No .XXX
To Whom It May Conern: As the primary creator, owner, operator and editor of several large, free adult directories, including Booble.com and SirRodney.com, I have been in the online adult industry since January, 2003. As the primary editor of 2,000 + sites in the Sir Rodney directory, I have personally visited the members areas of thousands of sites, which argueably makes me one of the world's leading experts in online pornography. I have been following the debate over .xxx for some time, and appreciate this opportunity for my voice to be heard in the process. The proposed .xxx domain will not protect children and families and will instead erode intellectual property rights, free speech and privacy. It will drive the adult business underground, and overseas, making it less safe, not more safe, for consumers. The result will a loss of jobs and tax revenues, as the business flees to more hospitable jurisdictions. To elaborate: 1) I am here to tell you I have never seen a hint of pornography involving children, ever. Child pornographers operate in a dark netherworld far from the adult industry. By all accounts, they work Google and chat rooms on sites like AOL. They do not work in the adult industry. I always laugh when people say they stumbled upon it "by accident". Impossible. Unless you believe someone could type "child porn" into Google by accident. The adult industry is doing an unassailably great job of policing itself through the ASCAP guidelines. How good a job are the major search engines doing? Is there a provision for regulating them, because they point to more pornography than anyone else online. Also, any one with a teenage boy will tell you that .xxx will create a virtual red light district that will attract minors, not keep them out. .XXX is one of those notions that makes for good tv news sound bytes, but is in actuality a total disaster for both businesses and consumers. 2) There is no provision to ensure that long time owners of .com domains will be able to protect and transfer those domains. Instead there is a provision for grievances that will be an administrative nightmare. 3) Governments would be able to suppress free speech on the grounds of "protecting children". 4) .XXX will spur adult businesses to re-locate to Eastern Europe and Central America, taking jobs and taxes with them to jurisdictions where they do not have to comply with existing laws. 5) Finally, who is to say which sites should be .xxx and which are ok to continue to operate as .com. Sir Rodney, for example, is largely text. There is no nudity whatsoever on the site. We do review and link to adult sites, just like Google and Yahoo. Would they be required to operate as a .xxx? Who is "the decider"? This seems to us a system built for exploitation and corruption and influence, not one that creates a fair regulatory environment. .xxx is not in the public interest. It will be unmanageable, create a political football, impinge free speech, while failing to protect the most vulnerable among us. For these reasons, I oppose .xxx, and urge you to reject it. Sincerely, Emil A |