I am certainly not convinced
that the "CHANGES IN CIRCUMSTANCES SINCE THE ORIGINAL AGREEMENT" section can be considered
accurate, or (if technically accurate) that it is at all relevant.
"ICANN has received no substantial complaints about discriminatory access to the
registries operated by VeriSign, and there is no indication or evidence that has
come to the attention of ICANN that VeriSign has not fully and effectively erected
a complete firewall that prevents any discriminatory information flow..." This
means, in essence, that ICANN denies any validity or importance regarding any complaints
it may have received. But that is the judgement of ICANN regarding a specific
set (empty or otherwise) of complaints, and does not address other complaint sets
or other judgements of the specified complaint set.
More importantly, even if the
"information" in that section is reasonably valid, I do not believe it is important.
The general message behind the overall proposed revisions is that VeriSign has not
abused its positions (according, at least, to VeriSign and ICANN, but not necessarily
according to others), so safeguards to ensure it does not abuse that position can
now be removed.
Let's look at an analogy: A new office building is constructed.
Fire extinguishers are on site during construction in case of fire, and the plan
is to install sprinklers. No fire occurs during construction. To use
the ICANN/VeriSign logic, the sprinklers should never be installed.
registry/registrar business separation to be the sprinklers. ICANN and VeriSign
want to take that away because supposedly no "fire" (abuse of position) has happened
...you disagree with the logic of limiting protections because nothing
bad has happened yet, or
...you disagree with the premise established in the CHANGES
IN CIRCUMSTANCES SINCE THE ORIGINAL AGREEMENT section, or
...you consider comments
about how this will put VeriSign on the same level as other registrars to be Orwellian
doublespeak (given the obvious preferences on the registry side of the business),
...you consider the phrase "significant benefits to the community" in the context
of the proposed revisions to be meaningless or deceptive, or
disagree with these revised provisions,
...PLEASE lobby directly with the US Department
of Commerce and (if you are a US citizen) with your elected officials in government.
DO NOT expect this public comment message board to have any impact, and DO NOT expect
to see resolution directly from ICANN.