[Donald Eastlake and I co-authored this IETF Internet Draft in advance of
the March 18 meeting in Minneapolis. This is an inital draft, and comments
are very welcome. You can also find the draft at:
http://www.ietf.org/internet-drafts/draft-eastlake-xxx-00.txt --Declan]
***********
INTERNET-DRAFT Donald Eastlake 3rd
Motorola
Declan McCullagh
Wired News
Expires: August 2001 February 2001
.xxx Considered Dangerous
---- ---------- ---------
Status of This Document
Distribution of this draft is unlimited. Comments should be sent to
the authors.
This document is an Internet-Draft and is in full conformance with
all provisions of Section 10 of RFC 2026. Internet-Drafts are
working documents of the Internet Engineering Task Force (IETF), its
areas, and its working groups. Note that other groups may also
distribute working documents as Internet-Drafts.
Internet-Drafts are draft documents valid for a maximum of six months
and may be updated, replaced, or obsoleted by other documents at any
time. It is inappropriate to use Internet- Drafts as reference
material or to cite them other than as "work in progress."
The list of current Internet-Drafts can be accessed at
http://www.ietf.org/ietf/1id-abstracts.txt
The list of Internet-Draft Shadow Directories can be accessed at
http://www.ietf.org/shadow.html.
Copyright Notice
Copyright (C) The Internet Society (2001). All Rights Reserved.
Abstract
Periodically there are proposals to require the use of a special top
level name or an IP address bit to flag "adult" or "safe" material or
the like. This document explains why this is an ill considered idea.
D. Eastlake 3rd, D. McCullagh [Page 1]
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Table of Contents
Status of This Document....................................1
Copyright Notice...........................................1
Abstract...................................................1
Table of Contents..........................................2
1. Background..............................................3
2. Legal and Philisophical Problems........................4
4. Technical Difficulties..................................6
4.1 Domain Name System (DNS) and Other Names...............7
4.1.1 Linguistic Problems..................................7
4.1.2 The DNS Hierarchy and Use of TLDs....................8
4.1.2 You Can't Control Who Points At You..................8
4.1.3 Particular Protocol Considerations...................9
4.1.3.1 Electronic Mail (SMTP).............................9
4.1.3.2 Web Access (HTTP).................................10
4.1.3.3 News (NNTP).......................................10
4.1.3.4 Internet Relay Chat...............................10
4.2 IP Addressing.........................................10
4.2.1 Hierarchical Routing................................11
4.2.2 IP Version 4 Addresses..............................12
4.2.3 IP Version 6 Addresses..............................12
4.3 PICS Labels...........................................13
5. Conclusions............................................13
References................................................14
Authors Addresses.........................................15
Full Copyright Statement..................................16
Expiration and File Name..................................16
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1. Background
The concept of a .xxx, .sex, or similar top-level domain is
periodically suggested by politicians and commentators. Other
proposals have included a domain reserved exclusively for material
viewed as appropriate for minors, or using IP address bits or ranges
to segregate content.
In an October 1998 report accompanying the Child Online Protection
Act, the House Commerce committee said "there are no technical
barriers to creating an adult domain, and it would be very easy to
block all websites within an adult domain." The report also said that
the committee was wary of regulating the computer industry and that
any decision by the U.S. government "will have international
consequences." [HOUSEREPORT]
British Telecom has backed adult top-level domains, saying in a 1998
letter to the U .S. Department of Commerce that it "strongly
supported" that plan. The reason: "Sexually explicit services could
then be legally required to operate with domain names in this gTLD
[that] would make it much simpler and easier to control access to
such sites..." [BT] One of ICANN's progenitors, the GTLD-MOU
committee, suggested a "red-light -zone" top-level domain in a
September 1997 request for comment. [GTLD-MOU]
Some adult industry executives have endorsed the concept. In 1998,
Seth Warshavsky, president of the Internet Entertainment Group, told
the U.S. Senate Commerce committee that he would like to see a .adult
domain. "We're suggesting the creation of a new top-level domain
called '.adult' where all sexually explicit material on the Net would
reside," Warshavsky said in an interview at the time. [WARSHAVSKY]
More recently, other entrepreneurs in the industry have said that
they do not necessarily object to the creation of an adult domain as
long as they may continue to use .com.
Conservative groups in the U.S. say they are not eager for such a
domain, and prefer criminal laws directed at publishers and
distributors of sexually-explicit material. The National Law Center
for Children and Families in Fairfax, Virginia, said in February 2001
that it did not favor any such proposal. For different reasons, the
American Civil Liberties Union and civil liberties groups also oppose
it.
Sen. Joseph Lieberman, the U.S. Democratic Party's vice presidential
nominee, endorsed the idea at a June 2000 meeting of the federal
Commission on Child Online Protection. Lieberman said in a prepared
statement that "we would ask the arbiters of the Internet to simply
abide by the same standard as the proprietor of an X-rated movie
theater or the owner of a convenience store who sells sexually-
explicit magazines." [LIEBERMAN]
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In the 1998 law creating this commission, the U.S. Congress required
the members to investigate "the establishment of a domain name for
posting of any material that is harmful to minors." The commission
devoted a section of its October 2000 report to that topic. It
concluded that both a .xxx and a .kids domain are technically
possible, but would require action by ICANN. The report said that an
adult domain might be only "moderately effective" and raises privacy
and free speech concerns. [COPAREPORT]
The commission also explored the creation of a so-called red zone or
green zone for content by means of allocation of a new set of IP
addresses under IPv6. Any material not in one of those two zones
would be viewed as in a grey zone and not necessarily appropriate or
inappropriate for minors. Comments from commissioners were largely
negative: "Effectiveness would require substantial effort to attach
content to specific I P numbers. This approach could potentially
reduce flexibility and impede optimal network performance. It would
not be effective at blocking access to chat, newsgroups, or instant
messaging."
In October 2000, ICANN rejected a .xxx domain during its initial
round of approving additional top-level domains. The reasons are not
entirely clear, but former ICANN Chairwoman Esther Dyson said that
the adult industry did not entirely agree that such a domain would be
appropriate. One .xxx hopeful, ICM Registry of Ontario, Canada, in
December 2000 asked ICANN to reconsider its decision. [ICM-REGISTRY]
2. Legal and Philisophical Problems
When it comes to sexually-explicit material, every person, court, and
government has a different view of what's acceptable and what is not.
Attitudes change over time, and what is viewed as appropriate in one
town may spark protests in the next. When faced with the slippery
nature of what depictions of sexual activity should be illegal or
not, one U.S. Supreme Court justice blithely defined obscenity as: "I
know it when I see it."
In the U.S., obscenity is defined as explicit sexual material that,
among other things, violates "contemporary community standards" -- in
other words, even at the national level, there is no agreed-upon rule
governing what is illegal and what is not. Making matters more knotty
is that there are over 200 United Nations country codes, and in most
of them political subdivisions can impose their own restrictions.
Even for legal nude modeling, age restrictions differ. They're
commonly 18 years of age, but only 17 years of age in Sweden. A
photographer in Oslo conducting what's viewed as a legal and proper
photo shoot there likely would be branded a felon and child
pornographer in the U.S.
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Saudi Arabia, Iran, and China are not likely to have the same liberal
views as, say, the Netherlands. Saudi Arabia, like some other
nations, filters its Internet connection and has created a government
committee to protect its society from web sites that officials view
as immoral. Their views on what should be included in a .xxx domain
would hardly be identical to those in more liberal democracies.
Those wildly different opinions on sexual material make it improbable
a global consensus can ever be reached on what is appropriate or
inappropriate for a .xxx or .adult top-level domain. Moreover, the
existence of such a domain would create an irresistible temptation on
the part of conservative legislators to require controversial
publishers to move to that domain.
Some conservative politicians already have complained that ICANN did
not approve .xxx in its October 2000 meeting. During a February 2001
hearing in the U.S. House of Representatives, legislators warned that
they "want to explore ICANN's rationale for not approving two
particular top level domain names -- .kids and .xxx -- as a means to
protect kids from the awful smut which is so widespread on the
Internet."
It seems plausible that only a few adult publishers, and not those
who have invested resources in building a brand around a .com site,
would voluntarily abandon their current domain name. Instead, they'd
likely add a propel legislators in the U.S. and other countries to
require them to publish exclusively from an adult domain, a move that
would invite ongoing political interference with Internet governance
and raise concerns about forced speech and self-labeling.
In fact, the ultimate arbiter of generic top-level domain names -- at
least currently -- is not ICANN, but the U.S. government. The U.S.
Congress' General Accounting Office in July 2000 reported that the
Commerce Department continues to be responsible for domain names
allowed by the authoritative root. [GAO] The GAO's auditors concluded
it was unclear whether the Commerce Department has the "requisite
authority" under current law to transfer that responsibility to
ICANN.
The American Civil Liberties Union -- and other members of the
international Global Internet Liberty Campaign -- caution that
publishers speaking frankly about birth control, AIDS prevention, and
gay and lesbian sex could be coerced into moving to an adult domain.
Once there, they would be stigmatized and easily blocked by schools,
libraries, companies, and other groups using filtering software.
Publishers of such information who do not view themselves as
pornographers and retain their existing addresses could be targeted
for prosecution.
The existence of an adult top-level domain would likely open the door
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for related efforts, either policy or legislative. There are many
different axes through which offensive material can be defined: Sex,
violence, hate, heresy, subversion, blasphemy, illegal drugs,
profanity, political correctness, glorification of crime, incitement
to break the law, and so on. Such suggestions invite the ongoing
lobbying of ICANN, the U.S. government, or other policy-making bodies
by special-interest groups that are not concerned with the technical
feasibility or practicality of their advice.
An adult top-level domain could have negative legal repercussions by
endangering free expression. U.S. Supreme Court Justice Sandra Day
O'Connor has suggested that the presence of "adult zones" on the
Internet would make a future Communications Decency Act (CDA) more
likely to be viewed as constitutional. In her partial dissent to the
Supreme Court's rejection of the CDA in 1997 [CDA], O'Connor said
that "the prospects for the eventual zoning of the Internet appear
promising." (The Supreme Court ruled the CDA violated free speech
rights by making it a crime to distribute "indecent" or "patently
offensive" material online.)
Privacy could be harmed by such a proposal. It would become easier
for repressive governments and other institutions to track visits to
sites in a domain labeled as adult and record personally-identifiable
information about the visitor. Repressive governments would instantly
have more power to monitor naive users and prosecute them for their
activities. It's also not clear how effective a top-level domain
would be when controlling access to chat, email, newsgroups and
instant messaging.
4. Technical Difficulties
Even ignoring the philosophical and legal difficulties outlined
above, there are substantial technical difficulties in attempting to
impose content classification by domain names or IP addresses.
Mandatory content labeling is usually advanced with the idea of using
a top level domain name, discussed in section 4.1 below, but we also
discuss the more fundamental possibility of using IP address bits or
ranges in section 4.2 below.
In section 4.3 difficulties with a few particular higher level
protocols are discussed. In some cases, these protocols use
different name spaces.
We also discuss PICS labels [PICS] as an alternative technology in
section 4.4.
Only a limited technical background is assumed so some basic
information is included below and in some cases descriptions are
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simplified.
4.1 Domain Name System (DNS) and Other Names
The most prominent user visible part of Internet naming and
addressing is the domain name system [RFC 1034, 1035]. Domain Names
are dotted sequences of labels such as aol.com, world.std.com,
www.rosslynchapel.org.uk, or ftp.gnu.lcs.mit.edu [RFC 1035, 1591,
2606]. They form an important part of most World Wide Web addresses
or URLs [RFC 2396], commonly appearing right after "//".
Actually, domain names just name nodes in a global distributed
hierarchically delegated database. A wide variety of information can
be stored at these nodes including IP addresses of machines on the
network (see section 4.2 below), such things as mail delivery
information, and many other types of information. Thus, the data
stored at foo.example.com could be the numeric information for
sending data to a particular machine, which would be used if you
tried to browse http://foo.example.com, the name of a computer (say
mailhost.example.com) to handle mail addressed to anyone
@foo.example.com, and other information.
There are also other naming systems in use, such as news group names
and Internet Relay Chat (IRC) channel names.
The usual labeling idea presented is to reserve a top level name,
such as .xxx for "adult" material and/or .kids for "safe" material or
the like. Ignoring the definitional and legal problems there are
technical and linguistic problems with this are described in the
subsections below.
4.1.1 Linguistic Problems
When using name labeling, the first problem is from whose language do
you take the names to impose? Words and acronyms can have very
different meanings if different languages and the probability of
confusion is multiplied when phonetic collisions are considered.
As an example of possible problems, note that currently the
government of Turkmenistan has suspended new registrations in ".tm",
which had previously been a source of revenue, because some of the
registered second level domain names may have been "legally obscene
in Turkmenistan". http://www.nic.tm
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4.1.2 The DNS Hierarchy and Use of TLDs
An important aspect of the design of the Domain Name System (DNS) is
the hierarchical delegation of data maintenance. The DNS really only
works, and has been able to scale the five orders of magnitude it has
grown since its initial deployment, only due to this delegation.
The first minor problem is that one would expect most computers or
web sites to have a mix of material only some of which should be
specially classified. Using special TLDs multiples the number of DNS
zones the site has to worry about. For example, assume the site has
already sorted its material into "kids", "normal, and "adult" piles.
Without special TLD labels, it can store them under kids.example.net,
adult.example.net, and other.example.net, for instance, which
requires only the maintenance of the single example.net zone of
database entries. With special TLD labeling, at least example.net
(for normal stuff), example.net.xxx, and example.net.kids would need
to be maintained which are three separate zones in different parts of
the DNS tree. As the number of categories expands and the number of
category combinations explodes, this quickly becomes completely
unmanageable.
4.1.2 You Can't Control Who Points At You
The DNS system works as a database and associates certain data,
called resource records, or RRs, with domain names. In particular,
it can associate IP address resource records with domain names. For
example, when you browse a URL, most commonly the domain name within
that URL is looked up in the DNS and the resulting address (see
Section 4.2) is used to address the packets sent from your web
browser or other software to the server or peer.
Remember what we said in Section 4.1.1 about hierarchical delegation?
Anyone controlling a DNS zone of data, say example.com, can insert
data at that name or any deeper name (except to the extent they
maintain delegations of some of the deeper namespace to yet others).
So the controller of example.com can insert data so that
purity.example.com has stored at it the same computer address which
is at www.obscene.example.xxx. This directs any reference to
purity.example.com to use the associated IP address which is the same
as the www.obscene.example.xxx web site. The manager of that
hypothetical web site, who controls the example.xxx zone, has no
control over the example.com DNS zone and so is technically incapable
of causing it to conform to any "xxx" labeling law. Or, in the
alternative, someone could create a name conforming to an adult
labeling requirement that actually pointed to someone else's entirely
unobjectionable site, perhaps for the purpose of polluting the
labeling.
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Thus, providers of data on the Internet cannot stop anyone from
creating names pointing to their computer's IP address with
misleading domain names.
4.1.3 Particular Protocol Considerations
There are additional considerations related to particular protocols.
We consider only a few here. The first two, electronic mail and the
World Wide Web, use domain name addressing. The second two, net news
and IRC, actually use different name spaces and illustrate further
technical problems with name based labeling.
4.1.3.1 Electronic Mail (SMTP)
The standard Internet electronic mail protocol separates "envelope"
information from content [RFC 821, 822]. The envelope information
indicates where a message claims to have originated and to whom it
should be delivered. The content has fields starting with labels
like "From:" and "To:" but these actually have no effect and can be
arbitrarily forged using simple normally available software, such a
telnetting to the SMTP port on a mail server. Content fields are not
compared with envelope fields.
While different mail client display envelope information and headers
from the content of email differently, generally the more common
content fields are given prominence. Thus, while not exactly the
same as content labeling, it should be noted that it is trivial to
send mail to anyone with arbitrary domain names in the email
addresses appearing in the From and To headers, etc.
It is also easy set up a host to forward mail to a mailing list.
Mail sent with normal mail tools to this forwarder will automatically
have content headers reflecting the forwarder's name but the
forwarder will change the envelope information and cause the mail to
be actually sent to the original list. For example, (with names
disguised) there is a social mailing list innocuous@foo.example.org
and someone set up a forwarder at cat-torturers@other.example. Mail
sent to the forwarder is forwarded and appears on the innocuous
mailing list but with a "To: cat-torturers@other.example" header in
its body. In some cases, similar things can be done using the "bcc"
or blind courtesy copy feature of Internet mail.
Thus, standard Internet tools provide no way to control domain names
appearing inside email headers.
There is work proceeding on securing email; however, such efforts at
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present only allow you to verify whether or not a particular entity
was the actual author of the mail. They do not generally relate to
controlling or authenticating domain names in the content of the
mail.
4.1.3.2 Web Access (HTTP)
At least with modern web servers and browsers supporting HTTP 1.1
[RFC 2616], the domain name used to access the site is available to
access different web sites even though they are on the same machine
at the same IP address.
(more to come)
4.1.3.3 News (NNTP)
Net news uses hierarchical structured newsgroup names that are
similar in appearance to domain names except that the most
significant label is on the left and the least on the right, the
opposite of domain names. However, while the names are structured
hierarchically, there is no central control. Instead, news servers
periodically connect to other news servers that have agreed to
exchange messages with them and then they update each other on
messages only in those newsgroups in which they wish to exchange
messages.
(more to come)
4.1.3.4 Internet Relay Chat
Internet Relay Chat is another example of a service which uses a
different name space. (more to come)
4.2 IP Addressing
A key characteristic of the Internet Protocol (IP) on which the
Internet is based is that it breaks data up into "packets". These
packets are individually handled and routed from source to
destination. Each packet has in it a numeric address for the
destination point to which the Internet will try to deliver the
packet.
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(End users do not normally see these numeric addresses but instead
deal with "domain names" as described in section 4.1 above.)
The numeric address system now primarily in use is called IPv4, or
Internet Protocol Version 4, which provides for 32 bit addresses.
There is a move to migrate to IPv6, which provides for 128 bit
addresses.
One problem in using addressing for content filtering is that this is
a very coarse technique. IP addresses address network interfaces
which usually correspond to entire computer systems which could house
multiple web pages, sets of files, etc., only a small part of which
it was desired to block or enable. Increasingly, a single IP address
may correspond to a NAT (Network Address Translation) box [NAT] which
hides multiple computers behind it, although in that case these
computers are usually not servers.
However, even beyond this problem of coarse granularity, the
practical constraints of hierarchical routing make the allocation of
even a single IPv4 address bit or any significant number of IPv6
address bits impossible.
4.2.1 Hierarchical Routing
As packets of data flow through the Internet, decisions must be made
as to how to forward them "towards" their destination. This is
normally done by comparing the initial bits of the packet destination
address to entries in a "routing table" and forwarding the packets as
indicated by the table entry with the longest prefix match.
While the Internet is actually a general mesh, if, for simplicity, we
consider it to have a central backbone at the "top", a packet is
typically routed as follows:
The local networking code looks at its routing table to determine if
the packet should be sent directly to another computer on the "local"
network, to a router to specially forward it to another nearby
network, or routed "up" to a "default" router to forward it to a
higher level service provider's network. If the packet's destination
is "far enough away" it will eventually get forwarded up to a router
on the backbone. Such a router can not sent the packet "up" since it
is at the top or "default free" zone and must have a complete table
of what other top level router to send the packet to. Currently,
such top level routers are very large and expensive devices. They
must be able to maintain tables of tens of thousands of routes. When
the packet gets to the top level router of the part of the network
within which its destination lies, it get forwarded "down" to
successive routers which are more and more specific and local until
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eventually its gets to a router on the local network where its
destination address lies. This local router sends the packet
directly to the destination computer.
Because all of these routing decisions are made on a longest prefix
match basis, it can be seen that IP addresses are not general names
or labels but are intimately associated with the actual topology and
routing structure of the network. If there were assigned at random,
routers would be required to remember so many specific routes for
specific addresses that it would exceed the current technical
capabilities for router design.
It should also be noted that there is some inefficiency in allocation
at each level of hierarchy. Generally allocations are of a power of
two addresses and as requirements grow and/or shrink, it is not
practical to use every address for a computer.
(The above simplified description ignores multi-homing and many other
details.)
4.2.2 IP Version 4 Addresses
There just isn't any practical way to reallocate even one bit of IPv4
global Internet Addresses for content filtering use. Such addresses
are in short supply and such an allocation would, in effect, cut the
number of available addresses in half. There just aren't enough
addresses, given the efficiency of hierarchical allocation and
routing, to do this. Even if there were, current numbers have not be
allocated with this in mind so that a renumbering within every
organization with hosts on the Internet would be required, a
nightmarish and Herculean task costing in the billions of dollars.
Even if these problems were overcome, the allocation of even a single
bit would likely double the number of routes in the default free
zone, exceeding the capacity of current routers and requiring the
upgrade of thousands of them to new routers that do not exist yet.
And all this is for only a single bit, let alone more than one, is
allocated to content labeling.
Basically, the idea is a non-starter.
4.2.3 IP Version 6 Addresses
IPv6 provides 128 bit address fields. (more to come)
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4.3 PICS Labels
PICS Labels [PICS] have several modes. If content is required to
have labels in it, it raises all the problems of categorization
granularity and forced speech. But if used in a mode whereby a third
party determines and provides labels for content and users are free
to select whatever such third party or parties they wish to consult,
it is a way to permit a myriad of categories, editors, and evaluators
to exist in parallel.
(more to come)
5. Conclusions
TBD
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References
[BT] - British Telecom comments to U.S. Commerce Department, February
20, 1998,
http://www.ntia.doc.gov/ntiahome/domainname/130dftmail/BT.htm
[CDA] - Reno v. American Civil Liberties Union, 117 S.Ct. 2329, June
26, 1997, <http://supct.law.cornell.edu/supct/html/96-
511.cpanel.html>
[COPAREPORT] - Final Report of the COPA Commission to the U.S.
Congress, October 20, 2000,
http://www.copacommission.org/report/newtopleveldomain.shtml
[GAO] - GAO Report OGC-00-33R, July 7, 2000,
http://www.gao.gov/new.items/og00033r.pdf
[GTLD-MOU] - GTLD-MOU Policy Oversight committee RFC 97-02, September
13, 1997, http://www.gtld-mou.org/docs/notice-97-02.html
[HOUSEREPORT] - U.S. House Commerce Committee report, 105th Congress,
October 5, 1998.
http://www.epic.org/free_speech/censorship/hr3783-report.html
[ICM-REGISTRY] - Request for reconsideration from ICM Registry to
ICANN, December 15, 2000,
<http://www.icann.org/committees/reconsideration/icm-request-
16dec00.htm>
[LIEBERMAN] - Testimony of Senator Joe Lieberman before Children's
Online Protection Act Commission, June 8, 2000,
<http://www.senate.gov/~lieberman/press/00/06/2000608958 .html>
[NAT] - ...
[PICS] - Platform for Internet Content Selection
Service Descriptions http://www.w3.org/TR/REC-PICS-services
Label Format and Distribution <http://www.w3.org/TR/REC-PICS-
labels>
PICS Rules http://www.w3.org/TR/REC-PICSRules
PICS Signed Labels (DSIG) 1.0 Specification
http://www.w3.org/TR/REC-DSig-label/
[RFC 791] - "Internet Protocol", J. Postel, September 1981.
[RFC 821] - "Simple Mail Transfer Protocol", J. Postel, Aug-01-1982.
[RFC 822] - "Standard for the format of ARPA Internet text messages",
D. Crocker, Aug-13-1982.
D. Eastlake 3rd, D. McCullagh [Page 14]
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[RFC 1034] - P. Mockapetris, "Domain Names - Concepts and
Facilities", STD 13, November 1987.
[RFC 1035] - P. Mockapetris, "Domain Names - Implementation and
Specifications", STD 13, November 1987.
[RFC 1591] - J. Postel, "Domain Name System Structure and
Delegation", March 1994.
[RFC 2396] - T. Berners-Lee, R. Fielding, L. Masinter, "Uniform
Resource Identifiers (URI): Generic Syntax", August 1998.
[RFC 2460] - "Internet Protocol, Version 6 (IPv6) Specification",
Deering, S. and R. Hinden, December 1998.
[RFC 2606] - D. Eastlake, A. Panitz, "Reserved Top Level DNS Names",
June 1999.
[RFC 2616] - "Hypertext Transfer Protocol -- HTTP/1.1", R. Fielding,
J. Gettys, J. Mogul, H. Frystyk, L. Masinter, P. Leach, T. Berners-
Lee, June 1999.
[WARSHAVSKY] - "Congress weighs Net porn bills," CNET article,
February 10, 1998, http://news.cnet.com/news/0-1005-200-326435.html
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Full Copyright Statement
Copyright (C) The Internet Society (2001). All Rights Reserved.
This document and translations of it may be copied and furnished to
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Expiration and File Name
This draft expires August 2001.
Its file name is draft-eastlake-xxx-00.txt.
D. Eastlake 3rd, D. McCullagh [Page 16]