<html>
<head>
<meta http-equiv="content-type" content="text/html; charset=UTF-8">
</head>
<body>
<center></center>
Hello,<span class="commtext c00">
<p>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.</p>
</span><span class="commtext c00">
<p>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.</p>
<p><br>
</p>
<p><span class="commtext c00">[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. <br>
</span></p>
<p><span class="commtext c00"><br>
</span></p>
<p><span class="commtext c00">-Dane Kouttron</span></p>
<p><span class="commtext c00"><br>
</span></p>
</span>
</body>
</html>