ASACP Comments on Child Protection Provisions of Proposed .xxx TLD

["Joan Irvine" <joan@xxxxxxxxx>]

March 9, 2007

 

Internet Corporation for Assigned Names and Numbers (ICANN)

4676 Admiralty Way, Suite 330 
Marina del Rey, CA 90292-6601 

 

RE:  Child protection provisions of proposed .xxx TLD

 

 

To Whom It May Concern:

 

I am the Executive Director of the Association of Sites Advocating Child
Protection (ASACP), a 501(c)(4) non-profit social welfare organization
dedicated to eliminating child pornography from the Internet. ASACP battles
child pornography through its CP reporting hotline, organizes the efforts of
the online adult industry to combat the heinous crime of child sexual abuse,
and works to help parents prevent children from viewing age-inappropriate
material online. I have attached more detailed information about ASACP at
the end of this letter.

 

Our organization has officially been neutral on the question of whether or
not ICANN should approve ICM's proposal for a .xxx top-level domain, since
we consider either endorsement or opposition to be outside of our mission.
However, because ASACP has organized the child protection efforts of the
online adult entertainment industry for more than a decade, many of our
Sponsors, Members and associates in the industry have asked us to assess the
provisions of the proposal which specifically address child protection
issues.

 

THE .XXX PROPOSAL: CHILD PROTECTION ELEMENTS

 

The .xxx TLD proposal includes a commitment to 

 

1)      prohibit child pornography on registrant sites, and 

2)      require website labeling by registrant sites

 

1) Prohibiting child pornography

 

Child pornography operators will not register their domains under .xxx, or
any other designated TLD. These are criminals who operate outside the law,
and indeed are willing to exploit the sexual abuse of children for profit.
Regulating websites that would voluntarily register under a .xxx TLD could
not and will not impact the problem of online child pornography in any way.
To suggest otherwise demonstrates a fundamental misunderstanding of the
nature of child pornography. 

 

Observation and analysis of data from our online CP reporting hotline over a
period of years has made it apparent that real CP operators specialize in
the most heinous sexual abuse of young children, even toddlers and infants.
Such images can never be confused with legal adult entertainment, and the
criminals who deal in them do not worry about laws or regulations of any
kind. If people suggest that the online adult entertainment industry is a
source of this material, they are mistaken. 

 

On the contrary, the industry has made fighting child pornography a
priority. Adult companies already contribute hundreds of thousands of
dollars annually to help support ASACP, including the hotline effort
detailed above. ASACP and its supporters in the adult entertainment industry
will continue to do everything possible to help eliminate child pornography
from the internet. But to stop child pornographers, we must understand who
they are and how they work. 

 

2) Requiring website labeling

 

ASACP favors self-labeling by adult websites, as exemplified by the recent
launch of our RTA ("Restricted To Adults") website labeling initiative. The
RTA label is free to use, voluntary, and universally available to any
website that wishes to clearly and effectively label itself as being
inappropriate for viewing by minors. Complete information about RTA is
available at www.RTAlabel.org.

 

Adult entertainment is a business like any other. The companies who support
ASACP want to demonstrate that this is a legitimate industry with
conscientious business practices, as evidenced by years of widespread
support for ASACP. But this industry has also been repeatedly targeted and
used as a scapegoat over the years. So the people who work in Adult are
understandably very resistant to being prodded, or having their hand forced.
That's why it's so important that self-labeling be voluntary. Adult
entertainment companies founded ASACP and support us, so they are therefore
not put off by the idea of a website label created and promoted by ASACP.
Adult sites have already begun adopting the RTA. 

 

The RTA label is also simple and easy to use. From a technical standpoint,
the RTA tag is already recognized by internet filtering products and
services such as CleanInternet.com, ContentProtect, CSWeb, Cyber Sentinel,
FamiLink, FilterGate, iShield, Kidsnet (and all of BluePrint Data's other
Internet Filtering products), Net Nanny, Netsweeper, ParentalControl Bar,
ScreenShield and SurfSafely.com. ASACP is currently working with Internet
Service Providers, as well as more companies that furnish internet browsers,
filtering software, search engines and computer operating systems, to
further ensure the tag's effectiveness. 

 

We believe that adoption of RTA will become widespread among adult
entertainment websites, and that self-regulation will accomplish what new
laws and regulations can not. 

 




SUMMARY

 

No doubt, considerations unrelated to child protection will influence your
decision about whether to approve the proposed .xxx TLD. However, ASACP's
position is that the existence of a .xxx TLD will not enhance the industry's
ongoing voluntary efforts to protect children. 

 

ASACP therefore recommends that ICANN avoid taking any action based upon or
influenced by the incorrect assumption that a .xxx TLD would further help to
protect children online. 

 

Please feel free to contact me if you need more information or have any
questions.

 

Sincerely,

 

Joan E. Irvine

Executive Director

Association of Sites Advocating Child Protection

joan@xxxxxxxxx

 

 

BACKGROUND: Association of Sites Advocating Child Protection

 

MISSION

 

Founded in 1996, ASACP is a 501(c)(4) non-profit social welfare organization
dedicated to eliminating child pornography from the Internet. ASACP battles
child pornography through its CP reporting hotline, organizes the efforts of
the online adult industry to combat the heinous crime of child sexual abuse,
and works to help parents prevent children from viewing age-inappropriate
material online. More information about ASACP is available at www.asacp.org.


 

CP REPORTING HOTLINE

 

ASACP provides an online hotline for web surfers and webmasters to report
suspected child pornography. Web surfers find the hotline via search
engines, or through our many Member sites who provide links to it. ASACP's
online CP reporting hotline receives thousands of reports every month. ASACP
investigates these reports and determines the hosting, billing, IP address,
ownership, and linkage of suspected CP sites. ASACP then forwards Red Flag
reports to the appropriate government agencies and associations. These
include the FBI and the  <http://www.missingkids.com/> National Center for
Missing & Exploited Children, as well as European hotlines. We also notify
ISPs and payment processors when their hosting and billing services are
hijacked by CP operators. 

 

APPROVED MEMBER PROGRAM

 

ASACP's Approved Member program for adult sites offers a model of effective
self-regulation for the online adult industry. Approved Member sites are
required to comply with our  <http://asacp.org/CodeOfEthics.html> Code of
Ethics. These regulations ensure that Member sites neither contain nor
condone child pornography. ASACP has also established
<http://asacp.org/best_practices.php> Best Practices for the online adult
industry, which are recommended not just for adult sites, but also for
search engines, billing and hosting companies, dating sites, and others. 

 

RTA WEBSITE LABEL

 

ASACP created the RTA ("Restricted to Adults") label to better enable
parental filtering, and to demonstrate the online adult industry's
commitment to helping parents prevent children from viewing
age-inappropriate content. The RTA label is free to use, voluntary, and
universally available to any website that wishes to clearly and effectively
label itself as being inappropriate for viewing by minors. Websites that
label with RTA can be recognized by Internet browsers, filtering software,
and even operating systems as being off-limits to kids. ASACP is promoting
RTA both domestically and internationally. Complete information about RTA is
available at www.RTAlabel.org.

 

EDUCATION & OUTREACH

 

ASACP works to educate and inform its members, the online adult industry,
government policy makers, the media and the public about issues related to
child protection, illegal online activities, and the efforts of the online
adult industry to battle child sexual abuse. ASACP staff serves as a
resource for reporters, meet with government officials and staff in
Washington DC, and participate in mainstream initiatives such as the Virtual
Global Taskforce, the Financial Coalition Against Child Pornography and the
Congressional Internet Caucus Advisory Council.

 

SPONSORS & MEMBERS

 

ASACP is supported by its many Sponsors, Members and Supporters who
contribute anywhere from $50 to $25,000 annually. Adult companies also
regularly contribute advertising in trade publications and on websites,
supply us with trade show space, volunteer at ASACP events, donate design
and printing services, and help us with various special projects. These are
all examples of how the online adult entertainment industry supports ASACP
and its child protection mission.