[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement

David Riordan dave at reflex.com
Fri Feb 14 23:43:14 UTC 2020


I am not sure that there is much point to this exercise since I previously
submitted a comment regarding the .org contract and sale, but you ignored
it and the overwhelming majority of opinion and more insultingly described
them as spam.  Nonetheless...

I work for a company that owns and operates businesses on multiple .com
domains and am writing on my own behalf.

I am against the proposed price increase to .COM domains, for all the same
reasons I was against lifting the price cap for .org names.

The current rate of $7.85 is already far more than justified, as the actual
costs to manage the database and servers is approximately one third of that
amount and will likely continue to decrease into the future.

Verisign is merely your manager of the .COM Registry with a perpetual right
of renewal, granting it monopoly power.  As such, you should maintain the
price regulations that have been in place, since Verisign is not subject to
market forces or a competitive bidding process.

ICANN is supposed to govern the domain name system in the public interest,
not for Verisign or for the $20 million kickback they have proposed to you
in order to renegotiate a contract that has 4 years remaining on it.

I am also against any implementation of URS to any of the established TLDs
as the UDRP process has proven to be more than adequate at resolving domain
name/trademark disputes.

Finally, I am utterly disgusted by the failure to follow the
multi-stakeholder based, consensus focused processes that ICANN is supposed
to follow, as well as the actions of current and former staff that indicate
the blatant appearance of, if not actual, corruption.

Count me as shocked if my comments are actually taken into consideration
and acted upon

David Riordan
Tampa, Florida United States
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