Do Not Approve .XXX

[Raffaele Manzo <raffaele.manzo@xxxxxxxxx>]

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.

Regards,

Raffaele Manzo