There is simply no justification for the price increase. ICANN is taking essentially a 20 million dollar bribe to allow VeriSign to capture many multiples more than that in increased profit. 20 million dollars over 5 years is nothing. If ICANN desperately needs this funding, it is sitting on ~450 million dollars from the last 990 I could find (2018 - https://www.icann.org/en/system/files/files/fy18-irs-tax-form-990-return-organization-exempt-income-tax-27may19-en.pdf ). If this is essential, it can be pulled out of the budget, it shouldn't be taking VeriSign's money in a quid-pro-quo arrangement to allow VeriSign to raise prices on a monopoly product with wildly healthy margins - "The operating margin for 2019 was 65.5 percent compared to 63.2 percent in 2018." (Quote from VeriSign quarterly report https://investor.verisign.com/static-files/4a30ffcc-5b47-464d-bf43-11637bdf5510 ).

VeriSign has a monopoly over .COM which has an extremely disproportionate power over internet commerce. The cost of operating domain registries has gone down (as seen by competitive bids to operate registries and in VeriSign's operating margin).

ICANN pretending it shouldn't be a price regulator is a new line which seems to be ICANN abdicating it's responsibility towards internet users and only representing the interest of registry operators. Removing price caps on .ORG has lead to the catastrophe we see today. Letting VeriSign continually increase prices on .COM has an even larger impact considering it's stronger monopoly and it being an order of magnitude larger than .ORG.

If ICANN really cared about competition, it wouldn't be giving contracts to run the registry in perpetuity and open them up to competitive bidding every so often. This selective interpretation of how markets should and shouldn't be free is designed to hurt consumers and line the pockets of registries, which seem to have a revolving door with the ICANN folks.

I fully expect ICANN to ignore the overwhelming opposition to these price caps as they did with .ORG ( https://reviewsignal.com/blog/2019/07/01/icann-fails-the-internet-community-allows-an-unlimited-non-profit-tax/ ). I will be amazed if we even see the board make a decision or if they simply hand it off to staff and pretend this is unimportant.

ICANN's multi stakeholder model is a failed project in governance and I'm sure this comment period will simply be the latest supporting evidence.

Kevin Ohashi 

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