The proposed amendment 3 should not be passed in current form. 1. While the pricing allowances are in line with Amendment 35, it is a loss to ICANN to take a $20M USD flat payment in this exchange. To create a stable source of funding for initiatives ICANN must consider a fixed rebate percentage tied to all wholesale domain transactions on .COM through registry operators. Decoupling the payment from the service serves only one party: the for-profit entity Verisign. 2. Verisign should NOT be able operate its own registrar or act as a reseller in which direct profits are obtained by line item domain registration. Combined with the price controls this is a severe conflict of interest. The language must specifically bar Verisign from engaging in domain registrar activities, directly or indirectly. -Dale Liszka