To Whom It May Concern, This letter is in response to the request for public comment on the ICANN-Verisign LOI and the Third Amendment to the .COM Registry Agreement. My comments below are based on the knowledge of ICANN’s non-profit status and its statement on its website that “ICANN’s fundamental belief is that all users of the Internet deserve a say in how it is run." LOI The LOI doesn’t make good business sense and would give Verisign an unfair advantage as a domain name registrar. ICANN manages, but does not operate, root servers. If Verisign is to provide services that increase security of the root server system, then it should be ICANN who pays Verisign. Verisign already sells security services to the domain name owners and registrars. According to Verisign’s website: “Verisign operates the authoritative registries .com, .net, .name, .cc, .tv, .コム, .닷컴, .닷넷 and קום domain names, and provides domain registry services for .jobs and new gTLDs. Verisign does not register or renew domain names—we work with domain registrars to register domain names.” However, the LOI will give Verisign the new ability to register domain names, allowing it to compete with its customers and enage in anti-competitive behavior. The LOI will give Verisign the ability to underprice to the public similar services already offered by its domain registry competitors by overpricing its existing services to those same registrars. Nothing in the LOI prevents this. All things considered, there is no evidence that the $20M to be paid ICANN by Verisign is nothing more than a quid-pro-quo. It enables Verisign to unfairly compete with the domain name registries that rely on it, which would be worth much more to Verisign than $20M. Not named in the LOI, but coincident to it, is the Third Amendment to the .COM Registry Agreement, which gives Verisign the ability to increase fees to its customers for .COM names by 7% a year. This is yet another gift in the quid-pro-quo in return for the $20M. Third Amendment to the .COM Registry Agreement No explanation is given as to why Verisign has earned the right to increase .COM registry fees by 7% a year. If Verisign’s costs associated with security are increasing, why isn’t this stated, and why is Verisign depleting its valuable resources by paying ICANN the $20M per the LOI? Altogether, giving Verisign the right to operate as a .COM domain name registrar to the public, while charging competing .COM registrars service fees that increase 7% a year, is simply a formula for anti-competitive behavior. This is clearly not in the public interest. Both the LOI and the Third Amendment need considerable re-thinking and should not be executed as-is. With best regards, Michael Karagosian President MKPE Consulting