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Letter from Freridge, Free Speech Coalition to Cerf regarding .XXX TLD Application

Post Office Bos 10480
Canoga Park, CA 91309

August 30, 2005

Dear Dr. Cerf,

The Free Speech Coalition is the trade association of the adult entertainment industry, with over 3000 members representing every area of the business. As such, we have a direct stake in the decision whether to implement the .xxx top-level domain (TLD), and we were pleased when Assistant Secretary of Commerce Michael D. Gallager asked the Board of Directors of ICANN to delay any further decisions regarding .xxx until it could "ensure that the concerns of all members of the Internet community on this issue have been adequately heard and resolved." We also share the concerns of foreign governments that have espressed their reservations about the creation of this TLD, and commend the Board for agreeing to suspend a final decision.

Our understanding is that there will be a one-month extension during which time discussions are to take place. As a significant stakeholder not yet afforded a voice in these discussions, we would like to take this opportunity to express our strong opposition to the creation of a .xxx TLD. We are also concerned that important decisions are being made allegedly on behalf of the adult industry by individuals who have, at best, minority support in the adult webmaster community, and lack any other legitimate authority to make any such claims to representation.

Specifically, we believe that ICM Registry has consistent and knowingly distorted the support it has received from the adult industry, and thatit has done so in order to qualify its application for a sponsored top-level domain, which requires said support. We are concerned about the prospect of a sponsored TLD run by people who would distort the truth in order to gain control of such a lucrative monopoly, and we wonder how hard they will fight for this industry when hostile forces attempt to dictate policy for this top-level domain.

In addition to our above concerns, we respectfully request that you rethink the wisdom of segregating lawful speech on the Internet in the first place. We urge ICANN to use the opportunity presented by the objections expressed by various governments and withdraw the proposed approval.


Michelle L. Freridge
Executve Director
The Free Speech Coalition

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."