[Comments-com-amendment-3-03jan20] Proposed Amendment 3 to the .COM Registry Agreement
I am a registrant of a .com domain name and work in the domain name industry. The new registry agreement contains various concerning issues that must be addressed before the agreement can proceed. The way that increases in registry fees are negotiated between ICANN and the Registry operator is anti-competitive and violates the rights of the parties that will ultimately have to pay these fees. Change in registry fees should be subject to negotiations between the parties to the registry-registrar agreement, e.g. Verisign and the accredited registrars and subsequently subject to review and approval by ICANN (to compensate any inequalities in negotiation powers). ICANN unilaterally agreeing to changes to registry fees without consulting the parties subject to those fees is anti-competitive and essentially disenfranchises registrars of their negotiation powers. I also am concerned about the proposed changes to the registry-registrar agreement that are included as part of the amendment of the registry agreement. Essentially this amounts to creating new obligations for contracted parties and registrants through the back door without policy. ICANN is proposing to create new obligations for parties that are not even at the table in these negotiations. Any changes to the Registry-Registrar agreement that create new obligations for either side cannot be unilaterally imposed by ICANN or the registry operator, but must be negotiated and/or approved by the parties to that agreement, subject to ICANN approval. Sincerely, Volker Greimann Saarbrücken, Germany
participants (1)
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Volker Greimann