Public Comment on .XXX sTLD

[Barry Shein <bzs@xxxxxxxxxxxxx>]

"XXX" is the ISO4217 code for "no currency" which seems to be at the
heart of this issue [1].

If the board were to take this .XXX process up afresh today at best it
would be added to the pile of other gTLD registration interest and
would proceed in due course according to the common gTLD time line and
criteria.

One problem I see is that "XXX" in the American and no doubt other
colloquial usage refers only to extreme forms of sexually explicit
material.

Without even beginning to belabor what that might mean I am fairly
certain that people voicing concern for what children experience on
the internet are multiple categories away from where XXX is generally
considered to begin.

The United States' MPAA movie rating system [2], like many other
nations', uses several shades of categorization starting at G for the
most innocuous, then PG, PG-13, R for restricted -- under 17 with a
parent only, NC-17 -- no one under 17.

NC-17 replaced the previous US "X" rating but you still see theaters
self-labelling films "X" or even "XXX" in advertising to set the
public's expectations.

Romania has a rating of I.M.-18XXX for films with adult content. It
was the only I could find which actually used "XXX" in their official
rating system.

Many countries have film rating systems similar to one another often
with ages worked into the codes such as South Africa's G, PG, 10M, 10,
13, 16, R18, X18 where the numbers all refer to minimum ages.

Most such film rating systems cover more than just sexual content and
will move a film up the scale for violence, illegal drug use, and/or
profanity. Smoking is fast becoming a criteria.

Not only do such systems concern themselves with sexual content but
also with violence and other potentially objectionable content. On the
internet it is easy to find sites which present images of extreme
violence with little or no sexual content. Beheadings are an example
which can be described in a single word.

Most likely, and we can only guess, people who want to limit access to
sexual content for themselves and/or their children probably wish the
same restrictions for videos of beheadings and similar.

The news has recently been filled with reports of fatwas and even
alleged assassination attempts against a Dutch cartoonist who is
accused of portraying the prophet Mohammed disrespectfully. Does
material such as that also belong in .XXX? Shall we add religious or
culturally objectionable to the lists? Where do all those ethnic slurs
belong?

One could work their way down this list of potentially objectionable
material and then for each category its own spectrum of
objectionability but I think the point has been made that this is a
multi-dimensional issue.

Even if we could accomplish all this it would still leave us with the
cross-cultural issue: What is completely reasonable and acceptable in
one culture (e.g., western style bathing suits) might be completely
objectionable in another.

So to create just one TLD, .XXX, to deal with all these issues seems
irresponsible and poorly conceived. Particularly when it implies one
single category only for the most sexually explicit material.

Another choice might be to try to follow the lead of international
film rating systems and create several TLDs. There is some commonality
among those film rating systems. We could create .G, .PG, .PG-17,
.NC-17, .X, and .XXX and hope by some miracle the appropriate content
finds its way into each of those TLDs. I suppose it's assumed that
everything else not rated (.COM, .ORG) is intended to serve as .G?

This is prima facie unworkable, certainly unmanageable as presented.

The domain name system is not well-suited for this sort of
categorization system for a myriad of reasons.

I urge the board to reject the .XXX sTLD as presented for lack of
"currency" as ISO 4217 seems to be hinting.

And I would ask the board to leave the door open to future
re-consideration of .XXX as part of the maturing gTLD process. Perhaps
a wiser scheme to accomplish goals we can be proud of will arise, but
this isn't it.


[1] http://en.wikipedia.org/wiki/ISO_4217

[2] http://en.wikipedia.org/wiki/Movie_ratings


-- 
        -Barry Shein

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