Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

Name: Reg Levy
Date: 22 Apr 2024
Affiliation: Tucows Domains
Other Comments

The .xxx sponsored top-level domain (“sTLD”) is a specialized namespace intended for the adult entertainment industry. However, the ongoing relevance of an sTLD just for the adult entertainment industry in the current landscape of top-level domains (“TLDs”) is questionable. The Internet has evolved to include a vast array of generic TLDs (“gTLDs”). 


Registering and using a .xxx domain name presents unique challenges due to its specific target audience and the regulations that govern it. Currently, to register a .xxx domain, one must become a member of the Sponsored Community, which involves a separate application process to verify eligibility. This extra step is a barrier for those looking to quickly secure a domain. Additionally, the domain cannot resolve—meaning it cannot be used to host a website—without a valid Membership ID, which is only issued after this verification process. 


This activation involves additional interactions between the registry, the registrant, and the registrar. Additional steps in the registration process can be a significant deterrent as they introduce complexity and time delays. This discourages individuals and businesses from securing their desired domain names, especially if the process is perceived as cumbersome or non-transparent. Simplifying the registration process will lead to increased participation and innovation online.


Furthermore, requiring membership in the Sponsored Community amounts to surveillance of sex workers and many members of the adult entertainment industry are rightly concerned about the necessity of this step for mere domain name registration.


As a registrar for .xxx domain names, the above challenges add complexity to the registration path and we support making it easier and less intrusive to register domain names.


The .xxx Registry Agreement (“RA”) has undergone multiple amendments since the original agreement was signed in 2011. These amendments typically sought to bring the agreement in line with the Base Registry Agreement used in the 2012 round of new gTLDs—but the “sponsorship” requirement remains.


The .xxx RA, Appendix S, states:


“In the event Registry Operator proposes to modify the Charter, Registry Operator shall bear the burden of demonstrating that such modification is consistent with the application for the sTLD submitted by ICM Registry in March 2004, as amended, and any such modification shall be subject to approval by ICANN.” (Part 1. DotXXX Charter, §4)


Tucows believes that the registry has met this burden, as is evident from the documents submitted to ICANN: there is no dilution of responsibility for the registry and the “community” that the sponsorship is intended to serve no longer believes that the sponsorship brings any value to the operation of the TLD.

Summary of Submission

The registry has provided sufficient proof that verification and membership requirement is outdated and no longer necessary. Bringing the TLD in line with other gTLDs will benefit everyone, including potential registrants