re: Proposed ICM Registry Agreement for .XXX

["John Foulds" <jayeff@xxxxxxxxxxxxxxxx>]

Sirs

This issue should have been closed long ago, as nothing more than a cynical 
attempt by members of a commercial concern to make large profits from something 
which is of no benefit to anyone but themselves. I am surprised and dismayed 
that ICANN is allowing itself to be manipulated in this way.

I believe that the vast majority of adult-industry webmasters would be happy to 
adopt an effective way to exclude minors from our sites. Many of us are 
parents, sharing the same views as much of the general public and from a 
business perspective, minors who visit our sites are pure expense. Consequently 
thousands of sites have already adopted voluntary filtering labels such as 
those provided by ICRA, ASCAP and others. That there are several long-standing, 
well-reputed filtering options, leads to the inevitable conclusion that any 
limitation in the effectiveness of filtering is not due to the lack of filters, 
but to the unwillingness of parents and institutions to apply those filters to 
the browsers their children use. There is neither evidence nor logical reason 
to make one believe that the addition of a further filtering method is going to 
change the broad picture. On the contrary, if the ease of identifying an .XXX 
domain has any impact at all, it must surely be the opposite of what is 
intended. Minors will be able to locate adult content even more readily than is 
now the case.

I do not believe for one second that ICM has the slightest interest in the 
welfare of minors or anyone else. They are motivated entirely by the belief 
that most adult-industry webmasters will feel they have little choice but to 
protect their existing internet presence by registering the .XXX version of 
their domain(s), should that TLD be created. The essentially captive nature of 
ICM's intended market is surely the reason for the extortionate price they are 
proposing to put on these domains.

Finally I do not believe it is appropriate for so much real and potential 
control over such a controversial internet sector to be put into commercial 
hands at all. Even if this were to happen at some point, it should only be with 
sufficient oversight to ensure that the primary goal of the organisation is 
indeed to protect the wider public interest. I do not believe that ICM is an 
organisation which has adequate reputation or history to be trusted with this 
role, nor - so far as I am aware - does ICANN have the authority to provide the 
necessary oversight.

In summary, were ICANN to grant this TLD, it would be opening the door to 
abuse, rather than providing solutions. I am confident that is not what any of 
the board members would want.

Yours faithfully
John Foulds