[Comments-com-amendment-3-03jan20] Comment on proposed Amendment 3 to the .COM Registry Agreement
Dear ICANN staff, The amendment to section 7.3(d) of the agreement is not reasonable or in the public interest because: * .com is the largest TLD by volume, and plays a key role in the dissemination of information on the Internet and in commerce. It is such a well established TLD that many people and companies have no reasonable alternative to 'vote with their feet', and so ICANN plays a key role in ensuring that Verisign does not abuse its position as registry. * When similar changes have been made to other registries, for example to .org, this has been rapidly exploited by registries for profit (for example, by selling of the registry to a company that undoubtedly intends to maximise profit unfairly at the expense of registrants). * New section 7.3(d)(ii) allows for 8 price increases of 7% in the next 10 years due to the backdated start date, even in the absence of any legitimate increase in expenses. This amounts to a maximum increase of a massive 71.8% ((1.07^8 - 1)*100%) even in the absence of any increase in costs. For comparison, inflation in the US over the last 10 years was 22.3%. Allowing for completely discretionary increases on the part of Verisign significantly above inflation is not reasonable, nor is it fair to registrants or the broader Internet community. Kind regards, Andrew
participants (1)
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Andrew Miller