ICANN grants Verisign its price increases, of course

ICANN has given Verisign its ability to increase .com prices by up to 7% a year, despite thousands of complaints from domain owners.

The amendments give Verisign the right to raise prices in each of the last four years of its six-year duration. The current price is $7.85 a year.

Because the contract came into effect in late 2018, the first of those four years begins October 26 this year, but Verisign last week said that it has frozen the prices of all of its TLDs until 2021, due to coronavirus.

Not accounting for discounts, .com is already already worth $1.14 billion in revenue to Verisign every year, based on its end-of-2019 domains under management.

In 2019, Verisign had revenue of $1.23 billion, of which about half was pure, bottom-line, net-income profit.

In defending this shameless money-grab, ICANN played up the purported security benefits of the deal, while offering a critique of the domainers and registrars that had lobbied against it.

Göran Marby, ICANN’s CEO, said in a blog post.

I believe this decision is in the best interest of the continued security, stability, and resiliency of the Internet.

…

Overall, the decision to execute the .COM Registry Agreement amendment and the proposed binding Letter of Intent is of benefit to the Internet community.

The decision was explained in more detail in a eight-page analysis document (pdf) published late last week.

I’ll summarize this paper in three bullet points (my words, not ICANN’s):

• Domainers are hypocrites.
• The deal is good for DNS security.
• Our hands were tied anyway.

First, while ICANN received over 9,000 comments about the proposed amendment, almost all negative, it said that publicity campaigns from domainer group the Internet Commerce Association and domainer registrar Namecheap were behind many of them.

the Internet Commerce Association (ICA) and Namecheap, are active players in the so called “aftermarket” for domain names, where domain name speculators attempt to profit by “buying low and selling high” on domain names, forcing end users to pay higher than retail prices for desirable domain names

It goes on to cite data from NameBio, which compiles lists of secondary market domain sales, to show that the average price of a resold domain is somewhere like $1,600 (median) to $2,400 (mean).

Both Namecheap and ICA supporter GoDaddy, which sells more .coms than any other registrar, have announced steep increases in their .com retail renewal fees in recent years — 20% in the case of GoDaddy — the ICANN document notes.

This apparent hypocrisy appears to be reason ICANN felt quite comfortable in disregarding many of the negative public comments it received.

Second, ICANN reckons other changes to the .com contract will benefit internet security.

Under a side deal (pdf) Verisign’s going to start giving ICANN $4 million a year, starting next January and running for five years, for what Marby calls “ICANN’s initiatives to preserve and enhance the security, stability, and resiliency of the DNS.” These include:

activities related to root server system governance, mitigation of DNS security threats, promotion and/or facilitation of Domain Name System Security Extensions (DNSSEC) deployment, the mitigation of name collisions, and research into the operation of the DNS.

Note that these are without exception all areas in which ICANN already performs functions, usually paid for out of its regular operating budget.

Because it looks like to all intents and purposes like a quid pro quo, to grease the wheels of getting the contract amendments approved, Marby promised that ICANN will commit to “full transparency” as to how its new windfall will be used.

The new contract also has various new provisions that standardize technical standardization and reporting in various ways, that arguably could provide some minor streamlining benefits to internet security and stability.

But ICANN is playing up new language that requires Verisign to require its registrars to forbid their .com registrants from doing stuff like distributing malware and operating botnets. Verisign’s registrar partners will now have to include in their customer agreements:

a provision prohibiting the Registered Name Holder from distributing malware, abusively operating botnets, phishing, pharming, piracy, trademark or copyright infringement, fraudulent or deceptive practices, counterfeiting or otherwise engaging in activity contrary to applicable law and providing (consistent with applicable law and any related procedures) consequences for such activities, including suspension of the registration of the Registered Name;

Don’t expect this to do much to fight abuse.

It’s already a provision that applies to hundreds of other TLDs, including almost all gTLDs, and registrars typically incorporate it into their registration agreements by way of a link to the anti-abuse policy on the relevant registry’s web site.

Neither Verisign nor its registrars have any obligation to actually do anything about abusive domains under the amendments. As long as Verisign does a scan once a month and keeps a record of the total amount of abuse in .com — and this is data ICANN already has — it’s perfectly within the terms of its new contract.

Third and finally, ICANN reckons its hands were pretty much tied when it comes to the price increases. ICANN wrote:

ICANN org is not a competition authority or price regulator and ICANN has neither the remit nor expertise to serve as one. Rather, as enshrined in ICANN’s Bylaws, which were
developed through a bottom up, multistakeholder process, ICANN’s mission is to ensure the security and stability of the Internet’s unique identifier systems. Accordingly, ICANN must defer to relevant competition authorities and/or regulators, and let them determine if any conduct or behavior raises anticompetition concerns and, if so, to address such concerns, whether it be through price regulation or otherwise. As such, ICANN org has long-deferred to the DOC and the United States Department of Justice (DOJ) for the regulation of wholesale pricing for .COM registry services.

It was of course the DoC, under the Obama administration, that froze Verisign’s ability to raise prices and, under the Trump administration, thawed that ability in November 2018.

If you’re pissed off that the carrying cost of your portfolio is about to go up, you can blame Trump, in other words.

No .com price increases this year. Thanks, coronavirus!

Verisign won’t increase prices on .com or any of its other TLDs this year.
The promise comes as part of a package of coronavirus-related measures the company announced on its blog yesterday. Verisign said:

In order to support individuals and small businesses affected by this crisis, Verisign will freeze registry prices for all of our Top-Level Domains (TLDs), including .com and .net, through the end of 2020. In addition, we will soon deploy a program, available to all retail registrars, to provide support and assistance for domain name registrants whose domain names will be expiring in the coming months.

No additional details on the proposed registrant support program were made available.
The pricing news sounds good, especially for high-volume domain owners such as domainers and trademark owners, but it should be noted that in the case of .com it amounts to a mere two-month price freeze.
Under the terms of its current agreement with ICANN, it can’t raise prices at all. The controversial proposed amendments that recently attracted about 9,000 objections, would reinstate price-raising powers.
However, assuming ICANN approves the new contract, which seems likely, Verisign would only be able to up its fees in the final four years of its six-year deal. The first of those four years begins October 20 this year.
Conceivably, it could have announced a 7% price hike for .com on October 21, but the company has now said that it will not.
Verisign also said yesterday that it’s donating an “initial” $2 million to “first responders and medical personnel in the Northern Virginia area, the United Way’s COVID-19 relief efforts, and the Semper Fi & America’s Fund”.
It is also doubling the funding available to the scheme where it matches employees’ charitable donations, which could increase (and incentivize) giving to coronavirus-related causes.

Nominet to intercept dangerous coronavirus domains

Nominet, the .uk registry, will start providing informational landing pages when it suspends domains for criminal behavior including coronavirus-related scams.
The company already suspends tens of thousands of domains every year at the request of law enforcement agencies.
The vast majority are related to intellectual property infringement such as counterfitting and piracy. A substantially smaller number are suspended due to the sale of fake pharmaceuticals.
Rather than Nominet suspending these domains, stopping them resolving, they will now instead resolve to landing pages “providing consumer advice and education”.
It’s similar to how the FBI handles domains it has seized during criminal investigations in the US, but Nominet says it’s the first example in the world of such a program being rolled out by a registry.
The first LEAs taking part in the program are the Medicines and Healthcare Products Regulatory Agency and the City of London’s Police Intellectual Property Crime Unit.
While Nominet pitched the news as coronavirus-related, the timing appears to be coincidental.
The company first announced its landing page plan last October, when it was opened to public consultation.
A MHRA spokesperson said in a Nominet press release that suspended domains will redirect to its “#fakemeds website”, which currently has a great deal to say about penis pills but nothing at all to say about coronavirus.

US senators tell ICANN to reject .org deal

Five US senators have called on ICANN to not approve the acquisition of Public Interest Registry by Ethos Capital.
The senators — all Democrats — said in a March 18 letter published today that the proposed $1.13 billion deal is “against the public interest”.
The surprisingly detailed nine-page letter (pdf) was signed by Ron Wyden, Richard Blumenthal, Elizabeth Warren and Anna Eshoo, following up from a similar letter sent in January. The new letter also has Ed Markey as a signatory. They write:

We were concerned that the sale would be contrary to ICANN’s commitment to the public benefit, that it might undermine the reliability of .ORG websites, and that Ethos is unlikely to be a responsible steward of the .ORG registry. New information we have obtained in the last two months, including statements made by ISOC, PIR, and Ethos, has validated these concerns. Accordingly, we write to reiterate our view that ICANN should block the proposed change of control of the .ORG registry.

Chief among their concerns is the lack of transparency about who is actually bankrolling the deal. Ethos has confirmed it will be partially funded by loans, but the identities of its actual owners have not been confirmed.
It’s been said that two of the backers are investment firms linked to high-profile Republicans — Senator Mitt Romney and the late Ross Perot.
The senators are also worried that the business plan Ethos has publicly laid out may not be realistic, suggesting that PIR will be forced to rip off customers in order to recoup the cost of the acquisition.
They go on to say that Ethos’ promise to only increase prices by 10% per year, enforceable via a Public Interest Commitment in its ICANN contract, is “weak”, particularly given that the commitment would automatically expire seven years from now.
They’re also not buying the notion that PIR’s proposed Stewardship Council, made up of outside .org stakeholders, would have enough power to guide registry policy, calling the council “toothless”.
ICANN is of course under no obligation to take its lead from a handful of legislators, but it’s yet another voice stacked against a deal that already had very little support.
ICANN has until April 20 to make a decision about the change of control.

.org decision delayed another month

ICANN has been given another month to decided whether or not to approve Ethos Capital’s proposed $1.13 billion acquisition of Public Interest Registry from the Internet Society.
PIR said today that it has agreed to give ICANN until April 20 to give it the yay or nay on the controversial deal.
It seems the disruption and distraction caused by the coronavirus pandemic played at least a small role in the decision. PIR said:

To ensure ICANN and the California Attorney General’s office, with which we have been communicating, have the time they need to address any outstanding questions regarding the transaction, especially in light of current events, we have agreed to an ICANN deadline extension to April 20th. We look forward to ICANN’s decision by this date.

Yesterday, opponents of the deal suggested that the acquisition could interfere with the global pandemic response, but PIR has dismissed these claims today as “misleading and alarmist” and “deceiving the public”.
Meanwhile, PIR has updated the proposed contractual Public Interest Commitments that it believes will address some of its critics’ concerns.
Future changes to the PICs will be subject to ICANN’s public comment process, the company said. This is presumably designed to calm fears that the registry will simply dump the PICs next time its contract comes up for renegotiation.
Given the level of confidence in the efficacy of the public comment process — which I would argue is currently close to zero — I doubt this new promise will have its intended effect.
PIR has also taken on criticism that its proposed .ORG Stewardship Council, designed to make sure .org continues to be managed in the public interest, could easily be captured by Ethos yes-men.
Now, instead of appointing the first five members of the council itself, Ethos will instead recruit an “internationally-recognized executive search firm” to find five suitable candidates from stakeholder groups including ICANN’s Non-Commercial Stakeholder Group and At-Large Advisory Committee.
Those nominations will still be subject to final approval by the PIR board, however, so again I think the deal’s critics will still have complaints to cling to.
PIR expects to announce further details of the council selection process next Monday, March 23.

Roundup: domain industry starts to respond to coronavirus pandemic

With much of the world already laboring under coronavirus-related movement and assembly restrictions, many domain industry companies have started to publicly outline their business continuity plans.
Some companies have already implemented blanket home-working rules, while others are ready to pull the trigger on such regimes just as soon as local government policy or other circumstances require it.
Here’s a roundup of what some of these companies have said over the last few days.
It’s not an exhaustive list — I’m sure many companies have unannounced contingencies in place — and it should be noted that some of these announcements may well be out of date already, due to the speed at which the virus risk, and government responses to it, are changing.

• In Italy, the nation hardest-hit by the virus outside of China, local ccTLD registry Registro.it said: “Due to the current health emergency, there may be delays in the processing of legal and administrative procedures in the coming days. Activities related to the registration and maintenance of domains will be carried out as usual”.
• NIC Chile, the .cl registry, has imposed a ban on outsiders attending its offices, effective today, “in order to safeguard the health of its clients and officials”.
• Portugal’s Associação DNS.PT, the .pt registry, has gone a step further, saying Friday that it has already adopted remote working. It added that it was not aware of any confirmed cases and that it expected business to continue as normal.
• An undated notice on DNS Belgium’s web site states: “To guarantee maximum business continuity, we temporarily close our office and all work from home.”
• Dutch ccTLD registry SIDN said Friday that “most” of its employees are working from home, and it will minimize in-person contacts to “strictly necessary” meetings. It does not expect disruption to services.
• Austrian Nic.at said that employees “who are not tied to the Vienna or Salzburg office locations due to their work can work from home by telework”, adding “strict hygiene measures apply in the offices”.
• In Denmark, DK-Hostmaster said that customer support will now be conducted purely via email, with phone support suspended until March 27.
• It’s the same story in Poland for .pl domains, according to a notice on the NASK web site.
• Afilias said Thursday that it has contingency plans in place to keep its registry business ticking over even if staff fall ill or office closures are mandated. It’s also stepped up office cleaning and made hand sanitizer available to staff. Employees will be able to home-work should the need arise, the company said.
• Corporate registrar family Com Laude said that it’s updated its business continuity and disaster recovery plans to account for the pandemic threat, including providing remote-working solutions for its staff.
• Network Solutions, part of Web.com, told customers Friday that its workforce is geared up to work from home too, and that customer service should be unaffected during the crisis.
• British registrar Astutium said it won’t book any in-person meetings with clients for the next 90 days, and that if anyone shows up for an already-booked meeting they will be required wash thoroughly before they’re let through the door.

I’ve not heard any reports yet of members of the industry with confirmed infections. So that’s good.

The latest industry C-suite musical chairs

There have been several top-level hires at big new gTLD players in the last week.
Donuts has announced it has appointed Mina Neuberg as chief marketing officer. Neuberg appears to be a newcomer to the domain industry, having most recently worked at a learning software company called Revolution Math. It’s the first time has had a named top marketing exec on its web site since VP Judith McGarry left a year ago.
Her appointment follows February’s announcement that Donuts hired Randy Haas as chief financial officer. He was previously CFO of Rhapsody/Napster, the online music company.
Meanwhile, Shayan Rostam has moved from Intercap Holdings, the registry for .inc, .dealer and .box, where he was chief registry officer, to portfolio registry Uniregistry, where he will be chief growth officer, a newly created position.
And DNW is reporting that new gTLD registry MMX has made two new C-level hires, both coming from Uniregistry: Vaughn Lilely has been recruited as chief growth officer while Ben Anderson is coming in as chief operating officer.

Ethos volunteers for .org pricing handcuffs

Ethos Capital has volunteered to have price caps written back into Public Interest Registry’s .org contract, should ICANN approve its $1.1 billion proposed acquisition.
The private equity firm said Friday that it has offered to agree to a new, enforceable Public Interest Commitment that bakes its right to increase prices into the contract under a strict formula that goes like this:

Applicable Maximum Fee = $9.93 x (1.10n)

The $9.93 is the current wholesale price of a annual .org registration. The “n” refers to the number of full years the current .org registry agreement has been in play, starting June 30, 2019.
In other words, it’s a 10%-per-year increase on average, but PIR could skip a year here and there and be eligible for a bigger price increase the following year.
For example, PIR could up the fee by 10% or $0.99 to $10.92 this coming June if it wanted, but if it decided to wait a year (perhaps for public relations reasons) if could increase the price to $12.13 in June 2021, an increase of $2.20 or roughly 22%.
It could wait five years before the first price increase, and up it from $9.93 to $16.53, a 66% increase, in year six.
While price increases are of course unpopular and will remain so, the formula does answer the criticism posed on DI and elsewhere that Ethos’ previous public statements on pricing would allow PIR to front-load its fee hikes, potentially almost doubling the price in year one.
But the caps have a built-in expiry date. They only run for eight years. So by the middle of 2027, when PIR could already be charging $18.73, the registry would be free to raise prices by however much it pleases.
It’s a better deal for registrants than what they’d been facing before, which was a vague commitment to stick to PIR’s old habit of not raising prices by more than 10% a year, but it’s not perfect and it won’t sate those who are opposed to increased fees in principle.
On the upside, a PIC is arguably an even more powerful way to keep PIR in line after the acquisition. Whereas other parts of the contract are only enforceable by ICANN, a Public Interest Commitment could theoretically be enforced via the PIC Dispute Resolution Procedure by any .org registrant with the resources to lawyer up. Losing a PICDRP triggers ICANN Compliance into action, which could mean PIR losing its contract.
The PIC also addresses the concern, which always struck me as a bit of a red herring, that .org could become a more censorial regime under for-profit ownership.
Ethos says it will create a new seven-person .ORG Stewardship Council, made up of field experts in human rights, non-profits and such, which will have the right to advise PIR on proposed changes to PIR policy related to censorship and the use of private user/registrant data.
The Council would be made up initially of five members hand-picked by PIR. Another two, and all subsequent appointments, would be jointly nominated and approved by PIR and the Council. They’d serve terms of three years.
The proposed PIC, the proposed Council charter and Ethos’ announcement can all be found here.
Correlation does not necessarily equal causation, but it’s worth noting that the proposal comes after ICANN had started playing hard-ball with PIR, Ethos and the Internet Society (PIR’s current owner).
In fact, I was just putting the finishing touches to an opinion piece entitled “I’m beginning to think ICANN might block the .org deal” when the Ethos statement dropped.
In that now-spiked piece, I referred to two letters ICANN recently sent to PIR/ISOC and their lawyers, which bluntly asserted ICANN’s right to reject the acquisition for basically any reason, and speculated that the deal may not be a fait accompli after all.
In the first (pdf), Jones Day lawyer Jeffrey LeVee tells his counterpart at PIR’s law firm in no uncertain terms that ICANN is free to reject the change of control on grounds such as the “public interest” and the interests of the “.org community”.
Proskauer lawyer Lauren Boglivi had told ICANN (pdf) that its powers under the .org contract were limited to approve or reject the acquisition based only on technical concerns such as security, stability and reliability. LeVee wrote:

This is wrong. The parties’ contracts authorize ICANN to evaluate the reasonableness of the proposed change of control under the totality of circumstances, including the impact on the public interest and the interest of the .ORG community.

Now, the cynic in me saw nothing but a couple of posturing lawyers trying to rack up billable hours, but part of me wondered why ICANN would go to the trouble of defending its powers to reject the deal if it did not think there was a possibility of actually doing so.
The second letter (pdf) was sent by ICANN’s new chair, Maarten Bottermann, to his ISOC counterpart Gonzalo Camarillo.
The letter demonstrates that the ICANN board of directors is actually taking ownership of this issue, rather than delegating it to ICANN’s executive and legal teams, in large part due to the pressure exerted on it by the ICANN community and governments. Botterman wrote:

It is not often that such a contractual issue raises up to a Board-level concern, but as you might appreciate, PIR’s request is one of the most unique that ICANN has received.

He noted that the controversy over the deal had even made ICANN the target of a “governmental inquiry”, which is either a reference to the California attorney general’s probe or to a letter (pdf) received from the French foreign office, demanding answers about the transaction.
It’s notable from Botterman’s letter that ICANN has started digging into the deep history of PIR’s ownership of .org, much as I did last December, to determine whether the commitments it made to the non-profit community back in 2002 still hold up under a return to for-profit ownership.
Given these turns of events, I was entertaining the possibility that ICANN was readying itself to reject the deal.
But, given Ethos’ newly proposed binding commitments, I think the pendulum has swung back in favor of the acquisition eventually getting the nod.
I reserve the right to change my mind yet again as matters unfold.

Verisign shits on domainers, again

It’s probably no exaggeration to say that Verisign makes hundreds of millions of dollars a year from .com domain investors, and yet it’s been developing a habit in recent years of shitting on them whenever it serves its purpose.
The company’s submission to ICANN’s just-closed public comment period on the proposed new .com contract, which re-enables Verisign’s ability to increase its prices, is the latest such example.
In the letter, which is unsigned, Verisign accuses the Internet Commerce Association, as well as registrars Namecheap and Dynadot, of conducting a “deceptive” campaign to persuade .com registrants to submit comments opposing the deal.
It notes that ICA represents “speculators” — it never uses the term “investors” — as if this was some kind of closely guarded secret, and describes the practice of domaining in a way that implies that the practice is somehow “illegitimate”, like this:

More than any other group engaged in the ICANN multistakeholder process, these speculators are highly sensitive to even the smallest wholesale price changes because of the enormous portfolios of .com domain names they control.
…
Speculators sometimes sell these domain name registrations to other speculators, but often they pass these costs along when they sell the domain names to legitimate internet users who wish to use .com domain names to build websites. We believe this resale activity adds little value to the DNS.

It’s not wrong, but good grief! The chutzpah on this company is sometimes jaw-dropping.
It’s like a car manufacturer complaining that its billion-dollar range of off-road SUVs are mostly being used by obese city dwellers for the school run. Just take the billion dollars and stop complaining about your biggest customers!
It’s not the first time Verisign has rolled out this line of attack. Back in 2018, when price caps were being negotiated with the US government, it posted an article on CircleID accusing domainers of “exploit[ing] consumers” and “scalping”.
Verisign’s able to get away with this kind of attitude, of course, because most domainers have an almost erotically slavish devotion to .com. The company could spend all day every day emailing them disgustingly personalized “yo momma” jokes and they wouldn’t stop buying up its product by the millions.
The two sides are trapped in an emotionally abusive relationship but they can’t break up because they’re both making so much goddamn money out of it. They’re like the Clintons of the domain world, in other words.
Anyway, the gist of the company’s comment to ICANN is basically “Ignore the 9,000 other comments you’ve received, the commenters were suckered into writing them by lying registrars”.
Read it here (pdf).
As a matter of disclosure, Verisign cites the DI piece last week about covid-19.com as an example of why domainers suck. That wasn’t the intent of the article, but there you go.

9,000 people tell ICANN they don’t want .com price increases. Here’s what some of them said

The public have spoken: they don’t want Verisign to get the right to raise .com prices again.
ICANN’s public comment period on the amended .com contract closed on Friday, with just shy of 9,000 comments which appear to be overwhelmingly against price-raising powers.

Almost 2,000 of the comments have the same subject line, “Proposed Amendment 3 to the .COM Registry Agreement”, suggesting they were generated by the Internet Commerce Association’s semi-automated outrage tool.
It’s a lot, but it’s dwarfed by seemingly non-ICA submissions, which will make the opposition to the deal harder to ignore than with last year’s .org deal, where many of the 3,000 comments were written off as “akin to spam”.
.com’s wholesale fee has been frozen at $7.85 per year since 2012, but Verisign managed to persuade the Trump administration in 2018 to allow it to return to the old policy of being able to raise prices by 7% in four out of the contract’s six years.
After a year’s negotiation, ICANN agreed to incorporate that change into its Registry Agreement with Verisign. Some commentators, including the Registrars Stakeholder Group, are now saying that ICANN should put contracts out to comment BEFORE they are negotiated.
The RrSG said of price increases:

The RrSG is concerned that the proposed price increases are without sufficient justification or an analysis of its potentially substantial impact on the DNS. ICANN has not explained how increase domain name prices are in the public interest or how this furthers the security and stability of the DNS. The price increases appear only to benefit one company, which has the right to operate .com in perpetuity (and without a competitive bidding process). This is inconsistent with ICANN’s bottom-up multi-stakeholder model.

It’s also understandably pissed off that Verisign is to get the right to own its own registrar for the first time, which could shake up the retail domain market.
While the proposed contract does not allow the hypothetical Verisign registrar to sell .com domains, the registrars think they’ve spotted a loophole:

nothing in the amendment prevents Verisign from reselling .COM domains via another registrar. In theory, Verisign could resell .COM domain names at or below cost and still profit from the wholesale .COM price

Some registrars submitted separate comments that echoed the RrSG collective view.
GoDaddy commented that there should be an economic study on the potential impact of higher pricing on competition before any increases are allowed to go into effect, adding:

GoDaddy believes that ICANN has agreed to a framework for wholesale price increases in .COM that will negatively impact current and future registrants of .COM domain names, as well as the overall domain name industry, which is disproportionately dependent and impacted by changes in .COM pricing. We are further concerned that there is no effective competition to assist in establishing what is a reasonable price for .COM.

Namecheap, which has also been vocal in fighting .org price increases, noted that .com prices could go up by as much as 70% over the next decade, due to the compound impact of annual 7% rises, adding:

The .com registry is well-established, so due to gained efficiencies, the cost of .com domain names should remain static or go down. It is not clear how much registrars will pass these price increases along to consumers, but it is likely that most of this increase will be paid for by domain name registrants.

Drop-catch specialist TurnCommerce/NameBright called for .com to be put out for competitive bidding:

There is simply no legitimate argument that competition for registry contracts—especially the largest registry contract—is bad for the domain name system or for consumers. Without the prospect of competitive pressure, Verisign has no incentive to be efficient, innovative, and effective. In the time that Verisign has operated the registry, prices have increased, we believe innovation has stalled, while Verisign’s operating costs have apparently declined.

As far as I can tell, the Registries Stakeholder Group, of which Verisign is a member, did not submit a comment. But some other constituencies did.
The Business Constituency generally supports ICANN’s somewhat hands-off approach to price regulation, but it did complain that there should have been a public consultation before the bilateral contract talks began a year ago. It wrote:

The BC has no practical objection to price increases that average just 4.5% per year for businesses who register .COM domains. Some BC members are concerned that Verisign has not provided justification for increasing .COM prices, though we are not aware of any requirement for gTLD operators to provide such justification. And while some BC members would prefer that ICANN seek competitive bids to operate existing registries, the BC has generally supported presumptive renewal performance incentives in registry agreements.

If you’re picking up hints of internal BC dissent in that comment, it’s almost certainly because BC member Zak Muscovitch is also general counsel of the ICA and was one of several contributors to its drafting.
The only other formal GNSO stakeholder group to submit a comment appears to be the Intellectual Property Constituency, but it took no position on pricing.
The At-Large Advisory Committee, which according to its web site “acts on the interests of Internet users”, sent a borderline humorous “Valentine” to the ICANN board that does not mention pricing but does congratulate ICANN on securing a $20 million Verisign bung, which is earmarked for DNS security work.
Here’s a sample of 10 public comments I clicked on randomly:

I’m writing to express disappointment and concern regarding the recent ICANN changes made to their contract with Verisign. These changes potentially create a lot of harm and unnecessary expense to customers for years to come. Please take customers into consideration before going forward with this.

Please don’t increase .com prices. As a small business owner we feel every price increase in our family business. We want to be able to keep the domain name that we have spent years building as our small business home on the web.

I’m here to tell you to stop this proposed price increase. You are being greedy. 40% price hikes with no caps in sight are ridiculous, stop it. I’m tired of getting ripped off by big secretive corporations and sleazy government agencies, and now this includes YOU!. We aren’t going to just put up with it, I, and a lot of others are here to fight! We demand to know
what you are doing with the money you propose to reap from us, aside from lining your pockets! Proveme wrong, give the internet community the clarity it deserves, and now demands!

This is a disgrace and not right.

I disagree with the changes that this amendment (3) will make to the domain registry system. I believe that this increase of fees will stifle innovation and takes the web further towards privatization and big money.
I know that I would not have taken as many opportunities or risks if prices were significantly higher and domains were a larger cost of business.
I urge you to reconsider these changes and reject this amendment.

I am writing in opposition to the proposed Verisign deal with respect to .com domains. I believe the current arrangement should be kept and strict price controls from ICANN should be preserved for .com domains. Verisign has no business exerting control or influence over ICANN, and the deal as proposed will be bad for consumers and anyone who holds a .com domain.
Please do not proceed with the proposed changes.

Please stop trying to fuck up the internet. It has been excessively adapted to suit capitalism. I think many more than just me have had enough. Stop being a shady ass business.

I do not agree with the extraordinary increase in prices for .com domains that appears to be a direct response to a bribe paid by Verisign company to the board of ICANN.
We live in perilous times, where democracy is threatened in every side by the resurgence of corruption, cronyism, and the far right.
You appear to be allowing the backbone of the internet become corrupted by greed, which would horrify the founding fathers of this essential technology.
Show some integrity and don’t give in to the basest of your natures.

I am a registrant of more .com domain names. I am against the proposed price increase to .COM domains. Verisign is merely your manager of the .COM Registry – it has no business dictating the price. ICANN is supposed to govern the domain name system in the public interest.

Thanks first for your hard work.
Please keep prices as they are and avoid this change that could have dire consequences for the entire internet as other less democratic countries will start soon offering alternative domains to .com. Furthermore, any increase will cause difficulties for us who are part of the third world.

If you’ve got more time on your hands than I have, you can peruse all 9,000 comments at your leisure over here. If you find anything good, please do drop a link in the comments.
Some poor bastard at ICANN now has the job of going through and summarizing all of them into ICANN’s official comment report, which has a March 6 deadline.