Dear ICANN staff,

The amendment to section 7.3(d) of the agreement is not reasonable or in the public interest because:

• .com is the largest TLD by volume, and plays a key role in the dissemination of information on the Internet and in commerce. It is such a well established TLD that many people and companies have no reasonable alternative to 'vote with their feet', and so ICANN plays a key role in ensuring that Verisign does not abuse its position as registry.
• When similar changes have been made to other registries, for example to .org, this has been rapidly exploited by registries for profit (for example, by selling of the registry to a company that undoubtedly intends to maximise profit unfairly at the expense of registrants).
• New section 7.3(d)(ii) allows for 8 price increases of 7% in the next 10 years due to the backdated start date, even in the absence of any legitimate increase in expenses. This amounts to a maximum increase of a massive 71.8% ((1.07^8 - 1)*100%) even in the absence of any increase in costs. For comparison, inflation in the US over the last 10 years was 22.3%. Allowing for completely discretionary increases on the part of Verisign significantly above inflation is not reasonable, nor is it fair to registrants or the broader Internet community.

Kind regards,

Andrew