These comments are from the online protection company, Kidsnet Inc. the developer of an Internet Protection System for schools and educational institutions, EducationNet. Comments are in response to the questions concerning Section 1703(a)(2), as we believe the questions most closely address the concerns of our company. We also believe that the issues involved in how we developed our product will be helpful in establishing more effective online protection policy. EducationNet is not “blocking and filtering” and takes a unique approach to the problem of children accessing inappropriate Internet content.

I encourage you to look at our Web site, www.Edcuation-Net.net (under construction). To get an idea of how EducationNet works, please feel free to download and install a beta copy of our sister software for individual computers at www.Kidsnet.com (the Kidsnet product is for single computers, EducationNet is designed to install on a server, or higher in the network, and protect all the computers at a particular location). You can also look more closely at our rating system and criteria by going to www.kidsnetinc.com/training. The universe of accessible Web sites available through the EducationNet database of reviewed Web sites is twice as large as that of Yahoo.

1. Are current blocking and filtering methods effectively protecting children or limiting their access to prohibited Internet activity?

While current blocking and filtering software offer some protections, these are not the most effective tools available to families and educational institutions. EducationNet was developed in part to specifically address the inherent weaknesses of current blocking and filtering software and to provide maximum flexibility to educators. Barring any significant leaps in the ability of technical tools to evaluate context, blocking and filtering software will always over-block acceptable sites and under-block some of the unacceptable sites. Every evaluation of this software to date has noted fairly high error rates in at least one of those categories, over-blocking or under-blocking. EducationNet has people complete 100% of all our Web site content reviews and we strongly believe that people will always do a better job of determining Web site content than software, thus helping eliminate many of the errors blocking and filtering software is prone to.

2. If technologies are available but are not used by educational institutions for other reasons, such as cost or training, please discuss.

We do not believe that most Internet users, including educational institutions, are aware that better options are available. As a start-up company, we have concentrated on building and developing our products and have not yet began to promote our products. We welcome the opportunity to show the ways in which our product overcomes many of the limitations of the current blocking and filtering software. We are available to make a presentation or demonstration of how the EducationNet system works or for further discussions on how to protect children while they are online.

EducationNet is also offered at very competitive and reasonable prices for educational institutions. As we have a new product we are aggressively pricing it, often at less cost than the current blocking and filtering products. For example, a license for 100,000 computers would be $0.36 per computer per month ($4.31 per computer per year, $431,250 total). This is significantly less than the average cost of $2.50 per computer per month for electricity.

3. What technology features would better meet the needs of educational institutions trying to block prohibited content?

We believe educational institutions need a product that puts information in the hands of educators and administrators and allows them to make decisions as to what content is inappropriate for students as they are best in tune with the developmental stage of the children in their care. Educators and administrators will almost always make a better decision on this than a software company of software. EducationNet has three strong philosophical guidelines that differentiate it from blocking and filtering software. First, EducationNet is more accurate and reliable than blocks and filters as people complete 100% of the content reviews. Two, EducationNet Web site content review criteria are based on a transparent and adaptable content review system making it easy for users to see, or even contest, how content is rated. And third, EducationNet can be adapted to fit the needs of different institutions and community standards. We strongly believe that educational institutions needs a product that will assist them in identifying quality sites as opposed to simply a quantity of sites.

The features that we have built into EducationNet offer educational institutions an optimal tool for making Internet access decisions with optimal flexibility. EducationNet is the optimal tool because it offers an unprecedented amount of information about Internet content. We have compiled content information on over 130,000 Internet Top Level Domains comprising millions of Web sites. And our database just continues to grow dynamically based on where our users go. Within that database, we have identified sites that have specific educational content. Proof of this is the top 10,000 Web sites account for approximately 90% of World Wide Web traffic. This shows most users are looking for specific content and quality, not quantity.

Most importantly, EducationNet offers detailed content information; it is the users who decide what content they want to restrict and at what level. The ability to restrict access is based on information in our database that has been gathered by a comprehensive system of our trained and certified content review specialists. Starting with an international standard of content rating for nudity/sex, language, and violence (ICRA standards), EducationNet added over 30 additional content categories that could be restricted. The ratings in each of the major content categories are fairly granular, offering users varying degrees of options for what could be acceptable. For example, pornography sites can be restricted while allowing nudity in an artistic, educational, or medical context. Also, there is a “one click” option that creates a CIPA compliant Internet protection system.

The rating structure and criteria used by EducationNet is totally transparent to users. Users are given complete access to the rating structure and restrictive categories. Our definitions and criteria are also available to users.

An educational institution using our product could make one generic content standard for the whole institution. However, the institution also has the option of establishing different content standards for users of different ages or levels. Our product could also be set up with individual user accounts (with, perhaps, parents setting the access restrictions)

4. Can currently available filtering or blocking technology adjust to accommodate all age groups from kindergarten through grade twelve? Are these tools easily disabled to accommodate bona fide and other lawful research? Are these tools easily dismantled?

We believe that the inherent limitations of blocks and filters make it difficult to provide meaningful accommodations for different levels and types of users. Our content rating system would be able to easily accommodate different age users and can be configured to allow for specific types of research.

Please feel free to contact us if we may be of additional assistance. As mentioned earlier we are available to come discuss our system, or demonstrate it, at your request. We look forward to assisting in whatever way possible in making the Internet a safer and better place for children.

Please contact our President, Mr. Bob Dahlstrom for further information or with comments, questions, or concerns. He may be reached at 904-398-1911 (866-kidznet) or via e-mail at bob@Education-net.net or bob@kidsnetinc.com