Thank you for taking the time to review
and comment on our proposal. Please find my comments enclosed below.
Lassre: Hello to you at ICM Registry,
There is no way that pornographic
material and children should be connected at all.
ICM REGISTRY: I
agree. Our proposal suggests that there should be no connection between the
two Top-Level Domain names.
Steven Lassre: By viewing what I have of your
application I can see that you look to fund the children safe zone by creating a
ICM REGISTRY: Initially we had planned to create
a separate non-profit company to operate ".kids". Verisign Global Registry
Services would operate that registry. We proposed that revenue from ".xxx"
would go to this separate non-profit charity company. Our goal continues to
be to allocate these funds in order to:
1. facilitate the development of
new technology to protect children from adult-oriented content.
children and parents online.
3. support the protecting of children and parents
In light of the other proposals for ".kids" we continue to evaluate the
best strategy to distribute this capital in order to realize our goals.
Lassre: It also appears that in an effort to create places safe for kids that
you suggest we create a place not for kids. How will children then not be allowed
to view this unsafe space.
ICM REGISTRY: Our service will make it
more difficult for children to view these websites because:
with the ".xxx" extension are easier to filter with traditional filtering technology
".xxx" websites will provide the appropriate measures to restrict access by minors
to adult websites.
3. Search engines will be able to better manage
adult content search results.
4. ICM Registry will invest capital to
develop more comprehensive filtering technology solutions.
5. ICM Registry
will contribute a significant proportion of revenue towards educational programs
for children and adults intended to inhibit children from going to these websites.
Lassre: How will this answer the dilemma of child-safe space. All it
seems we are doing is creating more of the non-desired pornography space under the
influence that all "adult" website operators will go there.
".KIDS" related domain names will provide access to content that is approved and
deemed acceptable to children. The structure of determining criteria for both
extensions will be determined by a policy advisory board that best represents the
broader Internet community in an open and transparent manner.
By giving websites
a rating (similar to G-rated or X-rated) you are in a position to advise the Internet
user what they're getting into...our service is the first step towards categorizing,
not segregating this type of content.
Steven Lassre: What makes you
think that Tradmarked Companies will want to obtain this adult space other than keeping
it out of the hands of people who wish to capitalize on these same companies good
ICM REGISTRY: Michael Palage, one of the founders of ICM Registry,
was the Chairman of Working Group "B". After extensive discussions with the
trademark community we are offering the following solution:
Registry has created a blacklisting service for all trademark holders at a nominal
one-time cost recovery fee.
2. ICM Registry will undertake at
no cost, free screening to notify trademark holders of potential infringing uses.
ICM Registry will be adopting Uniform Dispute Resolution Policy for disputes.
Lassre: While I am all for the seperation of Children and Pornography
I cannot see your solution as an answer.
ICM REGISTRY: Steven...the concept
is to offer a red-light district...our goal is to protect children from adult content.
The best way to do that is to first categorize. Once we have labeled it we
can begin to manage it and protect children from accessing it.
You can find
out more about our policy strategy in the document titled "Volume 3 - ICM Registry
Description of TLD Policies." on our website at www.icmregistry.com.
I would appreciate
any comments or recommendation you may have to enhance our submission in order for
us to best realize our goal of protecting children online.