Re: .xxx - ICM agreement:

[Choice Web Support <choicewebhost@xxxxxxxxxx>]

We have previously commented on the .xxx proposal, the last time
it was up for review. My previous opinions remain unchanged,
however, we are now to understand that ICM is deceptively
misrepresenting the views of the adult online community. 

Make no mistake, an overwhelming majority of adult website
owners and operators are opposed to .xxx. I would go so far as
to say that, if they are properly informed about it, nearly 100%
would be opposed. 

This proposal is ill thought out, and is being deceptively and
duplicitously marketed to opposing camps. The adult industry is
being told that the .xxx domain is completely voluntary and
adult content will never be restricted to .xxx domains. Yet, in
the same breath, ICM is telling those opposed to pornography
that the .xxx domain will help to ensure that adult content is
limited to this domain. Clearly those two thoughts are
diametrically opposed. 

ICM's goal cannot be anything other than to monopolize control
of adult content on the Internet, which would certainly be in
their best financial interests. Yet, since ICANN is charged with
regulating the Net with the best interests of all in mind,
approval of .xxx cannot possibly be viewed as supportive of that
mandate. For one thing, ICANN's .tld policy requires that
specialty domains be created only if there is strong support for
them. There is no such support for .xxx from the adult industry.


ICM deceptively rolled out a "preregistration" page in which
adult webmasters could "pre reserve" .xxx adult domains, "in the
event the .xxx domain was approved." Any savvy webmaster or
adult company would therefore place a reservation on names they
already use, simply as insurance in case the domain was, in fact
approved. 

This should IN NO WAY be construed as support for the .xxx
domain; if Coca Cola or General Motors or Amazon were suddenly
told that a new tld was being considered, and that, if approved,
they might be forced to change from their well-branded .com tld
to another tld, you can be assured that those companies would
preemptively reserve those domains simply as a business
precaution. But if you asked those companies if they wished to
switch, it would be clear that they wished to retain their
current, branded websites in the .com namespace.  

Another paradox: It would likely be a violation of free speech
in the US and elsewhere to force adult content into the .xxx
domain, and ICM argues out of one side of its mouth that it will
always be voluntary. Yet forcing adult content to use .xxx is
the only possible valid reason for approving the domain; absent
the ability to block adult content using the .xxx tld as the
blocking criteria, there would be no valid reason to create it,
as there is plenty of namespace for adult content within the
current .tld naming structures, and it would simply be a new and
unnecessary TLD. 

This also does not address the exceedingly complex issue of
what, exactly, constitutes adult content, and would therefore
fall under .xxx if use of the .xxx did become mandatory. Would a
blog making a passing reference to adult content and posting a
single sexually explicit image be subject? If not, how many
images would subject a blog to .xxx? Would language alone make a
site required to post under .xxx? What about mixed-content
sites, such as video rental or VOD sites containing commercial,
nonadult as well as adult content? What about artwork that could
fit the definition of sexually explicit? 

These issues are already thorny in the bricks-and-mortar world,
and pose far more questions (along with a myriad of mixed
answers, due to differing laws and customs in different
countries) in the online world. 

In short, approving the .xxx domain would be a disaster. It
presents serious free speech challenges, it is not wanted by the
industry it is supposedly being created for, it does not solve
the problem of limiting access to pornography, and it serves no
purpose whatsoever except to enrich the pockets of the owners of
ICM registry. 

I sincerely hope that ICANN will continue to make the correct
decision and permanently and irrevocably close the door on this
unwanted, unneeded, and disastrously bad proposal. 


Chip White
VP
Media Resource Communications, Inc