Reposting of FSC Letter

["Tom Hymes" <tom@xxxxxxxx>]

Dear ICANN Board,
 
I am the Executive Director of the Free Speech Coalition, the trade
association for the adult entertainment industry. I would like to
reiterate that the Free Speech Coalition is categorically opposed to
.XXX sTLD. To put it simply, XXX is a very bad idea because it would
make the industry an easy target for anti-industry extremists and
government intrusion. It will also add unnecessarily to the cost of
doing business.  At $60 per URL per year, the cost to a member could
reach tens of thousands of dollars annually. Many in the adult
entertainment industry will purchase and park addresses, realizing no
benefit to this added expense. Finally, there will be countless battles
for names, and the resulting arbitration will be costly. 
 
If .XXX becomes a reality, it is likely that the United States and other
countries will try to make it mandatory and subject to trans-Internet
filtering that could effectively eliminate much of the adult content
currently available on the Web. The .XXX option could enable the
industry's enemies to convert even voluntary .XXX domain use into an
effectively mandatory requirement by pressuring private parties, such as
credit card processors, to require .XXX use and compliance. In this way,
ICM, through unchecked rule making, could "back door" all the
governmental regulations that we have beaten back. If that happens the
industry would not have its most potent weapon, the First Amendment, to
challenge ICM, because ICM is not a governmental entity.
 
The ambiguity with which ICM plans to establish its governing board is
also of grave concern, as there exists strong potential for censorship,
which is clearly not in the best interest of the industry or ICANN. 
 
We urge you to reject ICM's proposal for .XXX sTLD and put this issue to
rest once and for all.
 
Sincerely,
 
Diane Duke
Executive Director
Free Speech Coalition
 
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