Thank you for commenting on our proposal. You raise concerns that
are important we address.
Please find my comments enclosed below:
"I think the difficulties arise for most people when they realize you'll be going
with NSI. Plain and simple, NSI has had a monopoly for too long, regardless
of how long they've been "established players" in the industry. The whole point
of new TLD's is to diversify. I think it's been mentioned before but have you
considered simply dropping the proposal for .KIDS? If you simply had a .XXX
proposal and decided to team up with another company that had .KIDS it would probably
be a lot easier for people to swallow what you're giving them."
Our application to ICANN is for the ".xxx" TLD. While we are proposing to operate
".kids" as a non-for-profit service, we are flexible to work with the other ".kids"
proposals. However, I can't see it being too difficult for the greater Internet
community to swallow a completely non-profit registry proposal.
"Why are you doing that? It's quite a generous gesture to donate $6.00 to the
creation of a non-proift .KIDS TLD but why wouldn't you simply agree to working in
colaboration with another company that would be able to manage the .KIDS TLD?
It seems a bit selfish to want both .XXX and .KIDS, esepcially when you've decided
to have both under NSI."
ICM REGISTRY: If you got Volume 3 - ICM Registry
Description of TLD Policies Section E2 it reads as follows:
"Upon information and
belief, there may be multiple third party submissions for a green space top level
domain for children. In such a scenario, ICM Registry is willing to work with these
entities to financially fund their operation or provide the necessary technical support.
If ICANN rejects ICM REGISTRY Registry’s effort to operate or financially sponsor
a .KIDS registry (or related green space), then ICM REGISTRY will donate the money
ear marked for these efforts to an acceptable non-profit organization. In the alternative,
the money can be set aside in a trust fund until a future non-profit organization
In response to your second comment, we are not using Verisign
to operate ".xxx" we are using The .TV Corporation International. The reason
we offered to run both the ".kids" and the ".xxx" registry originally is because
ICM REGISTRY believes that in order to protect children from adult content, you must
operate both a red-light district and green-light district in tandem.
our proposal $6 per ".xxx" domain goes to charity and 100% of every dollar save and
accept the $6 NSI registry's fee goes to charity...how is that selfish? Are
any of the other proposals more generous?
Hedeer: Again, this is only a question.
Have you created a model that would transport the existing adult-oriented sites over
to your .XXX over some period of time?
ICM REGISTRY: Our model is to categorize
content, not segregate it. The model we are proposing is similar to the movie
rating system with .kids being a Rated "G" and .xxx being a "Rated "X". Part
of the reason for this approach is to protect Internet users first amendent rights
concerns. In time, it is our expectation that the adult content community will
initiate steps to enhance the functionality and benefits of this service.
"Will be able to procure software that provides more filtering capability "
you started any collaborations with a third party group to develop this software?
REGISTRY: We have begun the development of categorization technology
internally, not filtering technology. We have not yet formalized relationships
with a particular filtering group. We have been in dialogue with several prominent
DNS and filtering technology development companies like for example i-DNS and other
leading filtering companies over the past few weeks.
Hedeer: "ICM Registry
strongly believes that the .XXX TLD is the strongest potential candidate on both
issues[succesful both a financial and broad consumer support], because of the high
degree of adult content Internet traffic. "
I agree with this wholeheartedly.
Your application demonstrates very thoroughly your ability to handle the .XXX TLD.
I'm quite impressed with how much you've thought it through.
We appreciate your support.
Hedeer: Can you name a few of the groups you're
working with? I'm simply curious.
ICM REGISTRY: igallery, Enough
is Enough are the first two significant relationships...others will be announced
over the next few weeks. When you consider the short amount of time ICANN offered
applicants to submit proposals and the complexity of our particular proposal, as
you can imagine, it is dangerous to show support prematurely.
Hedeer: I hate
to be a cynic, but it seems you've given far too much attention to the .XXX TLD and
not enough to the .KIDS TLD. Under this plan, all your revenue comes from the
.XXX TLD and in simplest terms what would motivate an efficient .KIDS TLD if not
a profit? And how do you plan to subsidze the .KIDS TLD? I don't think
the $6 donation per .XXX site is enough of a donation. Doesn't this in some
way limit the growth of the .KIDS TLD?
1. Our proposal
is for ".xxx". We have only offered to run ".kids" as a non-profit separate company.
Under our proposal ".kids" will be charging registrants per domain name fees per
".kids" registration. That revenue will be more than enough to operate the
service especially under our auction model scenario.
3. I am confident
that the structure we have proposed is one of the strongest and most reliable proposals
for the operation of ".kids". In addition, our proposal ensures that the company
is operated fairly and professionally by strong third party management and the broader
Hedeer: Wouldn't it again make more sense to leave
the actual managment, subsidization, and basically whole game plan of the .KIDS TLD
to another company which would then work in cooperation with you to provide a safer
So to summarize, I like the .XXX TLD. I really think
you've brought up a very telling point with concern to adult industry and internet
content. I don't think .KIDS and .XXX can work together the way you've planned
to manage both, especially having NSI as a not so reputable registar. I like
the auctioning system you've developed and the effort you've put into protecting
intellectual rights, basically I like your Registructure system. My advice
to you would be to let go of the .KIDS, hold on to .XXX. Your proposal as is
can really very easily be accepted as a .XXX proposal and I think ultimately should
ICM REGISTRY: Thank you Hedeer for your comments. ICM REGISTRY
continues to be open to developing relationships with the other ".kids" proposals.
So long as ".kids" can effectively support our goal of protecting children online
without damaging the delicate balance we have developed between: first amendment
rights organizations; the trademark community and the child advocacy groups, we would
be pleased to explore creatively working together.