No point with .XXX

["Skin Marketing" <info@xxxxxxxxxxxxxxxxx>]

Comment regarding the .xxx tld from concerned members of the adult
entertainment industry.

We and many of our colleges fear that creating a tld for porn is a very
negative development. We see no need for new domains, the market is already
saturated. So if there is no need for domains, why create a new tld? 

The ICM registry states that "the Benefits of the .xxx TLD" are:

"For willing adult consumers of adult entertainment, the Best Business
Practices incorporated into the .xxx registration agreement will bring a
greater degree of confidence and certainty to their online experience."

All serious parties in the adult entertainment business already adhere to
the practices named. Besides those few who don't will find ways to
circumvent the policy, they could easily put compliant sites on the xxx tld
that link to non compliant sites on other tlds, it would be impossible to
check all sites/links.

"For adult entertainment providers, identifying themselves as compliant with
a comprehensive set of Best Business Practices is expected to provide more
predictable revenue streams, greater customer retention and fewer complaints
as regulators and others will see adult entertainment providers take a
proactive and responsible approach to their web presence."

There is no base for this statement, the problems the adult industry has
today relate more to issues with billing and content. The consumers are
already accustomed to buying porn on regular tlds, why would they know about
or care about the Best Business Practices of the ICM Registry. The day the
adult entertainment industry get fewer complaints from regulators will be
the day hell freezes. There will always be people that oppose porn and they
will always put pressure on regulators to ban it.

"For individuals or families wishing to avoid adult content, the machine-
readable labels will allow easy and reliable filtering."

And they won't still be able to see the millions of domains not on the xxx
tld? There are several filtering services already available that will do a
better job. The xxx tld won't be as attractive as keeping the current
domains since the xxx tld will probably be filtered by many ISPs and
countries.
We have heard a lot of comments about protecting the children from adult
sites, but in order to protect children from adult sites you would have to
limit all of them to the xxx tld and that would be a violation of freedom of
speech in most countries and cause a lot of damage to the adult
entertainment industry. Thou we think there is a real need to protect
children from adult sites, we insist there are better solutions. 

"In addition, the introduction of .xxx creates a credible, self-regulated
forum for all stakeholders to discuss and actively respond to concerns about
online adult entertainment."

No, that could only be achieved if all adult entertainment companies worked
together to provide a forum, but it will not be the .xxx tld because they
don't have the support of the majority of the adult entertainment business
and don't adhere to the concerns we have. 


If you release this tld then there will be a lot more adult sites created by
the people that already have a lot of adult sites. There will be no added
value to the internet users because all the sites will just be the same
types as the current adult sites. The only parties that stand to win are the
ICM Registry and International Foundation for Online Responsibility.

Sincerely,
Skin Marketing - owner of 50+ adult entertainment domain names
Cyber Avatar - owner of 500+ adult entertainment domain names