concerns over ICM's proposed .XXX sTLD

[tibbalsc@xxxxxxxxxxxxxxxx]

September 14, 2010


Dear ICANN,


Hello! My name is Dr. Chauntelle Anne Tibbals, and I am writing to you  
to express my concern over and opposition to ICM Registry?s proposed  
.XXX sTLD.
First off, I would like to let you know that I am an assistant  
professor of Sociology at Southwestern University and a professional  
member of the adult online community ? the party most impacted by the  
ICANN Board?s decision.
I maintain a bog called Porn Valley Vantage (or PVV at  
www.pornvalleyvantage.com).  PVV is committed to the critical  
discussion of all issues impacting the adult production industry and  
the persons working therein.  PVV does not produce content or contain  
nudity or sexually explicit imagery.  It is an academically rigorous  
blog informed by my research on the adult industry and my experiences  
working with persons therein.
However, simply the willingness to discuss adult content and the adult  
production industry as culturally significant dimensions of our social  
world in a public online forum is enough induce a measure of the  
social stigma and discrimination members of the adult community  
experience on a daily basis.  For this reason, I identify my self and  
my work as part of the professional adult online community.
Here are some of the problematic issues with ICM Registry?s proposed  
.XXX sTLD as I see them ?
1. ICM Registry is attempting to insert their ?services? into a space  
that members of the adult online community already have covered.  The  
adult entertainment community already has an entity through which  
internet publishers and others can self-identify as a responsible  
global online adult entertainment community (the Free Speech Coalition  
and its code of ethics).  Why is an additional party necessary, and  
what additional ?better? services might an outside for-profit entity  
claim to offer adult entertainment community and the wider community  
of adult consumers, regulators, and the general public?
2. I have already attempted to register with ICM Registry (as a little  
experiment), but this most certainly DOES NOT mean I want a .XXX  
domain name.  In fact, outside of being curious as to what exactly the  
pre-registration process entailed, my main reason for pre-registering  
was to ensure that others did not get to my domain name first.   
Entrapping persons and businesses to pre-register in an attempt to  
protect business interests does not point to support.  I urge you all  
to consider how many pre-registrations have been submitted with this  
very same logic in mind.
3. I am concerned about who exactly is developing the regulations and  
standards for .XXX.  To my understanding, there has been a complete  
lack of transparency on the part of ICM Registry surrounding the names  
of IFFOR Board members and Policy Council members who will develop  
regulations for the .XXX sTLD.  Who are these persons, who selected  
them, and what are their qualifications?
Moreover, as I understand it, adult businesses would be required to  
agree to comply with ?IFFOR Policies and Best Practices Guidelines? in  
order to purchase a relatively pricey .XXX domain name; however these  
guidelines have yet to be created.  How possibly can people be  
expected to agree to such completely undefined terms?
Members of ICANN, I urge you to please consider these issues (and  
certainly there are many others).  If ICM Registry were to come with  
such a proposal for lawyers, construction workers, or even bloggers  
(for example), I doubt very seriously that the mechanics of the .XXX  
proposal would hold.  In fact, I feel very strongly that the main  
reason ICM Registry has offered up such an incomplete, presumptuous,  
and discriminatory proposal is directly related to the wider cultural  
marginalization of adult.  People have very mixed, often strong  
feelings about adult content and production, but this does not mean  
that this industry or its members warrant discrimination, entrapment,  
or ghettoization.  In fact, they deserve that very same protections  
and civil liberties we offer other humans and other industries.
Please help put an end to discrimination and what amounts to a  
thinly-veiled ploy to further marginalize the adult industry (and make  
a pretty penny in the meantime).

Sincerely,

Chauntelle Anne Tibbals, PhD