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Username: Hendeles
Date/Time: Tue, October 24, 2000 at 10:09 PM GMT
Browser: Microsoft Internet Explorer V5.5 using Windows 98
Score: 5
Subject: .xxx & .kids MUST work together to categorize Internet content




Thank you for commenting on our proposal.  You raise concerns that are important we address.

Please find my comments enclosed below:

Hedeer:  "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." 

ICM REGISTRY:  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. 

Hedeer:  "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 is established."

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. 

Under 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 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.

Hedeer:  "Will be able to procure software that provides more filtering capability "
Have you started any collaborations with a third party group to develop this software?

ICM 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.

ICM REGISTRY:   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.

2.  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 Internet community. 

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 internet community?

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 be.

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. 


Jason Hendeles


Link: The Internet Content Management Registry

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