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Child abuse material is an issue. You can try to ignore it and if you’re lucky enough you’ll never ever have to come into direct contact with it. I have a lot of respect for the law enforcement officers who work in this space. They’re dealing with crimes against children that make my stomach turn.

Unfortunately the “dark side” of the internet is a reality and I am thankful that there are people out there who are dedicated to eradicating these kind of issues.

However I am also very wary of any moves by law enforcement to force industry to block access to websites.

If website blocking is implemented in a country does it really solve anything?

Who decides which sites get blocked?

Are entire domain names being blocked or are the blocks only being applied to specific sub-domains?

Should the ISP be responsible for what users do on their network at all times?

Or should that be up to the user?

There are a LOT of questions around this.

But I’ve always been a strong advocate of industry self-regulation. Let us in industry work together with law enforcement and consumer protection authorities etc., to keep the internet clean. Top down actions are often unworkable and easily circumvented. Blocking access to a website at the ISP level might stop a non-technical user, but there are as many ways to get around those blocks as there are blocks themselves.

We are proud to be members of Irish ISP Association (, I’m a member of APWG and am also involved with We put our money where our mouth is and don’t just simply pay lip service to what we advocate.

However we do not offer all internet services. I’m not sure we’d even want to .. At the moment we offer website hosting, colocation, dedicated servers, transit, domain names, secure certs and a whole lot more. We don’t, however, offer “access” ie. you cannot buy internet access services from us.

So the letter below took me by surprise on more than one front:

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We have, of course, replied:



We acknowledge receipt of your letter dated May 30th 2014 in relation to distribution of child abuse material (CAM).

Your letter has caused us some degree of confusion.

Blacknight Internet Solutions Ltd (Blacknight), is Ireland’s largest hosting company and domain name registrar.

We are active members of several industry organisations including, RIPE, APWG and are proud supporters of

As part of our membership of, we have agreed to self-regulation. As part of this self-regulatory framework, we and other companies expect to work with law enforcement (LEA) via our industry association ( On this basis your letter to us confuses us, as we had not had any communication from on this subject.

Secondly we find your request problematic.

You speak about blocking access to websites, domains and sub-domains. However it is not clear from your letter where the list of these domains will come from, how it will be managed or who will be vetting it.

Also it sounds like you wish to make use of user access logs to identify other websites to block. Essentially this sounds like you want to have full access to all user logs from ISPs’ networks. This is problematic.

Has this plan been properly vetted by the Data Protection Commissioner? Granting access to user logs without warrant, even if “identification information” is not released is a form of mass surveillance.

Thirdly, due to the nature of the services that we currently supply we would be unable to assist you in this matter, as we do not provide compatible services, such as DSL, ADSL or other ISP connectivity services to end users. We provide website hosting, domain name registration, bandwidth and transit to Irish and international businesses.

We look forward to engaging with you further on this matter via our industry association.


Most of the Irish ISPs are member of and we, as a group, have had constructive dialogue with government, law enforcement and others in the past. Circumventing industry is not the best way to achieve any workable solution.


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