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BAD FOR INTERNET USERS - This Early RA Renewal will lay the foundation for no .COM Pricing Oversight in 2018

  • To: "comments-com-amendment-30jun16@xxxxxxxxx" <comments-com-amendment-30jun16@xxxxxxxxx>
  • Subject: BAD FOR INTERNET USERS - This Early RA Renewal will lay the foundation for no .COM Pricing Oversight in 2018
  • From: Ricarda Koppel <koppelricarda@xxxxxxxxxxx>
  • Date: Thu, 11 Aug 2016 21:44:21 +0000

This  proposed RA should NOT be extended, because it will lay for the 
foundation for no pricing oversight on .COM domain names in 2018.  Once 
VeriSign has no pricing oversight, they will be able to charge whatever they 
want for .COM domain names.  As we have witnessed in the past with .COM and 
more recently with .NET domain names, VeriSign will use every chance possible 
to increase the price of domains without any justification whatsoever to fatten 
the company’s bottom line. 

Let me explain:

1. This early RA extension is approved in its current form

2. The new Root Zone Maintainer Service Agreement is put into place between 
VeriSign and ICANN (which replaces most of the functions from the existing 
Cooperative Agreement.)

3. The Cooperative Agreement (between VeriSign and NTIA) is allowed to 
naturally expire in 2018.  The Cooperative Agreement contains the all-important 
pricing provision.  This agreement will longer be necessary because almost all 
of the functions from the existing Cooperative Agreement have been moved to the 
new Root Zone Maintainer Service Agreement (besides pricing.)

Thus, in 2018 when the Cooperative Agreement expires, VeriSign will no longer 
be subject to government-mandated price restraints.

VeriSign will only answer to ICANN in 2018 and beyond and it is foolish to 
assume ICANN will take any role in pricing of domain names as it has never had 
any intention of regulating pricing of second level domains.  Furthermore, 
there are terms in the RA that prevent ICANN from negotiating on the 
presumptive right of renewal or .COM pricing.

Phillip Corwin from the ICA wrote in a letter to Honorable Lawrence E. 
Strickling, Assistant Secretary for Communications and Information & 
Administrator of the NTIA back in 2012 with the following:

“Given ICANN’s self-imposed legal impotence, rendering it unable to negotiate 
any alteration in the presumptive renewal or registration pricing provisions of 
the proposed .Com  Agreement, only the Department of Commerce – acting in 
concert with the Department of Justice – can protect the overall public 
interest by compelling .Com pricing changes as a condition for government 

Thus, when the Department of Commerce and the NTIA go away in 2018 (because the 
Cooperative Agreement naturally expires), you have a situation where there is 
no oversight on VeriSign with regards to pricing of .COM domain names.

This is exactly why VeriSign is pushing for this early renewal.  This early 
renewal only benefits VeriSign.

We urge ICANN and the Department of Commerce and the NTIA to understand this is 
an EXTREMELY bad scenario for Internet users all over the world.  ICANN and 
NTIA should act in the public interest and should make sure they are not laying 
the path for unrestricted .COM pricing!  Especially considering .COM maintains 
huge market power. 


- Reject the proposed RA extension outright

-  Incorporate pricing provision & force a yearly reduction of .com prices into 
this new RA

 - Remove presumptive right of renewal clause – which will allow for this 
no-bid contract to be sent out for competitive bid and will benefit the entire 
Internet ecosystem


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