*****NO TO THE XXX sTLD*****

["Tickler" <tickler@xxxxxxxxx>]

First off: NO TO XXX sTLD!!!!!!!!

I have been a member of the adult community for 12+ years, and this TLD does
nothing for the community, is an outright money grab, and will cause major
damage to the very community that it is supposed to serve.



1. ICM does not have community support. A quick check of their supporters
indicates that most are domain squatters, and this was also indicated by
Diane Duke at your last meeting.

ICM's convoluted avaricious language is nothing more than smoke & mirrors to
disguise the fact that they are trying to redefine the "sponsored community"
to be only those that support them, and not the adult community that is
affected by XXX.

Even the GAC's report indicates that ICM is trying to redefine the
"sponsoring" community through "self-selection" to only include those that
support ICMs XXX sTLD application.


Additionally, when Kieren McCarthy prepared the "Executive Summary" for ICM
that was posted in the last comment period he indicated the separation
between the "sponsoring community", and the actual "affected" general adult
community that ICM is trying to ignore, When I questioned Kieren on why he
separated the adult industry from the "sponsoring community" the response
was that ICM was basically ignoring the adult community.

Kieren McCarthy: "ICM's argument, I believe, is that dot-xx is not intended
to be for the whole adult industry but only those that want to sign up to
it."
http://kierenmccarthy.com/2010/05/18/summaryanalysis-of-dot-xxx-issue/


There is also a wealth of information in Diane Dukes submission to ICANN,
and the comment by Diane sums up a major problem with ICM and the sponsoring
community. - "ICM's new definition of sponsorship community"
http://www.icann.org/correspondence/duke-to-jeffrey-08sep10-en.pdf


The adult community is the one most affected by XXX, and ICM is refusing to
even acknowledge that the adult community is the rightful "sponsoring
community".


ICM has failed to provide any actual data that ICM has the support of the
adult community which is the REAL "sponsoring community" that is most
directly affected.



2. ICM denies that XXX would create a ghetto for adult content online. They
try to paint it in terms like a luxury resort, or a high end shopping mall.

The reality with the current censorship push worldwide(i.e.. Australian
firewall, etc.) this over-priced real estate will easily end of behind
massive router walls where
adult consumers will not be able to even access it making XXX domains
worthless.

Again the GAC report highlights that there is significant risk with the XXX
sTLD for the adult community.
 - "frightening prospect of a great many nation states acting (in light of
their own public interest concerns) to direct their ISP communities to block
this domain"




3. The GAC also brings up the use of "inflammatory" phases in the TLD. If
ICANN permits ICM to proceed without the sponsorship of the actual adult
community, it will set a precedent that will allow anybody to define the
"sponsoring community" as only their own supporters opening the way for
1000s of inflammatory TLDs. This will in turn permit them to extort hundreds
of millions of dollars from the internet economy, and create massive chaos
in the domain dispute arenas.



4. ICM has stated that XXX will help to "protect the children" which is just
blatant propaganda. XXX will in fact make it easier for children to find. If
they are basing this on the use of blocking technology you only have to look
at Australia where it took a kid only minutes to bypass filters.



5. Additionally, the whole issue with IFFOR has many, many problems.

a) Suggesting that the industry is not "responsible" is irresponsible by
itself. The adult industry is vastly outnumbers by mainstream industries
regarding virus spreading, online phishing, identity thefts, and credit
cards schemes.

b) IFFOR was only created, and financed by ICM just to create the impression
that they had the support of an adult industry organization in their bid for
a sTLD.

c) If IFFOR is not run by the adult industry itself, then who decides what
is good for the adult industry? Even governments around the world can not
create a common definition of what is adult content.

d) The entire domain resolution system that ICM has proposed, is only
defined in extremely general terms, and even then does not compute.

e) Adult webmasters currently use RTA, ICRA, and 2257 labeling, A new
labeling system is not needed.

d) A casual review of some of the domain squatters who support ICM reveals
that they indulge in C*P* baiting tactics, and improper labeling contrary to
IFFORs rules.



6. There is not enough detail data in the XXX proposal to make informed
comments at this time.

a) Many more technical issues such as  need to be fleshed out.
 - domain dispute & resolution procedures
 - source of members for the IFFOR boards needs to be clarified.
 - mandates & financing.

b) There are also massive technical SEO problems associated with multiple
domains. To maintain Google ranking, a webmaster is best to redirect the XXX
ST:D to their current COM/NET/ORG TLD. If all the content is on the current
TLDs, what purpose does IFFOR have? Or are they suggesting that IFFOR should
regulate content on the COM/NET/ORG TLDs even though IFFOR should have no
jurisdiction outside the XXX TLD.




In summary ICM does not have the support of the adult industry, the FSC, or
even the GAC. Even ICMs attempt to "redefine the meaning of "sponsoring
community" to only include their supporters is basically an admission that
ICM doesn't have industry support.


Finally, as the GAC has remarked the granting of an "inflammatory" TLD
without the proper industry support will set a precedent that will certainly
be hard to quell. Rampant use of "inflammatory" TLDs designed only to ransom
money in defensive registrations would likely become the norm, and possibly
discredit ICANN to the point where it no longer remains relevant or
functioning.



So along with the FSC, and a lot of other "REAL" adult webmasters I request
the following information from ICANN/ICM.
1. Verify that companies which ICM has listed in support are viable "adult"
businesses,
2. Verify that companies listed in support in fact do support ICM's current
application for a .XXX TLD,
3. Determine how many pre-registrations claimed by ICM are in fact defensive
registrations,
4. Determine how many pre-registrations are registrars or companies hoping
to re-sell domain names.


*****NO TO THE XXX sTLD*****

Tickler