The details provided on the ICANN.org site indicate that wholesale pricing for .COM TLD registry services has been static at $7.85 since 2012. CPI data shows that the aggregate inflation index since 2012 was 255.657 (avg. CY 2019) / 229.594 (avg. CY 2012) or a total of 11.4% over eight years, for an annual rate of ~1.4%. The proposed changes provide that, "..., among other things, Verisign and ICANN may agree to amend the .COM Registry Agreement to permit an increase to the price for .COM registry services, up to a maximum of 7 percent in each of the final four years of each six-year period (the first six-year period commenced on October 26, 2018). The proposed Amendment 3 to the .COM RA reflects this change, essentially restoring the pricing structure from the 2006 .COM Registry Agreement." As an illustration, a 7% increase in 2020, 2021, and then in each of 2024-2027 inclusive would yield an aggregate price increase for .COM domains of 50.1%, for an annual rate for 2020-2027 of ~5.2%. Clearly, this is an excessive price increase, based on the past eight years of inflation data. Unless ICANN, Verisign and the U.S. DOC and DOJ can provide details justifying cost increases outpacing inflation by nearly a factor of four, this proposed amendment must be rejected as unfairly burdensome to .COM registrants. Coupled with the fact that Verisign is benefitting from decades of U.S. taxpayer-funded research and development, leading to the existence of the .COM TLD, prior to any cost increases associated with the operation of the .COM TLD, there should be a full audit of the actual costs of operating .COM, along with any proposed changes or enhancements of DNS as outlined in the proposed amendment. Any cost increases passed on to consumers and wholesalers of internet domain name services must be tied directly to actual costs, and not hidden in yearly "cost-of-services" increases without justification. Further, a U.S. DOC and DOJ inquiry should be initiated to assess whether a core network provider such as Verisign has an innate conflict of interest in managing any TLDs, much less securing hyper-inflationary cost increases with the cooperation of ICANN. Sincerely, Michael A. Chupa <chupa@acm.org>