The .XXX sTLD will amplify, not resolve, problems

["Jimmy Brokaw" <hedgie@xxxxxxxxxx>]

Dear ICANN,

This email is a comment in opposition to the Proposed Registry Agreement for
the .xxx sTLD by ICM Registry. The .xxx sTLD should be rejected in finality
for the following reasons:

* The creation of a .xxx sTLD will not segregate adult content.  On creation
of a .xxx sTLD, most filters will be immediately updated to block all .xxx
traffic.  Entire countries are likely to impose such a block.  This will
create a strong incentive for adult content to be created outside the .xxx
sTLD.  While individual countries may pass laws requiring adult content to be
placed on the .xxx sTLD, others will refuse to do so or fail to enforce them.

* The .xxx TLD is opposed by every sector and community it affects. This
includes people working in the adult entertainment industry (including
Hustler, Vivid, Penthouse, XBIZ, porn’s Free Speech Coalition, and Adult
Friend Finder), anti-porn family and religious organizations (including The
Family Research Council), leaders in the technology sector, and the ACLU.

* Despite ICM’s constant assurances of various industry representation and
support, there is no evidence of community support for .XXX.

* There is no concrete, agreed-upon definition of “adult content.”  Further,
the definition clearly varies from culture to culture.  Common "men's
magazines" such as Maxim are banned as pornography in countries such as Saudi
Arabia.  The creation of a .xxx sTLD will only result in endless debates about
whether particular content is appropriate on .xxx or other sTLDs.  For
example, should information on family planning and STD prevention be placed on
the .xxx TLD?  Depending on the cultural background of the person you ask, it
may or may not.

* Senators Max Baucus (D-MT) and Mark Pryor (D-AR) have introduced legislation
to make the use of .XXX compulsory for all web sites that are “harmful to
minors.”  Such a definition is extremely vague, and risks moving this debate
out of the Internet and into courtrooms, which are ill-equipped for the
discussion and unlikely to make wise decisions.

In light of the above, I object to .XXX and urge ICANN to reject .XXX.

Regards,

James Brokaw