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  • To: <xxx-revised-icm-agreement@xxxxxxxxx>
  • Subject:
  • From: Brittney Abernathy <brit_1565@xxxxxxxxxxx>
  • Date: Mon, 30 Aug 2010 07:36:26 +0000

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 .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), thought 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.

* The .xxx TLD will do nothing to solve problems surrounding adult 
content, manage adult content or protect children from inappropriate 
content. The higher purposes of ICM’s proposal have been abandoned. (As 
of this email the page on ICM Registry’s website about “Promoting Online
 Responsibility” for .XXX is blank and reads “Information to follow” as 
does the page titled “Contracts, Policies and Bylaws.”)

* There has been absolutely no proof of an “unmet need” for the .XXX TLD.

* There is no concrete, agreed-upon definition of “adult content.”

* The ACLU expresses serious concerns about the implications of .XXX 
outside the U.S., where in some countries, regulations around .XXX would
 certainly be enforced punitively. To this effect, the .XXX TLD raises 
human rights concerns.

* .XXX makes no business sense except to profit from defensive registration 
(brand squatting).

* 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.”

* .XXX raises serious issues around spurious and unsupported TLD’s in
 regard to the impact of ICANN on rulings on civil and human rights, and
 ICANN’s role in content-based discrimination.

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




                                          


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