Public Comment (forwarded to Andrew Moulden) [on behalf of Marcia Lynn Walker]

[Andrew Moulden <andrew@xxxxxxxxxxx>]

Our company believes that the proposed registry agreements SHOULD BE 
WITHDRAWN IMMEDIATELY, as they are anti-competitive and against core 
principles on which ICANN was formed.

In addition, in the proposed agreements, ICANN is attempting to give 
registries the power of determining valuation for domains and websites, 
which is clearly outside the bounds of ICANN's role of technical 
oversight, and clearly outside the ability of registries to do with any 
accuracy whatsoever.

Using our business as an example, we publicly state that registries are 
not knowledgeable about our expenses or profits, or the percentage of 
business that is generated through our websites; hence they cannot 
possibly determine with any accuracy the worth of our sites.

Furthermore, the registry had no input whatsoever in increasing the 
value of our websites; hence they should not be "rewarded" with higher 
annual renewal fees for the domain names on which we chose to build our 
websites.

That is, unless the registry were to simultaneously pay a proportionate 
percentage of:

* Our initial development costs;
* Fees paid, over several years, to programmers, graphic designers, 
writers, photographers, and hosting companies;
* Ongoing expenses to update, upgrade, and maintain our websites so that 
visitors are continually served useful, relevent, and up-to-date 
information;
* Advertising and marketing costs for promoting our websites in various 
media including online, in print, on radio, and on broadcast TV.

Clearly, any increase in value came about as a result of our company's 
effort, and at GREAT EXPENSE.

The brick mason who builds a foundation isn't permitted to come back 
years later, guestimate current value of the office building that now 
sits on the foundation, and profit from his assessment.  And if the 
contractor who hired that brick mason gave him the authority to do so, 
he'd likely be prosecuted and jailed.

Similarly, ICANN should not consider giving any registry operator the 
ability to profit from the basic foundation of all web content, domain 
name registrations and annual renewals.

Marcia Lynn Walker, CEO
Myrtle Beach Inc.