CANOGA PARK, Calif. — Free Speech Coalition (FSC) on Friday sent a letter to the Board of Directors of Internet regulator ICANN and to its Governmental Advisory Committee (GAC), urging the Board not approve Internet registrar ICM’s application for the proposed .XXX sponsored top level domain (sTLD).

“This is an extremely comprehensive and powerful document,” FSC Executive Director Diane Duke said. “FSC thanks Jeffrey Douglas, Tom Hymes and especially Reed Lee who worked long hours ensuring not only that all topics were covered, but also that they were meticulously referenced.”

FSC has opposed the adoption of .XXX domains for adult online business since 2004. The adult industry trade association is asking that the ICANN Board and GAC will consider the document prior to the ICANN Board meeting scheduled to be held in March, in San Francisco.

When it rejected ICM’s .XXX sTLD proposal in 2007, the ICANN Board articulated five reasons, virtually all of which related to concerns that had been expressed by ICANN’s Governmental Advisory Committee (GAC). After that decision, ICM Registry invoked ICANN’s process of an Independent Review Panel (IRP). Utilizing the information provided by ICM’s application and testimony that included ICM representation — but no adult entertainment industry representatives — the IRP determined that ICM had met the “sponsorship community” requirements for the sponsored TLD.

At the last ICANN Board meeting held in December, the Board expressed intent to move into a contract with ICM for a .XXX sTLD but, as required by ICANN’s by-laws, must consider GAC advice. The .XXX consideration now moves to consultations between the ICANN Board and the GAC.

On a number of occasions, the GAC has voiced concern over a .XXX sTLD. FSC’s letter focuses primarily on the context of those concerns raised by GAC. The GAC took issue with the promises included in ICM’s proposal, challenging ICM’s ability to follow through with those commitments.

ICM claims that .XXX will help combat child pornography and protect vulnerable communities. ICM asserts that $10 of every $60 registration will go to combat child pornography. However in its letter, FSC documents where that very same $10 has been promised to help the adult industry for everything from 2257 to piracy. Moreover FSC quotes the founder of Safekids.com — one of the oldest and most enduring web sites for Internet safety — stating, “As an Internet safety advocate, my concern about .XXX is that it could give parents a false sense of security.”

Also in its letter, FSC pointed out the promises to protect intellectual property seem to extend more to mainstream companies than the businesses ICM purports to represent. ICM’s “Sunrise for .XXX” initial rights protection document offers domain parking options to only non-adult companies. The letter challenges ICM’s intent to “take appropriate measures to restrict access to illegal and offensive content,” pointing out that what is legal and offensive varies drastically from country to country.

Finally FSC addresses the issue of “sponsorship community” clearly documenting where the adult industry and ICANN were deceived by the use of “pre-reservations” as a sign of industry support.