Public Comment

["Marcia Lynn Walker" <marcia@xxxxxxxxxxxxxxxxxx>]

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WITHDRAWN IMMEDIATELY, as they are anti-competitive and against core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.