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<p>Estimates say that the cost to manage the .com domain registry
does not exceed $3.50 per domain, per year, and the number might
really be significantly lower. Furthermore, other qualified
registrars/managers have proven the ability to operate other
domain registries for less than $1.00 per year. Based on this
information, there does not seem to be any legitimate reason to
raise .com domain rates to the proposed levels when the price is
already $7.85 per domain.<br>
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<p>If Verasign and ICANN can articulate a valid and evidence-based
reason for needing to raise the price of each .com domain, then I
could understand the request. HOWEVER, I read the proposed
amendment and the only reasons listed for raising the rates are
(1) imposition of any new Consensus Policy, or (2) documented
extraordinary expense resulting from an attack or threat of attack
on the security/stability of DNS. I have not seen any explanation
of what these would cost and how that would compare to the
proposed annual increase.<br>
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<p>However, based on Verasign's estimate of 144 million .com domain
names currently registered, we know factually that just in the
first 7% annual increase, Verasign would earn an additional $79.2
million.</p>
<p>If an increase in price is inevitable, I ask that ICANN consider
a much lower increase, such as 10 cents ($0.10) per year over the
next four years.</p>
<p>Thank you.</p>
<p>Patrick Sullivan<br>
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<p><span style="left: 376.2px; top: 120.378px; font-size: 20px;
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