[Comments-com-amendment-3-03jan20] Amendment and Commentary Criticism

Kevin Edwards consultkevin at yahoo.com
Fri Feb 14 21:15:36 UTC 2020

To Whom It May Concern,

> "ICANN org is not a price regulator and will defer to the expertise of 
> relevant competition authorities."

If you have been limiting wholesale registrar's prices and are now 
allowing higher prices, then you are, by definition, a price regulator 
or price fixer.

> "to support ICANN’s initiatives to preserve and enhance the security, 
> stability and resiliency of the DNS"

Was that already part of your mission or is that mission creep beyond 
basic name assignment?  In either case, you should clarify what exactly 
requires more money and how it will be spent, if you want public support.

It wouldn't be bad for ICANN to stop regulating prices if the result 
would be a properly competitive free market that naturally seeks lower 
prices for independent services, but the market is basically a monopoly 
at your level and Verisign is paying you to let them raise prices on 
other people.

As an aside, I have a friend whose self-named domain: stephaniewohar.com 
was hijacked or drop caught by Chengdu west.cn for unrelated spam 
purposes, and it would have cost her upper hundreds or thousands of 
dollars to recover, so I'm not particularly impressed with the cost 
effectiveness or current structure of your monopoly.

Kevin Edwards

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