Friday, February 14, 2020 The Honorable Senator Elizabeth Warren, Senate Office Building, Washington DC 20510 The Honorable Senator Amy Klobuchar, Senate Office Building, Washington DC 20510 The Honorable Representative Steny Hoyer, 1705 Longworth House Office Building, Washington, D.C. 20515 The Honorable Representative Nancy Pelosi, 1705 Longworth House Office Building, Washington, D.C. 20515 Bureau of Consumer Protection, FTC Bureau of Competition, FTC ICANN Re: https://www.icann.org/public-comments/com-amendment-3-2020-01-03-en To whom it may concern: A few days ago, I was contacted by my domain name registrar advising that Verisign was asking for pricing increases (about 30%) that would substantially increase the cost of holding the small portfolio of domain names I own (10-20). I think everyone should own a few because ownership of the internet, its value, should derive from users, mainly the people (real people, not corporations doing business as persons for purposes of business law). I am not looking to flip mine for a profit. I have no websites up. The only websites I have put online were for teaching and research purposes, paid for out of my personal income. It is expensive enough merely to put up, protect, and maintain a website. To reach an audience requires a campaign war chest to pay for social media and search engine advertising. I, like most Americans, am not wealthy nor a fundraiser. The cost of owning a few domain names is not a cost of doing business for me since I don't own one or have any plans in that direction. The internet should be first and foremost a resource that enhances public speech, the internet should belong to the people. But, so that the internet remains open and free, I understand we must rely on both private and government, or quasi-governmental agencies to manage necessary infrastructure. Unfortunately, it seems that the internet is plagued with potholes, worse than our highways. Until I was contacted by my registrar 2 days ago, I had never heard of Verisign and was only vaguely familiar with ICANN. I recall paying ICANN fees to my registrar that are very low. What I did not know is that a substantial part of the substantial annual cost paid to my registrar just to own them, whether I do anything with them or not, goes to Verisign. Amendment 3 will increase those costs dramatically and also change the structure of the internet to increase the monopoly Verisign holds over the internet. Verisign already has no competitors, already is a monopoly contractually. On the other hand, there are very many domains and domain registries. These compete on price; but, from what I can see, are highly constrained in doing so because all of them must pass on considerable fixed (Verisign) fees to consumers and other owners of domain names. Verisign is publicly traded and has outperformed all stock markets substantially. Most public comments are going to complain that Verisign already makes too much money and has not specified why they need to make more. That's easy to predict because that's pretty much all the public knows and has been told. The only reason Verisign gives to demonstrate the need, is a generalized, vague statement about the need to safeguard internet security. I would think that if they had specific plans for improvements to what they already do--since protecting the internet essentially is also Verisign's mission statement--they would have a specific budget and that they would be pitching these plans through the roof because they are publicly traded--it's both in their interest to disclose and required by accounting standards and the SEC. Verisign has already bullied the same for .org and other domain types. Thousands of public comments objected. Only a few voiced in favor, which implies almost all those who would personally profit from these price increases did not even bother to submit a letter voicing their approval. Why? Because like the present case, the old public comment process was merely an excuse going through the motions, not a serious solicitation and consideration of public comments. I am told the public comments against were all dismissed as "spam" for the earlier case. I think there was a little more to it. The usual reason most public comments against are dismissed is that they do not rise to the technical and legal standards necessary to require explanation and/or reconsideration. You have to be an expert in the field or a lawyer to submit comments that matter these days, especially in this case of a high-tech company that acts in the background of the internet, in the shadows of our lives. The only comments likely to stop this process, or most any other process from Keystone to health and safety regulations are lawsuits or credible threats to sue submitted in comments in the absence of sincere federal, indeed international, regulation and oversight. I don't see that happening. We don't have a public union. Registrars are not well organized. And, I doubt anyone could recover the substantial legal fees. ICANN is supposed to regulate Verisign but seems to be surrendering their responsibilities. Verisign gave ICANN a considerable sum of money to make these changes happen. This, I presume, was to pay ICANN's costs but the amount seems more like paying for all of ICANN's bonuses and new corporate memberships at Mar-A-Lago. As a monopoly, Verisign minimizes risk by definition. In a free market, stock values are supposed to reflect risk. High tech firms generally earn more because they face the added risk of the technology itself. The internet has been around for Verisigdecades now. I don't see there being all that much risk to the internet failing. Verisign's only risk has been and is keeping the internet secure but in a very limited way. What[ <#_msocom_1>do they plan to do different? Build a Wall around the internet? Overall, I don't judge the internet a safe place. I don't believe and Verisign has not convinced me as a member of the public that the internet is going to be safer if Verisign gets these price increases. Verisign has extremely (abnormally) high operating profits and net incomes. I am not going to go into those specifics because I am objecting to the process itself. The public has not been given adequate knowledge or time to make credible objections. Essentially, *the Amendment 3 public comment process is fraudulent*. There is reason to suspect ICANN has been paid off and will not see to the public interest. We have been given no reason to justify the price increases. They know the public can only object to the price increase itself and that objecting to price increases will be easily dismissed by free market reasoning. The problem is that the public, average folks, have no other place to go. They used to say the crooks were in the banks because that's where the money is. Today, the crooks seem to camp out in Verisign and ICANN. I ask that the price increase be denied due to unfair process according to principles of the free market, free internet, and free speech. ICANN should require and publish a detailed review explaining what they want to do that requires this price increase and what they want to achieve by it besides jacking up their stock price before the next heist. The US Department of Commerce should have gotten off its soup can and seen that it was so instead of conspiring with Verisign and ICANN to further usurp the internet. Since I do not think public comments are being solicited with sincere intents, I am forwarding my own to above members asking Congress to hold hearings on the past and present process by which these price increases and encroachment on our freedoms have been conducted by US Department of Commerce, Verisign, and ICANN. That’s the only way the public is going to have the information necessary to judge and comment. Thank you for your consideration and assistance, Dr. Susan Grogan Professor of Political Science St. Mary's College of Maryland St. Mary's City, MD 20686 ------------------------------ [SG1] <#_msoanchor_1>