- comments-com-amendment-3-03jan20@icann.org

[Comments-com-amendment-3-03jan20] Impeach icann
by Daniel Wruck Feb. 13, 2020

Feb. 13, 2020

I am a registrant of a .com domain name. Why are you going into collusion with a greedy company to raise rates? The current rate of $7.85 is already far more than justified. Daniel W Indiana

1 0

[Comments-com-amendment-3-03jan20] Comment in opposition to Proposed Amendment 3 to the .COM Registry Agreement
by pub 144 Feb. 13, 2020

Feb. 13, 2020

To Whom it May Concern, I am a dot com domain registrant and I am deeply disappointed to hear that ICANN is proposing a new contract amendment with Verisign, the operator of the dot com registry that, among other things, will impose a string of annual price increases on domain registrants. Unfortunately, almost everything you hear these days coming out of ICANN is negative for domain registrants and positive for domain registries. Registrants, the most important part of the domain name ecosystem, are the least valued, and their pocketbooks are treated as a playground for powerful companies such as Verisign. You hear people say, “well, it’s only a dollar a year. It doesn’t really make a difference. I can afford it.” But I believe it’s important to see the forest for the trees. When viewed in the aggregate, this proposed price increase does in fact make a difference when you consider that it will have a negative financial impact on over a hundred million dot com registrants worldwide. Beginning in the first year, dot com registrants will lose approximately $100 million due to this price increase, By the end of the contract, 2024, the annual loss to consumers will be approximately $300 million. By any standards, that is a massive giveaway to the operator of the dot com registry that comes straight from the pocketbooks of mom and pops, small businesses, entrepreneurs, and other individuals around the world. ICANN has agreed to grant Verisign the right to seek not just one price hikes, but a string of four annual price hikes up to 7% a year which will, on a cumulative basis, significantly increase the price of dot com domains by the end of the contract term. Verisign is seeking to implement the maximum 7% increase allowed under the proposed contract. That 7% price increase is well above any common measure of inflation, which currently runs around 2% annually. How can a price increase of 7% possibly be justified? Further, the cost to operate domain registry services on a per domain basis continues to decrease. Thus, ICANN should be seeking price decreases for domain registrants rather than price increases. Let alone price increases that are 300% above the general rate of inflation. The unchallenged position of Verisign as the sole operator and perpetual incumbent of the global behemoth dot com domain extension with creates an unhealthy imbalance of power in the domain name system that ICANN is ill-equipped to manage. Registry operators such as Verisign are contracted parties that operate according to ICANN’s terms, not the other way around. Yet, the proposed contract perpetuates this imbalance and grants Verisign even more economic profits and corporate power. (It should be noted that my comments are not directed at Verisign in particular. Indeed, any company that was granted the unchallenged right to oversee the dot com registry and virtually dictate the terms of its contract would assume such outsized financial and political power. ICANN is solely responsible for creating and perpetuating the existence of such as Frankenstein. ICANN states that it is not a price regulator. However, the DOJ and DOC are not interested for political purposes in fulfilling such a role, so then who is in charge of protecting global consumers from abuses of pricing power in the domain name system? It seems the registries are in control and imposing their wishes upon consumers through ICANN’s policymaking processes and domain registrants have no one looking out for them. ICANN seems content to pass contracts which bestow upon registry operators uncontested price increases and even removals of all price protections for consumers, and if registrants don’t like it, they are forced to pursue costly private litigation to prevent the price hikes from being imposed upon them. That is untenable and unfair. As ICANN must know, even at the $7.85 annual wholesale fees Verisign has been limited to since 2012, Verisign Corporation has already grown into a financial behemoth. It operates with unrivaled levels of profitability by commonly-accepted financial measures such as operating margins and EBITDA. As a result of its no-bid, perpetual right to operate the dot com registry, Verisign operates as a massive cash cow and pockets virtually all of the income from charged for dot com domain registrations. Each year, Verisign has more than $600 million in profits that it has no use for and does nothing with but buy back its own stock. This is money that comes straight from the bank accounts of domain registrants. And now ICANN is working with Verisign to implement price hikes that by 2024 will add an additional $300 million a year to the enormous annual windfall that Verisign already enjoys. ICANN must be aware that that money is coming from the pockets of businesses and individuals, akin to a massive private tax imposed upon registrants. Those millions of dollars that will be going to one large private company at ICANN’s behest are being sucked out of communities and out of households which have far greater need and purpose for the money than an already fatly rich company does. Worse, many dot com registrants come from poorer parts of the world, where domain registrations are a luxury, and ICANN is making the promise of an opportunity to escape poverty harder to achieve by raising prices on these less fortunate registrants. ICANN has stated that the comments period is an important part of enforcing the multi-stakeholder model. However, we have seen ICANN attempt to disregard thousands of comments opposing price increases and removal of price caps on the dot org extension. ICANN’s own ombudsman attempted to rule out thousands of comments opposed to the dot org contract amendment on the grounds that they were engineered by one trade association. ICANN, here is the hypocrisy of the comments period and of what happened in the dot org comments period and what is happening in the dot com comments period now: ICANN has no requirement incumbent upon registrars, and itself makes no effort whatsoever, to notify domain registrants that a comment period has been opened during which registrants can voice their opinion against such price increases. So, you have a situation where just a tiny percentage of the tens or hundreds of millions of impacted registrants are even aware that such a price hike is being proposed. How can they possibly let ICANN know that they oppose the increases if they are not aware of them? If all those registrants were notified and urged to comment, ICANN would receive hundreds of thousands or even millions of comments against the increases. Yet, it seems ICANN and its registry partners seem to prefer the status quo and operating with little public awareness of these changes that negatively impact the average registrant. And when an independent entity attempts to expend its own resources to help make registrants aware of the comments period and encourage them to submit a comment for or against the contract changes, instead of thanking that entity for its help in engaging the public in the multi-stakeholder model ICANN supposedly supports, ICANN goes out of its way to criticize that entity as a “self-interested” party and does what it can to delegitimize all comments that came from its laborious efforts to raise public awareness. How can anyone but conclude that ICANN and the powerful registries seem to prefer operating in the dark, and public engagement in the policymaking process is in fact not valued or even wanted by ICANN or the registries. It is worth noting that in winning the auction to operate the .web domain extension several years ago, Verisign - disguising its identity through the use of a stalking horse bidder -, opted against an auction format that would split the proceeds amongst the many other bidders competing for the .web extension, as was commonplace in other auctions with multiple bidders during the rollout of ICANN’s new gtld program. This maneuver had the effect of directing the entirety of Verisign’s $135 million bid solely to ICANN, rather than being shared amongst the losing bidders. Hence, Verisign paid $135 million AND secured the single domain extension that was widely agreed to present the greatest competitive challenge to Verisign’s dot com extension. That series of events prompted a Department of Justice investigation, (which in fairness was closed without remedial action). Nevertheless, the .web incident is important because many have noted that as part of granting the proposed contract which grants highly lucrative financial gains to Verisign, ICANN has also arranged a $20 million payment for itself from Verisign (ostensibly to promote efforts to maintain security of the domain name system). While it is indeed circumstantial, I would propose that readers of this comment consider the $135 million payment that Verisign made to ICANN as part of the atypical .web auction process in the context of this proposed lucrative contract renewal, in addition the $20 million that Verisign is paying to ICANN in conjunction with the new contract. ICANN must be blind not to see how this is being perceived by the general public and the media as a quid pro quo or payoff for approving the contract with price hikes. This may or may not be true, but perceptions matter. ICANN has created the perception that it is incapable of fair policymaking, that it is in the service of powerful companies it is supposed to oversee, that it favors those powerful few companies over the many million of registrants who do not have the same financial clout and small army of consultants and lobbyists who work the insides of ICANN and Washington to promote their own agenda the way those companies do. Despite the appearance of soliciting community input through comments periods, ICANN really has no true mechanism to protect the interests of registrants and, based on its actions, seems to be okay with that. That is deeply disappointing. With such actions as approving the price hikes contained in the proposed contract amendment, ICANN seriously risks losing its legitimacy as an impartial governing body. Domain name registrants need a strong, fair, and trustworthy governing body that looks out for the rights of registrants too. I oppose the proposed contract amendment and call for ICANN to amend it to better protect consumers from unwarranted price hikes. ICANAN can do this by eliminating the price increases it has granted as part of the contract, or reducing the size of annual percentage increases on dot com fees granted therein. I also propose that, in return for maintaining the perpetual, no-bid contract to operate the dot com extension, ICANN should consider requiring Verisign to relinquish the right to operate the dot net and dot web extensions in an effort to promote vibrant competition among domain registries and prevent concentration of power in the domain name system. Further, ICANN should make all efforts to put the contract to operate the dot com registry out to bid and let the market decide what the wholesale cost of a dot com should be based on those bids. Open bidding to operate the dot com registry would undoubtedly result in LOWER prices for consumers, not the ever-increasing annual registration fees that registrants are forced to endure under this perpetual, no bid contract ICANN has bestowed upon Verisign. Respectfully Submitted, Matthew Klein

1 0

[Comments-com-amendment-3-03jan20] To Who--icann,
by Imago Dei Feb. 13, 2020

Feb. 13, 2020

As a small business owner and a sole proprietor I'm concerned about .com rate increase in the coming years. I may have to drop a site because so I can afford to operate and support my family. Please attend to this and fight for those of us who have smaller operation that cannot easily absorb rate increase. Thanks. Sincerely, Chris Cavanaugh http://www.ChrisCavMusic.com http://www.musiclessonsnh.com http://www.weddingmusicnh.com FACEBOOK: https://www.facebook.com/suzukiviolinstudio https://www.facebook.com/ChrisCavmusic cell/text 785 1884

1 0

[Comments-com-amendment-3-03jan20] Proposed.Com price increase
by Kevin Deutsch Feb. 13, 2020

Feb. 13, 2020

Please do not increase the cost to maintain my .com domains. An increase will cause a huge hardship. Thank your...Kevin

1 0

[Comments-com-amendment-3-03jan20] Do not increase .COM prices
by Bojidar Kardalev Feb. 13, 2020

Feb. 13, 2020

This price hike will have a stifling effect on a lot of small businnesses and initiatives online. Internet's inception was based around fundamental ideas as freedom of expression and enterprise. And now more and more it's about different groups trying to 'privatize' it and get a piece of the pie. Keep it's spirit alive! Don't raise the prices!

1 0

[Comments-com-amendment-3-03jan20] Comment on amendment
by Joe Pavlisko Feb. 13, 2020

Feb. 13, 2020

Hello, These price increases are an obvious way to generate an extra $500 million without doing any extra work, an unacceptable and dishonest increase. If the price increases go through, I will advocate that the rights to register for .com domains be transferred to another party. Thanks, Joe Joe Pavlisko Full-Stack Developer P 440 488 5055 [image: www.alpha-sense.com] www.alpha-sense.com

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3
by Victoria Tennant Feb. 13, 2020

Feb. 13, 2020

I strongly oppose the "Proposed Amendment 3 to the .COM Registry Agreement". It is a monopoly and will hurt small businesses. Victoria Tennant

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Andrei Igna Feb. 13, 2020

Feb. 13, 2020

Hi, I am a registrant of a .com domain name and I am against the proposed price increase to .COM domains. No one other than Verisign want increases in .COM prices. The current rate of $7.85 is already far more than justified. Hope you can do something about this Andrei Ig Barcelona, Spain https://andrei.net

1 0

[Comments-com-amendment-3-03jan20] No
by daniel.gordon Feb. 13, 2020

Feb. 13, 2020

No increase is needed

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Justin Godfrey Feb. 13, 2020

Feb. 13, 2020

I am a domainer (I invest in domain names as a business). I am also a US Air Force Veteran and have been running my own domain name business for the past 13 years. It has allowed me to attend every school function with my children and put them to bed at night. An increase in .com domains would significantly impact my business. I am against the proposed price increase to .COM domains. No one other than Verisign want increases in .COM prices. The current rate of $7.85 is already far more than justified. Verisign is merely your manager of the .COM Registry – it has no business dictating the price. ICANN is supposed to govern the domain name system in the public interest. Justin Godfrey Marquette, Michigan United States -- Justin Godfrey Domain Investment Services Inc Marquette, MI

1 0

[Comments-com-amendment-3-03jan20] Don’t shut out small entrepreneurs
by Horace Torys Feb. 13, 2020

Feb. 13, 2020

The internet deserves transparency and accountability for all decisions affecting everyone. Price increases will hurt small entrepreneurs. Please change your policy to include us all. Jay

1 0

[Comments-com-amendment-3-03jan20] Concerns about increases
by Ty Johnston Feb. 13, 2020

Feb. 13, 2020

I have four main concerns with ICANN’s decision: *1. Price Increases* 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. 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. *2. ICANN Will Receive an Extra $20 Million * 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. *3. Verisign Can Operate as a Domain Registrar* 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. 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. Verisign’s registrar could also use its dominant position to charge higher prices to consumers, while at the same time raising registrar prices. *4. ICANN Ignored Previous Comments* As detailed on Standing Up to ICANN to Keep Domain Prices in Check and pricecaps.org, 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. ICANN removed the price caps, primarily relying upon a biased preliminary analysis from 2009 by an economics professor that did not reference any data. This is bullshit and you know it :)

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Eyuphan OZDEMIR Feb. 13, 2020

Feb. 13, 2020

I use the Internet but I am not a .com registrant. I am against the proposed price increase to .COM domains. No one other than Verisign want increases in .COM prices. The current rate of $7.85 is already far more than justified. Thanks for your valuable time. Eyuphan Ozdemir Bursa, Bursa Turkey Sent from my iPhone

1 0

[Comments-com-amendment-3-03jan20] small business and club manager
by JesSwift DotDotDot Feb. 13, 2020

Feb. 13, 2020

we use .com for our organization and for my very small business. any increase in cost will make it difficult to maintain a web presence apart from social media please keep costs for the small guy low thanks Jes dotdotdottshirts.com dotdotdottshirtproductions(a)gmail.com Facebook <https://www.facebook.com/DotDotDottshirtproductions/> Twitter <http://twitter.com/dotdotdot_tshir> Instagram <https://www.instagram.com/dotdotdottshirts/?hl=en> 784-571-4368

1 0

[Comments-com-amendment-3-03jan20] Keep the pricing fair
by Stuart Brent Feb. 13, 2020

Feb. 13, 2020

Please maintain transparency in the Verisign / ICANN relationship, and do not hike domain registration costs arbitrarily. A fair and open internet means accessibility to all, and lower prices help accessibility.

1 0

[Comments-com-amendment-3-03jan20] Amendment Comment
by Matt Mleziva Feb. 13, 2020

Feb. 13, 2020

Request you not take actions that would raise the price of domain name registrations – support freedom of speech! – thanks & cheers, Matt Sent from Mail for Windows 10

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Amit kirkole Feb. 13, 2020

Feb. 13, 2020

1 0

[Comments-com-amendment-3-03jan20] Against this amendment
by Karademir, Ertugrul Feb. 13, 2020

Feb. 13, 2020

Dear ICANN, Internet has been a good money source for a lot of companies who have contributed a little but demanded their cut. If you squeeze your user too much though, people will choose choice over convenience. Ertugrul Karademir Senior Software Engineer

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Wayne Gonzales Feb. 13, 2020

Feb. 13, 2020

I am a registrant of a .com domain name. I am against the proposed price increase to .COM domains. Verisign is merely your manager of the .COM Registry – it has no business dictating the price. ICANN is supposed to govern the domain name system in the public interest. Wayne Gonzales Tustin, California United States Sent from my iPhone

1 0

[Comments-com-amendment-3-03jan20] Proposed price increases of .com
by Diane Bush Feb. 13, 2020

Feb. 13, 2020

Absurd that there would be such massive price increases proposed to a .com domain name. You will be taking advantage of countless small businesses who operate on minimal funds, yet make a huge impact in the community. NO price increases.

1 0

[Comments-com-amendment-3-03jan20] .com price increase
by Bob Coleman Feb. 13, 2020

Feb. 13, 2020

I'm an ultra small business owner. One thing I do buy and own are .com domain names. Please don't increase my expenses, putting my potentially growing business into stagnation or worse, decline. You have control over that. The rate of increase I've heard you're wanting to implement will affect my ability to buy more domains. Capitalism works best when you have a cheaper product you sell to everyone instead of selling an expensive product to a select few. Bob

1 0

[Comments-com-amendment-3-03jan20] .com domain price increases
by Vincent Tavera Feb. 13, 2020

Feb. 13, 2020

Good morning, I as spokesperson for our 53 year old business and my own interest in developing websites, .com are a foundational base for most companies trying to create an online presence. An increase in.com pricing would have a major impact on every companies ability to establish an online marketing presence. Please do not move forward with the verisign deal. If needed, I'd be happy to come speak with someone in regards to this issue. -- Best Regards, Vincent Tavera | Marketing EPI Electrical Enclosures & Engineering (210) 673-3580

1 0

[Comments-com-amendment-3-03jan20] Comment
by Meagan Lang Feb. 13, 2020

Feb. 13, 2020

Please do go forward with this deal. Raising the cost of .com domains will limit access, depriving people with low income of a significant professional tool for self promotion. Meagan Lang

1 0

[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
by Sébastien Chazaud Feb. 13, 2020

Feb. 13, 2020

Hello, I have to buy a lot of domains for my job (SEO expert), so I’m against the increase of the prices. Regards, Sébastien Chazaud referencer-son-site.ch

1 0

[Comments-com-amendment-3-03jan20] Opposed to price increases for Dot com domain names
by Lorraine Maita, MD Feb. 13, 2020

Feb. 13, 2020

Any price increase to dot com domain names will make it increasingly difficult for small businesses to compete in a global market. Small businesses provide a significant amount of jobs and contribution to the overall economy. Instituting ongoing price increases will cause many to shutter and the marketplace will be dominated by multinational corporations fraying the fabric of our country. I want to voice my concerns and objections Lorraine Maita, MD Vibrance for Life 64 River Road, First Floor Summit, NJ 07901 (973) 218-1199 www.HowToLiveYounger.com<http://www.HowToLiveYounger.com> www.VibranceForLife.com<http://www.VibranceForLife.com> --

1 0