Resubmission of ICA Initial Comment
It has been brought to my attention that the Word document submitted by ICA on
May 26 is not displaying when the attachment is clicked on. I am therefore
resubmitting it both as text in this e-mail and as an attachment.
VIRTUALAW LLC
Philip S. Corwin, Founding Principal
1155 F Street, NW Suite 1050
Washington, DC 20004
202-559-8597/Direct
202-559-8750/Fax
202-255-6172/Cell
psc@xxxxxxxxxxx
April 26, 2012
By E-mail to: com-renewal@xxxxxxxxx<mailto:com-renewal@xxxxxxxxx>
Internet Corporation for Assigned Names and Numbers (ICANN)
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601
Re: .com Registry Agreement Renewal
Dear ICANN:
I am writing on behalf of the members of the Internet Commerce Association
(ICA) in regard to ICANN's initial comment period on the proposed renewal of
the .com Registry Agreement which would allow VeriSign to continue operating
the largest gTLD for an additional six-year term running from December 1, 2012
through November 30, 2018. This Reply Period was opened on March 27th and
closes today, April 26th.
ICA is a not-for-profit trade association representing the domain name
industry, including domain registrants, domain marketplaces, and direct search
providers. Its membership is composed of domain name registrants who invest in
domain names (DNs) and develop the associated websites, as well as the
companies that serve them. Professional domain name registrants are a major
source of the fees that support registrars, registries, and ICANN itself. ICA
members own and operate approximately ten percent of all existing Internet
domains on behalf of their own domain portfolios as well as those of thousands
of customers.
Executive Summary
* We applaud ICANN's rejection of trademark interest entreaties that it
impose URS and other untested new RPMs on .com through contractual fiat, as
well as ICANN's recognition that the rights and legitimate expectations of
registrants require that any consideration of this matter be within the normal
policy development framework. We also urge ICANN to initiate the long-delayed
implementation process for URS so that the community may review its operational
aspects and the qualifications of prospective arbitration providers well in
advance of the first delegations of new gTLDs.
* We lament the fact that the perpetual renewal and pricing provisions of
the current .com agreement preclude ICANN from subjecting the agreement to
competitive rebid and permits additional price increases without any
justification or public explanation. Notwithstanding the manner in which ICANN
has unwisely restricted its own bargaining latitude, we believe that a
requirement should be imposed on VeriSign and all other gTLD registry operators
to provide a public explanation of the justification for any future price
increases, and that such a requirement would not be a material term or
condition that ICANN is precluded from imposing or altering. Because of these
serious contractual flaws, it is even more critical that the batching process
for new gTLDs facilitate the rapid introduction of new, general purpose gTLDs
that can exert pricing competition against .com and other incumbent registries.
* We generally approve of other modifications of the agreement that enhance
cybersecurity, bolster ICANN's audit powers, continue to prohibit the offering
of universal wildcard services, and set high performance requirements enhanced
by registrar payment credits in the event they are not adhered to.
* We have no objection to the imposition of "thick" WHOIS requirements on
.com if mandated by the GNSO.
Imposition of URS on .Com via Contract Renewal
One of the most significant aspects of this renewal agreement is what it does
not contain - imposition of Uniform Rapid Suspension (URS) or any of the other
new Rights Protection Mechanisms (RPMs) developed for new gTLDs, through
contractual fiat, on this largest and most important of incumbent gTLDs.
ICA is extremely pleased by ICANN's announcement that no attempt will be made
to impose URS or other new gTLD RPMs on .Com through the contract renewal
process. It appears that that this decision has been made in a way that
effectively closes the door on attempts by trademark interests to foist these
untested mechanisms on incumbent gTLDs through a backdoor that avoids ICANN's
multi-stakeholder policy process.
On this point, your announcement states:
New trademark protections: The .com renewal proposal does not include a
requirement to comply with the rights protection mechanisms (RPMs) developed
for new gTLDs: Uniform Rapid Suspension (URS), Post-Delegation Dispute
Resolution Process (PDDRP), and the Trademark Clearinghouse. Taking them in
reverse order, the Trademark Clearinghouse currently works in the period of a
registry operational start-up and so would not be applicable to .com.
URS and PDDRP have so far only been approved in the context of new gTLDs. The
URS and PDDRP are new and untested, and arguably should enjoy a "ramp-up"
period to ensure that they are robustly designed and implemented before they
are asked to absorb the full workload of the entire gTLD namespace. Secondly,
registrants have procured domain names in existing gTLDs with an understanding
of the landscape of existing RPMs. New RPMs affect registrants, as well as
registries and registrars. They should arguably be introduced in existing gTLDs
after a bottom-up discussion. Finally, these RPMs are not in any other existing
registry agreement, and ICANN has no basis for requiring them - as described
above, the renewal agreement should be similar in terms with the other largest
registries.
The malicious conduct and rights protections were added because the community
stated that ICANN should implement new gTLDs in order to make sure that there
is as little harm as possible caused by the introduction of new gTLDs. When
creating the new gTLD rules, existing registrants (and registries) were not
consulted with the idea that those protections would be implemented in existing
gTLDs without further community discussion. (Emphasis added)
ICA is particularly gratified by ICANN's recognition that registrants in .Com
and other incumbent gTLDs acquired their domains with an expectation of being
subject to UDRP, but not these new and untested mechanisms; that "new RPMs
affect registrants"; and that any consideration of imposing URS on new gTLDs
should occur after they have been tested - and then "after a bottom-up
discussion" that is the hallmark of ICANN's policy development process. These
are all points that ICA has made on a consistent basis over an extended period
of time.
We take serious issue with comments on the proposed contract such as those of
the International Trademark Association (INTA) which assert that ICANN's
reasoning on this critical matter is somehow inconsistent with its prior
statements regarding RPMs at new gTLDs. Rather, what is inconsistent is for
INTA and other trademark interests that called for delay of the initiation of
UDRP reform consideration so that the performance of the new RPMs could be
considered in that context to now try to subvert ICANN's standard policymaking
process by urging imposition of URS on .com absent any experience with it. We
also take issue with the notion that "harmonization" requires imposition of URS
on .com and other incumbent gTLDs at some future point in time. We believe that
the experience with URS and other new RPMs needs to be thoroughly evaluated
after a substantial period of use at new gTLDs before that debate should be
initiated, and also believe that the .com registry is qualitatively
differentiable from all other gTLDs and may well deserve and require some
distinct contractual anomalies well into the future.
ICA spoke out against a similar attempt to require URS in the renewed 2011 .Net
contract (see http://internetcommerce.org/ICA_Tells_ICANN_No_URS_at_dot_Net);
and has objected to its consideration for .Com at multiple ICANN gatherings
and in our recent comment letter on defensive registrations at new gTLDs (see
http://internetcommerce.org/Defensive_Registrations_Second_Level). That letter
stated:
We are unalterably opposed to this suggestion for 2012 contractual imposition
of URS on .Com , both on its own demerits as well as because it would usurp the
policymaking role of the Generic Names Supporting Organization (GNSO) Council.
More than 100 million domains are registered in .Com. It is by far the largest
gTLD and constitutes almost half of all existing domains in both gTLDs and
ccTLDs. Non-infringing domains registered at .Com tend to have substantial
secondary market value - sometimes reaching the $millions. The reckless notion
that a thoroughly untested RPM should be foisted on the most important gTLD
absent any experience - indeed, absent any assurance that a qualified provider
can even be located and retained - is absurd on its face.
Second, imposing URS on .Com through a contract negotiation would completely
undermine the December 2011 policy decision made by the GNSO in regard to
initiation of a policy development process (PDP) for UDRP reform.
Motion 20111215-1(see http://gnso.icann.org/resolutions/#201112 ) states in
relevant part:
Whereas, a Final Issue Report was published on 3 October 2011
(http://gnso.icann.org/issues/udrp/udrp-final-issue-report-03oct11-en.pdf) in
which ICANN staff recommended the GNSO Council consider the "perspective of the
majority of the ICANN community, and the advice of the Government Advisory
Committee (GAC), and the At-Large Advisory Committee" and that "a PDP be
delayed until after the New gTLD Uniform Rapid Suspension System (URS) has been
in operation for at least eighteen months. . . to allow the policy process to
be informed by data regarding the effectiveness of the URS, which was modeled
on the UDRP, to address the problem of cybersquatting."
... RESOLVED further, the GNSO Council requests a new Issue Report on the
current state of all rights protection mechanisms implemented for both existing
and new gTLDs, including but not limited to, the UDRP and URS, should be
delivered to the GNSO Council by no later than eighteen (18) months following
the delegation of the first new gTLD. (Emphasis added)
ICA did not agree with that GNSO Council decision, which defers the initiation
of UDRP reform until at least mid-2014 - 18 months after the likely launch of
the new GTLD program. We believed and repeatedly stated, verbally and in
writing, that after more than ten years of operation and in light of
substantial grievances from both registrants and complainants, the UDRP was
deserving of at least procedural policy reform.
But trademark interests vigorously resisted initiation of UDRP reform at this
time, in large part to assure that any deferred reform process would consider
the imposition of the URS and other new gTLD RPMs on incumbent gTLD registries,
including .com. Having achieved their objective, it is rather astonishing for
some to now suggest that ICANN should undermine the GNSO's policymaking role by
imposing URS through contract negotiations. ICANN should firmly reject that
suggestion.
ICANN staff recommended that UDRP reform be delayed so that the policy process
could be informed by data regarding the effectiveness of the URS. Their clear
intent was to allow any consideration of imposing the URS on incumbent gTLDs to
be informed by the URS experience with new gTLDs, and to subject that
consideration to the rigors and multi-stakeholder review of the standard PDP.
We agree that any consideration of URS for incumbent gTLDs, especially .Com,
should only occur within the full PDP context. If trademark interests wish to
have their concerns about the UDRP addressed then they should join with ICA in
urging the GNSO to reconsider its decision to defer initiation of a UDRP reform
PDP for more than two years.
The ICA's view is that the numerous procedural and structural flaws in the UDRP
fail to provide adequate protection of the legitimate rights of domain
registrants from abuses perpetrated by some overreaching trademark holders.
ICANN's priority should be reforming the flaws in the current UDRP to assure
adequate balance to the UDRP process, chief among them the elimination of forum
shopping and forbidding the empanelment of Complainant attorneys as 'neutrals'
in third-party cases.
Further undermining the rights of legitimate domain registrants, who constitute
99% of domain owners -- including small businesses, non-profit organizations,
and myriad individuals -- by the premature adoption of an untested URS system
for any incumbent gTLD would create an environment ripe for abuse by those who
already abuse the UDRP. This would be the wrong decision for ICANN and for the
Internet community as a whole."
In addition to these public statements and written filings, ICA's concerns have
also been conveyed in conversations with ICANN Board members and staff. We are
pleased that our message appears to have gotten through.
We remain hopeful that ICANN will finally initiate the implementation process
for URS as soon as possible so that we can understand in detail how it is
expected to operate, and see whether any credible arbitration body can be
secured to administer it at the ultra-low pricing promised to trademark owners.
However, in this regard we are dismayed and bewildered that ICANN's newly
constituted New gTLD Program Committee adopted a Resolution at its initial
April 10th meeting that "directs staff to provide a briefing paper on the topic
of defensive registrations at the second level and requests the GNSO to
consider whether additional work on defensive registrations at the second level
should be undertaken". This action has created additional confusion and anxiety
about the final pre-launch status of URS and other new gTLD RPMs, and provides
trademark interests with yet another opportunity to advance already-rejected
arguments that the burden of complainant proof and post-decision options be
altered to convert URS from a narrow supplement to the UDRP into a bargain
basement supplement at a severe cost to registrant due process rights. We again
urge ICANN to immediately initiate the long-delayed implementation process for
URS, including publication of a request for Proposals (RFP) and establishment
of an Implementation Advisory Group (IAG) similar to that constituted for the
Trademark Clearinghouse. As URS is required to be in place at the time that the
first new gTLD is delegated, an event likely to occur in the first part of
2013, it is critically important that ICANN provide sufficient time for
development of the implementation process and feedback from the entire
community including potential registrants in new gTLDs.
Presumptive Renewal and Permissible Price Increases
The presumptive renewal and price increase provisions of the draft renewal
agreement engender a sense of déjà vu, as they are unchanged from the
provisions that engendered significant outcry in 2005-6. ICA was in significant
part established in reaction to that controversy, which ensued when the draft
of the 2006 .Com agreement was unveiled as the negotiated settlement of
litigation brought against ICANN by VeriSign. Following our establishment, ICA
filed an amicus brief with the 9th Circuit Court of Appeals that played a
critical role in a June 2009 revival of the Coalition for Internet
Transparency's (CFIT's) antitrust litigation against VeriSign that challenged
the .Com contract terms. But CFIT settled that case with VeriSign in May 2011
and once it essentially abandoned the litigation the critical terms of this
successor agreement were predetermined.
In reviewing the renewal and pricing provisions of the renewal agreement, we
are reminded why the 2006 contract engendered so much enmity - because ICANN
has effectively agreed to tie its own hands in regard to future renewal
negotiating leverage (and this self-imposed restraint has, regrettably, been
subsequently written into other existing gTLD agreements).
Let us be clear - as a trade association representing free market
entrepreneurs, ICA has no objection to the notion that a registry operator
which performs in keeping with the terms of its agreement with ICANN should
have a strong presumptive right to being re-awarded that operator agreement for
an additional term. We also have no argument with the notion that a registry
operator should have a right to implement justifiable price increases, and know
from experience that ICANN is ill-equipped to function as a price control
regulator.
However, the renewal agreement, like its predecessor, is deficient in several
significant respects:
* Operation of each TLD registry is a "natural monopoly" because only a
single entity may exercise control over registry operations. Traditionally, the
possibility of excessive price increases imposed by the entity in control of a
natural monopoly has been addressed either by a regulatory regime that controls
such increases (a role that ICANN has declined to assume) or by periodic price
testing in the marketplace - a possibility that is effectively precluded by the
agreement's presumptive renewal provisions. The possibility of excessive price
increases is even more pronounced in this case, given the dominant position of
.com in the TLD marketplace -- .com registrations constitute nearly half of all
domain registrations, and the secondary marketplace as well as consumer
behavior conclusively demonstrate that .com domains are by far the most
valuable and that a registrant which believes it has been subject to excessive
price increases has no practical alternative at present to moving their domain
location to another TLD. In December 2008 the U.S. Department of Justice's
Antitrust Division advised the Department of Commerce that "ICANN should
require competitive bidding for renewals of a gTLD registry agreement, rather
than granting the incumbent operator a perpetual right to renew without
competition...We respectfully suggest that the DOC refrain from expressing
satisfaction with ICANN's progress toward the goal of promoting competition
among TLDs unless and until ICANN develops a credible and effective policy that
compels it to employ tools such as competitive bidding to manage TLDs in a
manner that safeguards the interests of registrants in obtaining high quality
domains at the lowest possible prices. To date, we believe that ICANN has not
come close to fulfilling its obligations to employ competitive principles in
its management of TLD registry operations."
(http://www.ntia.doc.gov/comments/2008/ICANN_081218.pdf) Unfortunately, ICANN
declined to take that advice and has subsequently entered into renewal
agreements with other incumbent gTLDs that embrace perpetual renewal and
unjustified, unexplained, and often unlimited price increases, and has
established a model agreement for new gTLD registry operators with the same
fundamental flaws. Meanwhile, in 2009 the United States terminated its direct
oversight of ICANN (although we would assert that, as a California non-profit
corporation, ICANN remains subject to U.S. antitrust law).
* The presumptive renewal provisions are drafted in a manner that makes it
nearly impossible for VeriSign to ever face potential termination of the
agreement and its competitive rebid. Termination under Section 6.1 can occur
only if VeriSign is notified by ICANN of a fundamental and material breach of
its obligations, refuses to cure such breach, forces ICANN to take the matter
to arbitration or court, and then refuses to comply with the decision of the
arbitrator or court. This is a scenario that is unlikely to ever occur, that
permits a registry operator to continue operating in breach of its agreement
for months or even years, and that effectively converts presumptive renewal to
guaranteed perpetual renewal. In our view, a registry operator should be
required to cure any fundamental and material breach of its agreement with
ICANN no later than 30 days after receiving notification, and the onus should
be on the registry operator to seek redress if it believes that ICANN's
assertion is wrong.
* The pricing provisions of Section 7.3 (d) continue to permit VeriSign to
raise prices by seven percent in four out of six contract years without any
justification whatsoever, without any reference or indexing to overall
inflation (which has been exceedingly low in recent years), and without any
requirement to even state the rationale for such price increases. We also note
that additional price increases may be imposed in the two remaining years under
this agreement provision that references new Consensus Policies as well as both
actual and threatened cyberattacks :
In any year, however, where a price increase does not occur, Registry Operator
shall be entitled to increase the Maximum Price by an amount sufficient to
cover any additional incremental costs incurred during the term of the
Agreement due to the imposition of any new Consensus Policy or documented
extraordinary expense resulting from an attack or threat of attack on the
Security or Stability of the DNS...
At a minimum, we believe that VeriSign or any other gTLD registry operator
should be required to publicly state its rationale for any price increase in
keeping with ICANN's principles of accountability and transparency. We believe
that such a public rationale requirement would not be a material change in the
contract's terms and conditions and that ICANN could therefore place it within
this renewal agreement. In addition, it is lamentable that ICANN has never
authorized any economic study to determine the base cost of providing registry
services or that addresses the issue of whether the operator of a large
registry such as .com enjoys economies of scale that make its per domain
operating costs lower than average. Like many others, we cannot help but note
that domain registration pricing at the much smaller .net registry also
operated by VeriSign is substantially less than for .com, even though the
largest gTLD likely enjoys the most favorable economies of scale.
* Overall, we believe that ICANN has tied its own hands to a highly
regrettable degree in this and other successor registry operator contracts by
committing itself to renewal on essentially the same terms for an unlimited
period other than for incorporation of new Consensus Policies, and that by
doing so it has harmed the interests of general public registrants. Given the
rapid evolution of the Internet as well as changes in the competitive structure
of the DNS - changes that are likely to accelerate given the looming
introduction of massive numbers of new gTLDs - it appears quite unwise and
irresponsible for ICANN to have placed itself in a position where seeking to
impose any fundamental change in a registry agreement would be a breach of the
predecessor agreement and would expose it to litigation and significant
potential damages. In this lopsided contractual context, putting the .com
agreement out for competitive rebid would almost surely trigger litigation
against ICANN by VeriSign that could well result in a settlement agreement that
is even more adverse to the public interest than the proposed renewal.
In regard to presumptive renewal ICANN's notice correctly states the basic
situation in a manner that reinforces the deficiencies we have noted:
The registry agreement precludes a competitive bidding process to provide .com
registry services. The renewal provisions in the current .com Registry
Agreement are consistent with all the other ICANN gTLD agreements. All ICANN's
gTLD registry agreements essentially provide that they will be renewed absent a
serious breach of the agreement. These renewal provisions encourage long-term
investment in robust TLD operations, and this has benefitted the community in
the form of reliable operation of the registry infrastructure. ICANN does not
have the right under the current .com Registry Agreement to unilaterally refuse
to renew the agreement or to bifurcate registry functions. Breaching the
renewal provision would expose ICANN to liability under the contract. (Emphasis
added)
We do note for the record that we are not aware any fundamental and material
breach of the current contract committed by VeriSign. Indeed, it appears that
their .Com operations has been consistently reliable and quite secure.
On the matter of future price increases, ICANN's notice provides this relevant
description:
Registry services pricing: Both the current .com registry agreement and the
proposed renewal agreement permit Verisign to increase the price it charges
registrars for domain names registrations four times during the six-year term
with each increase being no greater than 7%. This provision was substantially
negotiated between Verisign on the one hand, and the U.S. Department of Justice
and the U.S. Department of Commerce, on the other. The current agreement
(Section 4.2) specifies that the pricing and renewal provisions (among others)
are not subject to change through the agreement renewal process. If the .com
pricing provisions were to be changed to be similar to the other large gTLDs
then that would most likely allow Verisign to raise prices by 10% per year in
each of the six years of the agreement, as in the .biz, .info, .net, and .org
agreements. Note: ICANN's registry agreement for new gTLDs and registry
agreements for sponsored gTLDs (.aero, .asia, .cat, .coop, .jobs, .mobi,
.museum, .post, .pro, .tel, .travel, and .xxx) do not include any price
controls. (Emphasis added)
Again, for the record, we concede that VeriSign would undoubtedly point out
that .com continues to have the most restrictive price caps of any gTLD - with
the other significant gTLDs allowed to raise wholesale prices by 10% every
year, and with the less significant ones - and all the coming new gTLDs -
subject to no price caps at all. VeriSign would probably also note that .Com
will face potential competition from a slew of new gTLDs over the next six
years (although we don't yet know for how many it will be either registry
operator or backend technical services provider). Nonetheless, as previously
stated, we believe that .com is qualitatively differentiated from other gTLDs
due to its market dominance and high secondary market domain valuations and
that this difference justifies continues to justify more restrictive
contractual terms. Further, the fact that ICANN has entered into even more
adverse contracts for other gTLDs does not convert the .com contract into one
that protects the broad public interest.
It will be several years before we can gauge whether a .Web or other lower
price point general purpose generic gTLD operated by a party other than
VeriSign can gain market share from .com. While VeriSign is not required to
exercise the price increase capability that is extended under this Agreement,
it is a public company and its management has a duty to maximize shareholder
value. We therefore presume that it will use all four of the increase
opportunities unless there is at least a significant decline in .com registry
growth, much less an unprecedented decline in overall .com registrations. On
the other hand, .com registry revenues will not immediately grow by 7% each
time pricing is increased, as many registrants have or will take advantage of
their ability to lock in current pricing for up to ten years.
Since we are not to have any market testing of .com pricing through a contract
rebid process, it is all the more important that the new gTLD program is
managed in a way that maximizes the probability that one or more new general
purpose generic gTLDs brings outside pricing pressure to bear on .com and other
incumbent registries. Competition, after all, is the one of the promised
benefits from new gTLDs.
In this regard, the most important aspect of the "digital archery" approach to
new gTLD application batching recently announced by ICANN is that it does not
discriminate between gTLD types, and thereby assures the maximization of
diverse types of new gTLDs and the greatest introduction of potential new price
competition between registries. This is highly preferable to a prioritization
system that has been floated by some trademark interests, who would have ICANN
process IDNs first, .geos second, .brands third, and all .generics dead last.
We have nothing against new gTLDs in non-ASCII scripts or city, state, and
nation gTLDs. And we believe that some savvy brand owners are going to find
that owning their .brand at the top level of the DNS provides multiple benefits
at very reasonable costs. But new .generics should be beneficial as well, and
their greatest potential benefit is the fostering of domain price competition
among registries.
While recognizing that new gTLDs will not be subject to pricing limitations, we
hope to see a variety of new monetization models that include low cost or even
free domains. In any event, new gTLD choices in the general purpose and
vertical generic spaces will hopefully provide meaningful competitive benefits,
especially those that are operated by new entrants into the registry space.
Therefore, a non-discriminatory batching policy must be adhered to as a means
of generating marketplace price competition against .com.
Additional Matters
In reviewing changes negotiated between ICANN and VeriSign in this new draft
agreement, we take note of and generally approve the following positive
modifications:
* General modernization provisions consistent with post-2006 policy
changes, including enhanced cybersecurity (implementation of IPv6 and DNSSEC),
IDN compliance, and clarified point of abuse contact designation.
* Continued prohibition of universal wildcard services, such as last
decade's controversial 'Sitefinder' proposal, with new language limiting
commercially usable traffic data to that available under a "thin" registry
model even if .com is required to convert to "thick" WHOIS during the term of
the renewal agreement.
* Required cooperation with ICANN registrar compliance actions, including
registrar suspensions.
* Enhanced audit provisions that facilitate more robust contract compliance
efforts by ICANN.
* New language in the draft Appendices which specifies extremely high
required performance levels for VeriSign's operation of .com (99.99% SRS
Service Availability per calendar year, and 100% DNS Name Server and WHOIS),
and that amend the Service Level Agreement (SLA) to require specified monetary
compensation to registrars for any failure to meet these targets, with
aggregate credits ranging from $100,000 to $1 million.
We also note that ICANN has deferred imposition of "thick" WHOIS implementation
for .com, with the ultimate disposition of that issue to be decided by the GNSO
Policy Council. For the record, ICA's Code of Conduct requires our members to
submit correct WHOIS contact information and to comply with lawful requests for
data placed under privacy protection. And our understanding has been that
VeriSign is neutral on whether .com should continue to have "thin" WHOIS - with
the more detailed registrant data still available but residing at their
registrars -- or should be required to convert to the "thick" WHOIS database
maintained by other gTLDs. ICA has no position in regard to whether or not
"thick" WHOIS requirements should be imposed on .com
Conclusion
ICA appreciates this opportunity to comment in the regarding the draft renewal
Agreement for VeriSign's continued operation of the .com registry.
Thank you for considering our views in this matter.
Sincerely,
Philip S. Corwin
Counsel, Internet Commerce Association
Philip S. Corwin, Founding Principal
Virtualaw LLC
1155 F Street, NW
Suite 1050
Washington, DC 20004
202-559-8597/Direct
202-559-8750/Fax
202-255-6172/cell
Twitter: @VlawDC
"Luck is the residue of design" -- Branch Rickey
Attachment:
ICA-dotcom_renewal_comment_letter-FINAL-042612.docx |