Like it will make any difference submitting a comment to any of you would-be watchdogs, but your proposed amendment, worked out as it was in secret with Verisign (an Evil Corp subsidiary) appears mostly to be a license to steal — as always, from those who can least afford it. So hey, good plan. I assume the median income of ICANN employees and contractors just isn't what it should be, at least not yet. Best of luck on your journey to the dark side — and if this involves any sort of eternal rotting in Hell . . . well, you earned it.
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Roger Piantadosi