Do Not Approve .XXX

[Kirsten Harrison <kirstenmichelle@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,

Kirsten M. Harrison