free internet, and free speech.  ICANN
should require and publish a detailed review explaining what they want to
do that requires this price increase and what they want to achieve by it
besides jacking up their stock price before the next heist.

The US Department of Commerce should have gotten off its soup can and seen
that it was so instead of conspiring with Verisign and ICANN to further
usurp the internet. Since I do not think public comments are being
solicited with sincere intents, I am forwarding my own to above members
asking Congress to hold hearings on the past and present process by which
these price increases and encroachment on our freedoms have been conducted
by US Department of Commerce, Verisign, and ICANN.  That’s the only way the
public is going to have the information necessary to judge and comment.

Thank you for your consideration and assistance,
Dr. Susan Grogan

Professor of Political Science

St. Mary's College of Maryland

St. Mary's City, MD 20686


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