ICANN, As the current proposal stands, there is zero chance of gaining my support for the release of O.com. While this proposal might be warm and fuzzy at the high level, this proposal is clearly made to give VeriSign an opportunity to ask to amend the .com contract. And not for the general good. Instead of being forced to charge realistic prices for .com domain names, VeriSign is trying to introduce premium fees, premium renewals and ownership restrictions into what is a straight forward and agnostic top-level-domain. In the end, if VeriSign is successful, this proposal would open Pandora's box for allowing such things on more .com domain names in the future. And then for more groups of domain names in the future. And then ... who knows. Existing domains? All .com domains? Domains of major trademarks? This is clearly VeriSign trying to push limits. It is using the charity portion of this auction as a clutch to push for altering the .com contract to its long-term benefit. I AM ABSOLUTELY AGAINST THIS. I GIVE A RESOUNDING *NO* TO PREMIUM PRICES AND RENEWALS ON ANY .COM DOMAIN NAME(S)!!! INCLUDING, BUT NOT LIMITED TO THE PROPOSED AUCTION OF O.COM. I ALSO GIVE A RESOUNDING *NO* TO OWNERSHIP RESTRICTIONS ON ANY .COM DOMAIN NAME(S)!!! THIS PROPOSAL GOES AGAINST THE ENTIRE SPIRIT OF THE .COM DOMAIN NAME EXTENSION AND INTRODUCE UNNECESSARY COMPLEXITIES. I submit that this proposal was made in bad faith. And here is how I know it: If this proposal were in good faith, it would have simply stated, "we, Verisign, would like to allow the auction of O.com. The auction will be conducted by a third party, all profits from said auction will be donated to charity. After that, this domain will abide by the exact same rules of all 133 million other .com domain names in existence." However, VeriSign did not do this or make this auction anywhere near so simple. VeriSign has made this extremely convoluted and complicated. Verisign is suggesting premium renewal fees and ownership restrictions. This is merely VeriSign's indirect plan. The proposal was not made with open arms. This proposal is an excuse to meddle with the longstanding .com contract! It is trying to carve out special requirements for certain domain name(s). If successful with O.com, what next? Obviously, the other single character and single letter .com domain names. But then what? Microsoft.com? Google.com? Diamonds.com? Mortgage.com? Bank.com? Search.com? Two-letter domains? All .com domains? The three already delegated single-character domains? Where would it end? ICANN should also realize the very dangerous precedent it would be setting if it entertained such a proposal. Entertaining this proposal as-is would mean subsequent rounds of "we want this" and "we want to auction that" and then "we want the profits" and then "we want premium renewals on existing domains." It sets up a dangerous precedent for ICANN to have to answer to all sorts of random carve-out requests in the .com contract by VeriSign. This is something ICANN is neither financially prepared for, nor should ICANN be putting any resources into! VeriSign should be managing the extension as the monopoloy it is, not trying to dictate special terms into specific domain names within the extension! I gladly support the release of the O.com domain name if it came with the exact same renewal prices every year going forward as every other .com domain name in existence, and as long as there are no limitations of ownership transfer. Essentially, if the domain were to act and abide by all rules and regulations already in place for ALL other 133 million .com domain names. I also support all proceeds of an O.com auction going purely to charity. But I only support such an auction *only* if the auctioned domain name(s) have no special restrictions which require meddling and altering the .com contract. A live O.com should be treated as every other .com domain in the world. VeriSign should *not* be allowed to alter the already monopolistic, most successful, most well-known extension for this one domain. To have a special section just for this domain in the contract. VeriSign should not be allowed to introduce carve-outs in the contract for ownership restrictions and premium renewal prices. And for what? Fir this one domain? For a group of 23 domain names? Think of it this way: There are 133,000,000+ .com domain names in existence. And Verisign is trying to alter the .com contract over ONE DOMAIN NAME. If this proposal is even considered, I propose VeriSign finally be forced to put the .com contract out for public tender once and for all. VeriSign, through this proposal, is trying to introduce changes into the .com contract for 1 domain name out of 133,000,000 domain names. This is absurd and insanity! Verisign, if foolish enough to pursue this, would wind up spending more on legal fees than the auction would net in the end. Why is it making such a request? Because Verisign is trying to use charity as an excuse to alter the .com contract. At the cost of ICANN, at the cost of the Internet community, and at an ultimate cost to .com domain name owners worldwide. In the end, the real cost is that the .com contract would become more complicated, split, and murky with special edge-cases, giving VeriSign more opportunities to try and put restrictions on more domain names in the future, which indirectly would lead to better bottom-line profits for the company. But would not be in the benefit of the world, a benefit to any .com domain name owners, and would take more and more of ICANN's time and resources going forward. I propose James Bidzos and Verisign simply donate the $35 million to charity on good accord (or whatever such auction might net) instead of trying to pull a fast one like they are doing here. The nuance of what they are doing might seem subtle at first, but it is clearly Verisign's intent to push the boundaries. Because if VeriSign wanted to be charitable it would have just given to charity. And if it wanted to be charitable, it would have simply proposed auctioning off O.com, with no strings attached. Instead, VeriSign has proposed premium renewal prices be introduced to the .com contract, that ownership rights restrictions be put into the contract. Over time VeriSign would love to start to introduce premium fees and ownership transfers on more .com domain names, put in more controls, and ratchet up the profits even more. Do not be fooled. This is 100% not about charity! It is VeriSign testing what limits it can push, so that eventually it can reap more profits from owners of .com domain names worldwide. Remember, this is a corporation that has proven to do such things. Remember when VeriSign forced its upper hand in the .com contract by means of Regulatory Capture? And remember when VeriSign upped the prices of .com domain names at every opportunity it was able to do so, until the NTIA said it could not do so anymore? What an embarrassment to the company that is supposed to be the steward for the .com extension, yet is it now proposing to muddy the .com contract over ONE SINGLE DOMAIN. To pave the path for more carve-outs in the .com contract in the future. VeriSign is always working to be more profitable and make things better for itself, worse for domain name registrants. Better for VeriSign. At a higher financial cost to the world. I am absolutely against the proposal to alter the .com contract for just one domain. Even if the argument is made they could do this for all other 23 one-letter .com domains currently not delegated, that is only 23 domain names out of 133,000,000 in existence. As a decimal this is 1.72932331e-7. Or in more readable format, Verisign is proposing altering the .com contract for only 0.00000017% of .com domain names in the world!!! This is stupid and should *not* be considered. If it were done, it would only be time until VeriSign then tries to alter the contract again, then again, then again. Only to push for what eventually gives the company the highest possible profits. This is their clear and obvious long-term plan. It is so abundantly obvious and all-for-profit. Not "charitable". VeriSign threw charity into the mix only try and make this sound like a good idea. Do not jeopardize the more than 132,999,974 .com domain names in existence by entertaining such a radical deviation from how the .com gTLD always has run with special pricing! Again, VeriSign is only using this as an excuse to try and modify the .com contract to its future financial benefit, and in no way should this one domain hold more important rights than the 132,999,974 COMBINED domain names that proceed it. The .com contract should *not* be altered for any specific domain or group of domain names!!!!! To do so would be a slap in the face of every .com domain name registrant worldwide! Should Verisign want push for the release of single character domains, the single most important thing is that these extremely few domains are bound by the exact same rules of all other .com domain names in existence today. To do otherwise is just too murky, and for what reason? Only to push the envelope and allow VeriSign to modify the .com contract? At a huge legal cost to ICANN and to VeriSign. And at the cost of splitting the .com contract for every single person and/or company who owns a .com domain name and this does in fact affect. To make management of domain names more complicated than it should be. This is very problematic to the other 133 million other owners of .com domain names in the world! This is AN EXTREMELY BAD IDEA which should be totally dismissed on behalf of the other 133 million .com domain name owners, whose contract (the .com contract) is potentially going to be altered and tarnished and muddied ... over ... one single domain name. And this would only introduce carve-outs which go completely against the defacto standard the other 133 million .com domain names are bound by. Finally -- why should I, Keven Dabney, have a say in the matter? Not only am I a citizen of the Internet and a domain name professional looking out for the common good, I myself own many domain names and this proposal affects me tremendously. It potentially jeopardizes each and every one of the .com domain names I own and operate, and I thus am completely against this proposal. I am also quite fearful that VeriSign would even consider such a move, and to me only indicates VeriSign is in this for ultimate long-term profit, and not to be the best steward to the .com namespace in the end. Thank you for listening. Keven Dabney Internet and Domain Name Professional
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Keven Dabney