PFIR - People For Internet Responsibility
PFIR Statement on
Top-Level Domain
"Ghettoization" Proposals

March 9, 2001

PFIR Home Page

Greetings. Amidst the continuing discussions and arguments regarding the selection and allocation of Internet Global Top-Level Domains (known as "gTLDs" -- such as ".com"), the politically popular concept of what might be termed "ghettoized" domains has been been frequently cited. The term "ghetto" is emotionally loaded, but seems particularly apt nonetheless for the situations at hand.

In the case of the Internet, a domain ghetto is a gTLD allocated for the specific purpose of attempting to keep particular users "in" or "out" of the sites contained therein. The two most frequently suggested domain ghettos at present are "dot-ex-ex-ex" and ".kids" (the phonetic version of the former is being used to try avoid triggering typically overzealous and inaccurate filtering programs -- please see the "PFIR Statement on Content Control and Ratings").

The implementation of these sorts of ghettoized gTLDs (the term "ghetto-domains" will be used henceforth) would be unwise, unworkable, unsuccessful at achieving the stated purposes, and potentially dangerous to speech-related freedoms. Overall, not a good idea!

The following discussion is directed specifically to the issues surrounding official gTLDs as sanctioned by ICANN and appropriate governmental authorities. It does not address various attempts by some entities to establish their own top-level domains outside of the generally accepted domain structure, since such unsanctioned domains are not (and are unlikely in the near future to become) accessible by the majority of Internet users, and appear to mainly add confusion to an already complex environment.

What would be involved in establishing ghetto domains? In order to implement a ghettoized-domain system, you would of course need to determine what sorts of sites would be required, permitted, encouraged, or pressured to be in each such restricted domain.

Next, you need to establish dispute resolution, policing, and enforcement mechanisms to implement those decisions. Since the Internet is a worldwide medium, most of these decisions and dispute enforcement mechanisms would seemingly need to be determined on a global basis, since the vast majority of sites are free to move their Web operations to other jurisdictions or countries as they wish, and can usually be easily accessed from most other locations around the world.

Finally, if there's to be any intellectual honesty in the equation, there would also be a need to establish that the ghetto-domains can technically achieve their goals and that they are not simply encouraging a false sense of security in the name of political expediency.

Unless we wish to fundamentally change the nature of many of our societies, the above steps would presumably need to be accomplished without the creation of an oppressive "information control" regime that could alter the basic nature of communications and could conflict with existing laws and rights of citizens in many countries.

The bottom line: forget it! Ghetto-domains as a method to try control undesired access to Internet materials appear impossible to implement without extremely serious side-effects. Nor would the end result, after so much effort and disruption, be effective at achieving the stated goals of most ghetto-domain proponents (e.g. to protect children from "inappropriate" materials).

Technical limitations and fundamental design constraints of the Internet Domain Name System (DNS) and Web addressing make absolute control over how sites are named and referred to by other sites impossible to assure, even with the best intentions of the target sites themselves. This could lead to such "leakiness" of the categorization system as to render it practically meaningless as a control mechanism -- it could be easily subverted, contaminated, and circumvented.

Achieving even basic consensus on what material had earned the "right" to be in a ".kids" ghetto-domain -- or would be somehow required to be in a "dot-ex-ex-ex" ghetto-domain, would prove impossible in many countries even on a domestic basis, much less internationally. The likely outcome of attempts in this direction would be the reduction of Internet content to a "lowest common denominator" approach where the dictates of the most conservative and possibly repressive viewpoints could potentially hold sway over the entire planet.

Enforcing such decisions would appear to require vast new surveillance, policing, and judicial (litigation) resources. While it can be assumed that there would some commercial firms and non-commercial organizations which would willingly locate within ghetto-domains, there would undoubtedly be vast numbers of sites, many operated by individuals without charge or profit, that would be unwilling to voluntarily have their content categorized by outside entities. For example, can all such persons be forced to move their Web materials from a personal Web page based on an ISP's ".net" domain over to a ghetto domain, to maintain access to their viewers or to avoid being cited for posting "inappropriate" content in the wrong "ordinary" domain? Such demands would likely result in a parade of litigants for our already overburdened court systems.

There are many specific examples of these issues that are easy to imagine. A page of children's "knock-knock" jokes is on someone's conventional home page. Would this site be ostensibly restricted from access by children because the author hasn't placed that single page within a ".kids" domain? Would every site and every page that might be appropriate for a child -- from museums to encyclopedias to search engines, be required to exist in ".kids" or be (supposedly) unreachable by children? And what would be the penalties if it were determined that some of their material did not meet the ".kids test" promulgated by the powers-that-be? Will general-interest sites be forced to go through every page of their materials, every entry in their databases, to somehow segregate the content via arbitrary external standards?

Similarly, assume that a completely legal nudist camp posts a picture of their members playing volleyball as part of their site information. Regardless of individuals' personal feelings about this sort of recreation, can the site be forced to move to a "dot-ex-ex-ex" domain, since some persons or localities might feel that such activities were deserving of condemnation and isolation in that manner? Would the camp operators be willing to quietly acquiesce to having their sun-drenched volleyball game equated with hard-core, explicit pornography? And what of art, medical information relating to sexually-transmitted diseases, and other categories of content where controversy has always reigned?

Any attempts to impose mandated ghetto-domain requirements either domestically in the United States (or in many other countries), or on some sort of standardized global basis, will entail vast amounts of time, money, effort, and litigation, most of which will be wasted in terms of achieving their stated technical goals.

As was mentioned above, the technical infrastructure of the Internet and DNS system simply will not allow for the level of control that ghetto-domain supporters would require. Internet users (including children), who want to find their way to particular sites, however those sites are categorized, will find a way to do so. The task of "merely" categorizing the vast array of commercial and non-commercial sites would be literally endless and largely fruitless.

However, this is not to say that such efforts won't have oppressive effects. Calls for other avenues of Web site ghettoization can be expected in any case. As more ghetto-domains are defined, the situation only gets more complicated. What would be targeted next for ghettoization? Political speech? Consumer complaints? Non-profit fundraising sites? There will always be vested interests with a desire to compartment public speech in an attempt to limit its reach. Even though such attempts will be largely unsuccessful from a technical standpoint in the Internet environment, the fears of prosecution, litigation, or harassment would still be likely to have chilling effects on many forms of speech that were mandated to exist within ghettoized-domain cubbyholes.

We all have concerns about helping our children learn the appropriate ways to use the Internet responsibly. We certainly need to control genuinely criminal behavior involving the Net. But we must come to grips with the fact that the kinds of "censorship" and "categorization" models which have been applied to other forms of relatively centralized mass media simply will not function appropriately even in a limited sense for the Internet. They cannot be applied without draconian changes in the fundamental nature of speech and other freedoms that are celebrated in many countries throughout the world.

Ghettoized Global Top-Level Domains are not a solution to Internet content concerns, but rather are a route to whole new classes of social, legal, and political problems.

Lauren Weinstein or
Co-Founder, PFIR - People For Internet Responsibility -
Moderator, PRIVACY Forum -
Member, ACM Committee on Computers and Public Policy