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Username: SBSC
Date/Time: Tue, March 6, 2001 at 4:20 PM GMT
Browser: Microsoft Internet Explorer V5.5 using Windows 98
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Subject: Letter of Support for Proposed Amendment


      The following letter was sent to US Commerce Department Secretary Donald Evans in support of the agreement:

On behalf of the Small Business Survival Committee ( and its more than 70,000 members across America, I wanted to take this opportunity to urge the Department of Commerce to support cooperative agreement reached between the Internet Corporation for Assigned Names and Numbers (ICANN) and VeriSign, Inc. that would allow VeriSign to operate the .com Registry until at least 2007 and the .net Registry until at least 2006.

In 1999, an agreement was reached between ICANN and Network Solutions (now named VeriSign, Inc.) that called for Network Solutions to separate legal ownership of its Registry Services business from its Registrar business.  This agreement was reached in an attempt to advance competition among registrars, and the proposed amendment is intended to address the state of the current marketplace.

A principal reason the Department of Commerce should support the proposed amendment is the fact that the goals of the original agreement have largely been met.  The original agreement was crafted in an attempt to bring new competitors into the marketplace of providers of Internet domain names.  Since the 1999 agreement, ICANN has now accredited over 180 competitive registrars, of which nearly 90 are already operational.  In addition to the dramatic growth in the number of companies marketing .com, .net and .org top level domain names, the prices for these services have also dramatically decreased.  In fact, the average cost to obtain a domain name has fallen from an average of $70 for two years down to below $15 per year.

There is no inherent reason why a company should not be allowed to operate a Registry while also competing as a Registrar.  In fact, ICANN allows companies to serve both functions, and the amendment to the original agreement will create a level playing field that does not require VeriSign to divest itself from the Registrar business.  The changing nature of technology and the Internet means that companies must have the flexibility to adopt their business plans on a relatively quick timetable, and this proposed amendment to the original agreement has been negotiated in response to new conditions that were not present in 1999.

The Department of Commerce is charged with reviewing any changes to the original agreement, and the Small Business Survival Committee wishes to express our support for the amendment.  While it may not appear to be an agreement that will help small businesses, there are several very simple reasons why this amendment is needed to protect the interests of millions of small entrepreneurs across America, not to mention the rest of the world.

First, competition has exploded since the original agreement was signed.  By removing a significant competitor from the market of those serving as domain registrars, the incentives for keeping the cost of Internet domain names down will be largely removed.  Prices have fallen because companies are competing for market share.  Removing VeriSign from the market will remove the pressure other companies face to keep lowering prices.

Second, small businesses set up websites and select domain names for a variety of reasons -- among which is the knowledge and comfort of choosing a branded company with a long track record of service. Other companies and competitors to VeriSign are competing to build brand loyalty, but those customers who choose to stay on with VeriSign to build or renew their Internet registrations should be allowed to do so if they choose.  If VeriSign fails to provide adequate service for reasonable prices, small businesses will switch to another company to act as their website registrar.  VeriSign has an incentive to keep prices low and service quality high, and it should be allowed to continue in this business model given the fact the goals of the original agreement have largely been met.

Perhaps the greatest reason to support the proposed amendment is simply one of fairness.  As the Internet business changes daily to meet the needs of small businesses and consumers, companies seeking to compete in the registrar market must be operating on a level playing field.  Forcing VeriSign to operate in a structurally different manner from its competitors places the company at a competitive disadvantage.  With an increasingly competitive environment, the public interest is not well served to force a company to spin off or sell a key component of its operation as a result of an agreement that was forged in an entirely different market. 

Thank you for your attention to this matter, and I hope the Department of Commerce will see the wisdom of ensuring long term competition in the market for Internet domain names and support the agreement reached between VeriSign and ICANN.  Please feel free to contact me at (202) 785-0238 with any questions, and I look forward to working with you on this and many other matters.


Christopher A. Wysocki



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