<html><head><meta http-equiv="Content-Type" content="text/html; charset=utf-8"></head><body style="word-wrap: break-word; -webkit-nbsp-mode: space; line-break: after-white-space;" class=""><div class=""><span style="font-size: 14px;" class="">Hello,</span></div><div class=""><span style="font-size: 14px;" class=""><br class=""></span></div><span style="font-size: 14px;" class="">I find the proposed changes to your contract with Verisign extremely alarming. There is potentially some very valid reasons for price increases to domains, such as freeing up domains bought up in bulk with the propose of reselling with a markup. However, there is much to be worried about in terms of general accessibility and the specifics of these changes. In particular, there is at the very last the appearance of some major conflict of interest. Some of these concerns were demonstrated to me by my domain registrar, NameCheap:</span><div class=""><div class=""><h2 class=""><span style="font-size: 14px;" class="">1. Price Increases</span></h2><p class=""><span style="font-size: 14px;" class="">Verisign will be allowed to increase the wholesale price to
registrars for .COM domains by 7% each year in 2020, 2021, 2022, and
2023. After a two year “freeze”, Verisign can increase prices by 7%
annually during 2026-2029, then another two year “freeze”. This cycle
will continue, meaning that within 10 years, .COM domains could cost
approximately 70% more than the current wholesale price of $7.85 — and
the sky is the limit.</span></p><p class=""><span style="font-size: 14px;" class="">It is not clear how much of these price increases registrars will
pass along to consumers, but it is likely that most of these increases
will be paid by domain name registrants. The contract does allow for
other price increases for certain extraordinary situations, so it is
possible prices could increase more than anticipated. </span></p>
<h2 class=""><span style="font-size: 14px;" class="">2. ICANN Will Receive an Extra $20 Million </span></h2><p class=""><span style="font-size: 14px;" class="">With the contract changes, Verisign agreed to pay ICANN an additional
$20 million dollars over five years to support ICANN’s initiatives
regarding the security and stability of the domain name system. There is
no explanation why Verisign did this, how ICANN will spend the money,
or who will ensure that the funds are properly spent. </span></p>
<h2 class=""><span style="font-size: 14px;" class="">3. Verisign Can Operate as a Domain Registrar</span></h2><p class=""><span style="font-size: 14px;" class="">ICANN also had rules that the operator of a TLD could not operate a
domain name registrar. Although in 2012 ICANN allowed operators of new
gTLDs to have domain name registrars, it did not apply to Verisign. The
new contract will allow Verisign to operate its own registrar, except
for selling .COM domain names itself. To circumvent this, it is also
possible that Verisign could act as a reseller of .COM domains, through
another registrar.</span></p><p class=""><span style="font-size: 14px;" class="">This result is that the company that controls almost 80% of the
registrar pricing for domain names will compete directly with all domain
registrars, maximizing its control of domain name pricing to the
detriment of other competing registrars. While this might result in
lower prices to consumers, fewer registrars will harm competition,
choice, and domain name services. </span></p><p class=""><span style="font-size: 14px;" class="">Verisign’s registrar could also use its dominant position to charge
higher prices to consumers, while at the same time raising registrar
prices. </span></p>
<h2 class=""><span style="font-size: 14px;" class="">4. ICANN Ignored Previous Comments</span></h2><p class=""><span style="font-size: 14px;" class="">As detailed on <a href="https://www.namecheap.com/blog/ensuring-icann-keep-domain-prices-in-check/" class="">Standing Up to ICANN to Keep Domain Prices in Check</a> and <a href="http://pricecaps.org" class="">pricecaps.org</a>,
over 3,500 comments were submitted in support of price controls for the
.ORG, .INFO, and .BIZ TLDs. Only six comments supported removing price
controls. ICANN discounted the comments that were in favor of
maintaining price caps. A number of the comments were submitted using an
online tool, which caused the comments to be discounted as “spam” by
the ICANN Ombudsman. </span></p><p class=""><span style="font-size: 14px;" class="">ICANN removed the price caps, primarily relying upon a biased
preliminary analysis from 2009 by an economics professor that did not
reference any data. </span></p></div></div></body></html>