I finally got around to sending ICANN my

The DOTXXX top-level domain is a bad idea for 2 reasons:

1. DOTXXX is NOT the right solution.

2. DOTXXX seriously imperils the first amendment rights of Web publishers.
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1. DOTXXX has been proposed as a way to, foremost, identify adult entertainment on the Web. While corralling and sectioning-off adult material into a broad, all-inclusive category provides basic identification, this is an overly simplistic, over-broad, low-common-denominator approach that neither provides protection for children nor does much for parents and communities interested in protecting their children.

Because it operates at the domain level, the DOTXXX approach to identification is essentially server-side. It also means it is necessarily a binary approach, allowing for only 2 possible conditions: inclusion or exclusion. The Supreme Court has upheld the principle that the classification of adult material is a matter for community standards. DOTXXX not only presumes to make that determination for all communities, it also presumes (because it only provides for one category, based on one definition) that all communities will agree.

What we need is a client-side classification system that provides for multiple categories. This is the only way to put control in the hands of parents and communities, where it belongs. And it is the only way to properly reflect the spectrum that adult material comprises. Parents and communities have the power to draw their own line. Parents and communities have a useful range of choices when deciding where to draw that line.

2. While the DOTXXX top-level domain has been presented as an "at will" alternative for adult publishers, its existence simply poses too great a threat that it will be used as a tool of censorship. Though DOTXXX supporters have produced a list of "benefits" the TLD would offer adult publishers who embrace it, these benefits are nullified by the danger (the reasonable likelihood) that it will be used by the Censorial Agenda exerting influence in Washington.

The pressure to censor (eliminate) adult entertainment originates from a number of groups, lobbies and individuals (both inside and outside government) who have a long and well-documented history of condemning adult entertainment as an unequivocal evil. Their arguments are based in religious ideology, and lack the impartial rationality needed to pursue the best soluition for all concerned.

The recently enacted USC 2257 is an example of how the Censorial Agenda distorts truth in order to punish adult publishers and achieve censorial effects.

DOTXXX, like 2257, is trying to shroud itself in the cause of protecting children, so as to be morally unassailable. This is opportunistic and contemptible. It is a lie being pepetrated against the American people, that preys on our love for our kids.

On behalf of the adult industry online, I want to passsionately affirm our commitment to acting in the best interests of our children and to developing the RIGHT solution to this important classificational need. Please trust us. We have never lied to you about what we do or why we do it.

As regards the likelihood that it will be put to destructive use by fundamentalist zealots, the DOTXXX top-level domain is exactly like a nuclear-capable Iran.

We simply cannot risk it.

i love you, franck.