Good Evening,

It has come to my attention that ICANN has announced significant changes to the contract it has with Verisign, Inc. that will result in increased charges to organisations' costs to register their Top Level .COM Domain names.  It has been suggested that wholesale prices could increase by 70% over the next decade.

I am writing on behalf of The Sol Sante Club to express my dismay at this prospect.  We are a non profit organisation staffed entirely on a volunteer basis and work very hard to contain all of our operating costs.  I have little doubt that there are thousands of such organisations facing the same concern.

The information provided to me was separated into 4 areas and I have commented on each of these below.

  1. Price Increases

    As noted above these increases will place a significant burden on a Non Profit organisation and I would urge that consideration be given to this fact in structuring future price increases.

  2. Additional $20 Million

    The information provided to me indicates that ICANN will receive an additional $20 million from Verisign Inc yet there is no information provided regarding how these funds will be used, why they are required or what kind of oversight, if any, will be implemented to ensure good use of the funds.

    This is simply poor business practice and is not at all aligned with the transparency you promote on your website with regards to your Privacy Policy.

  3. Verisign Inc. may now operate as a Domain Registrar

    I understand that this change will now allow Verisign Inc. to have a significant degree of control over the pricing of Domain Name registration and the reduced  number of competitors will potentially lead to higher prices to consumers.

    Not only does this seem unfair to the entire Domain Registrar business sector but, again, it is of great concern to non profit organisations such as The Sol Sante Club.

  4. Dismissal of Comments on Previous Price Changes

    I understand that when similar changes were being made to other Domain Names, such as .ORG, .INFO and .BIZ, some 3,500 comments were submitted but ignored.  In particular, a large number of comments were dismissed as "spam" solely because they were submitted via an online tool.  That fact alone should not be sufficient reason to dismiss comments without further investigation as to their veracity.

    I also understand that this, in turn, resulted in the decision to remove the price caps primarily relying upon a biased preliminary analysis from 2009 by an economics professor that did not reference any data. 

    Simply poor science / data collection / analysis and, again, poor business practice to reach a decision based on such poor and unsupported analysis.
IN SUMMARY:

I urge ICANN to review their position and revise their plans based on good business practice and defendable decisions while also considering the financial impact on non profit organisations.

Kind Regards,

Tom Mitchell
Vice President
The Sol Sante Club