Return to tldreport Forum - Message Thread - FAQ

Username: tyrastor
Date/Time: Wed, November 15, 2000 at 5:26 AM GMT
Browser: Microsoft Internet Explorer V5.0 using Windows 98
Score: 5
Subject: .Kids Domains, Inc. Formal Rebuttal to the ICANN Staff Report

Message:
 

 
Dear Sirs or Madams:

In reply to the ICANN Staff Report of 9 November 2000, and in light of factual inaccuracies therein,  .Kids Domains, Inc. (KDI) wishes to respectfully present our rebuttal. Acknowledgement of this letter and commencement of further communication is positive proof that the application process is indeed open, transparent, accountable, and fair, and we are extremely grateful to the ICANN Board and cognizant of the magnitude of work and effort from them.

The 9 November Staff Report states: “given the difficult definitional issues inherent in a .kids TLD, together with the limitations of existing technology and the approaches suggested by these proposals, it is questionable whether these applicants would be able to meet the unmet need and provide an effective proof of concept.”

KDI has borrowed heavily from international bodies such as UNESCO and UNICEF in defining issues.  Our restricted content policy is based on laws and organizations around the world including, but not limited to: UNESCO, UNICEF, ABA (Australia), Bertelsmann Foundation(Germany), Singapore Broadcasting Authority Act, ACLU, MPAA, Euroli Council Conclusions, and the United States law.

We believe that the “limitations of existing technology” refers to electronic filtering methodology and technology.  While we expect these technologies to enhance the security of our content policy and facilitate the audits specified in our application, our reliance is based upon a private, binding contract with registrants agreeing to the content and policies in our application.  We are not proposing to be a restricted TLD by way of forbidding content.  Rather, we restrict registration to those registrants who, through private contract, agree with our policy and content.  Therefore we become a network neighborhood of like-minded groups that have contracted a desire to proceed in a common direction with common goals and common protocols.  Individuals from the IPC have provided solid feedback in support of this concept. 

The 9 November Staff Report states: “While .KIDS Domains recognizes and attempts to deal with the issue of "what content is appropriate", its proposal does not address the larger conceptual concern whether a self-appointed TLD sponsor should make these decisions.” 

Again borrowing from organizations around the world, such as UNESCO: “that there is broad international consensus that certain kinds of content, which may be appropriate for adults to access, is unsuitable for children.”  The concept of shielding or protecting our children from harmful content is not only global, but also timeless.  In fact, global concern and comment is so prevalent, that it is not a difficult task to establish common ground at the base level.  KDI has adopted this approach in establishing our Content Policy.  We have never set precedence, but rather relied on International Organizations, Foundations, Seminars, and Legal codes that are focused on Children.  KDI asserts that the “larger conceptual concern” is really whether we will make a start and address a patent and looming problem.  It is important to point out that KDI is not attempting to limit the Internet, but define a section of it as a greenspace.  Similar to a “G” movie in a world that promotes and accepts the entire range of ratings, or the FoxKids channel on the cable that features the spectrum of content.

The 9 November staff report states: “The evaluation team believes that in order to be successful in meeting unmet needs and providing an effective proof of concept of a safe online domain for children, an applicant for a .kids TLD must be able to deliver on the explicit or implicit public expectation of suitable content. At this juncture, it appears that there are no technical or other means to ensure that unsuitable material is not available to children while the applicants rely on partial measures that are not self-executing and that seem certain in execution to fall short of public expectation.”

KDI congratulates the ICANN staff report in recognizing that there are currently unmet needs of children and parents regarding the Internet.  Public expectations will absolutely be unmet should ICANN decide not to issue a .kids TLD.  In the short period of time that has elapsed since the staff report was published, KDI has received support and request for establishment of a .kids TLD from over two hundred individuals around the world.  It is significant to us that every individual or organization that has engaged us in discussion has come along side us and agreed with our goal and the urgent need for a .kids TLD.  We feel confident that our experience with children and children’s welfare organizations, our partners, and supporting organizations (I-Safe, KidsSearch, StudentCashCard, Yosemite Sierra Summer Camp, Amazing Kids) are at least as competent at judging public expectations and public needs as ICANN, a self-defined technical body.

We agree wholeheartedly with the Bertelsmann Foundation that “More people will migrate online when they are confident that their families will not be exposed to harmful content” and we urge ICANN to act positively to establish something for kids.

Respectfully submitted,

H. Page Howe
Chairman
.Kids Domains, Inc.
    
     

 


Message Thread:


Privacy Policy | Terms of Service | Cookies Policy