Open comment to ICANN submitted 2020-Feb-14 @ 23:58 UTC
Dear Members, Board Members, Employees and Advisors of ICANN,
I write to you today in hopes to make you aware of the potential damage your Proposed Amendment #3 will do to the Internet Community as a whole, as well as to all the citizens of the world. Before doing so, I feel I need to quote something to serve as a reminder some of you seem to have forgotten:
“In performing its Mission, ICANN must operate in a manner consistent with these Bylaws for the benefit of the Internet community as a whole” – ICANN BYLAWS 1.2a (First Sentence)
While your proposal to allow the raising of .com pricing 31% from $7.85 USD to $10.26 USD might not seem like much, I specifically specified “USD” to stress the fact that for the majority of the people you are charged to represent, almost any price in “USD” is already a challenging sum to accrue.
Yet many people still pay what is a sizeable fee to them, because establishing themselves on a .com domain finally gives them a global voice, a planetary platform, a megaphone to the world; from which they can share information and ideas to improve their quality of life; or their political situation in the case of the oppressed or those who do not benefit from the same legal rights and freedoms of those in the nations where $7.85 seems insignificant; or even develop businesses from which the brightest entrepreneurs in the world can empower themselves to economic freedom for themselves, their families and communities while offering helpful goods and/or services to be benefited from by the rest of the world.
In fact, it would be wrong for me to even try to list all the possible ways in which a globally understood Domain Name can benefit an individual, a community, a society or even humanity as a whole. Such a list could never actually be complete specifically because of the grandiose scale of imagination and diversity of thought throughout our shared planet.
With regards to ANY increase in costs to .com domains, it is imperative that you understand that by allowing such increases to continue, you are removing the abilities of some to continue to have and share their voices, ideas and visions. What you would in fact be doing is censorship against the citizens of the world rather than helping those without a voice to finally have one. It would also be a threat to democracy in the cases where people struggle to share crucial information or their own ideas, and then go on to debate and challenge the status quo in hopes for something better.
The foundational premise of the internet is to help bring every citizen of the world together, as such we should be fighting to remove and reduce the barriers to access in each and every way possible, with one of the most notable being the cost of having a voice, the cost of being relevant, the cost of sharing an idea, information, a vision, a concept, a project or any of another countless things from which the rest of humanity can learn or grow from.
Beyond that, while clearly the pricing increases within Proposed Amendment #3 will be harmful to the people you are pledge to serve and protect, the “Internet Community” is still in growth. Also to be considered are not just the people currently with a .com domain who might no longer be able to afford the current global recognition thanks to having a .com domain; but also those who at $7.85 per year are already priced out of having such a voice. By implementing Proposed Amendment #3 you are effectively ignoring the voices of those who are currently unheard; of those who for whom having a global voice isn’t even possible now. By allowing the increasing of prices you would be diminishing their voices even more, sadly rendering them effectively meaningless because nobody will ever get a chance to listen to what they have to say.
With private enterprise creating and operating ngTLD registries, I personally don’t mind them seeing them used and even priced based on different priorities. Some of such TLDs have great potential to improve the Internet.
HOWEVER .. It should be very clear that there be a foundation of the Domain System and a minimum catalogue of TLDs available to anyone and everyone, regardless of race, location and fiscal capacity. By far the biggest and most significant of such TLDs is the .com TLD, of which there is currently no match and no realistic alternative.
While the current partially private structure within which the .com TLD is set up indeed has certain basic costs that cannot be ignored; the current .com steward, Verisign, is one of the most profitable companies in the world when it comes cost:profit and employees:profit ratios. The term “Cash Cow” is one regularly used when discussing the fiscal strength and success of Verisign. While all companies should strive to remain profitable, in this specific case it needs to be VERY clear that any unreasonable profits made by verisign, comes at the cost of censorship upon the least fortunate people in the world. Please do not forget that fact, and do not ignore your mandate to serve the ENTIRE global community.
ICANN should not and cannot simply ignore the facts and numbers, as those numbers prove that there is zero necessity or need to increase prices and therefore further incapacitate a larger portion of global citizens from acquiring a .com domain, one of the strongest globally recognised platforms in human history.
Furthermore, not only should any potential .com pricing increases be removed from Proposed Amendment #3, but if indeed ICANN were truly concerned with ALL the people they are mandated to represent, they should end the monopolistic and anti-competitive nature of the .com TLD and open the .com registry to actual competition via a bidding process.
This is not to say that the secure and stable history of the .com TLD under Verisign’s stewardship should be completely dismissed, nor that it shouldn’t even be given a premium versus other potential bidders. But without any real competition and a complete and fully transparent costing analysis of the operations of the .com registry, ANY increase in pricing in any way given the ever continuing reductions in technology costs is quite simply absurd.
In the end I implore you to think of the millions and eventually potentially billions of people that WILL BE harmed if .com domains allowed to go up in price … and remember that it’s those very billions of people that ICANN is supposed to represent.
Thank you for time and giving these comments the full consideration they deserve. If you have any questions or would like any clarifications, please do not hesitate to reach out.