An Alternative to Government Regulation and
Content Advisory Systems for the Internet
C. Dianne Martin, RSAC President, George
Joseph M. Reagle, Jr., WC3 Group. Massachusetts Institute of Technology
With the huge increase of on-line users below the age of 18 caused by
the explosive growth of on-line services and access in the United States and other
technologically sophisticated nations, there has been an accompanying surge in the availability
of adult oriented content and services that has generated much concern for the protection of the
public and children, in particular, from exposure to inappropriate content. As a result, a
plethora of government policies and industry strategies have been proposed for dealing with this
Due to the competing interests between government control and regulation
of content on the one hand and the individual privacy, autonomy, and free speech on the other
hand, several industry coalitions have been formed to develop and endorse voluntary content
labeling and blocking systems that can be embedded in the very technologies creating the problem,
thus providing technological alternatives to censorship and regulation of the internet.
"The RSACi system was developed to provide parents
and consumers with objective, detailed information about the content of an Internet site,
allowing them to make informed decisions regarding site access for themselves and their
children. "óRSAC home page.
There are approximately 750,000 on-line users below the age of 18. A
recently pronounced goal in the United States for the National Information Infrastructure (Nll)
is to enable it to provide a level of education to all students that surpasses the highest
levels of education available today. Throughout the history of the Nll, education and research
were a key motivation for the development of the technology, first as the ARPANET, then the
Internet, the NREN, the Nll, and as part of the United States Department of Education project
GOALS2000. Many of the recent initiatives (from about 1989 onwards) have also focused a great
deal on the educational capabilities of these networks for K-12 (grade school) students. In
addition, a significant reason for the presence of young people on the Internet has been the
explosive growth of on-line services and Internet access, especially through services such as
America On-line (AOL), CompuServe, and Prodigy. Ironically, this surge of new users has also
brought an increase in the availability of adult-oriented content and services, much of which is
considered inappropriate for young people.
For those that find this alarming, the situation is further complicated
by other Internet controversies involving censorship, anonymity, and government control; the
decentralized nature of the Internet; and ill informed media attention. Hence, those who are
sincere about preventing censorship on the one hand and enabling legitimate parental control on
the other hand are left in a difficult position. One solution that has been proposed that will
meet the dual goal of non censorious content selection and screening has been content labeling.
Several different labeling schemes now available allow Internet content providers to either self
label or to be labeled by third parties with respect to any number of attributes. The areas of
greatest concern relate to attributes such as sex, violence, nudity, and language.
In 1994, Senators Joseph Lieberman (D-Conn.) and Herbert Kohl (D-Wis.)
chaired a number of Senate hearings regarding the increasing levels of violence in computer
games. To address these concerns and to deflect possible government regulation of this media,
two major content classification systems for interactive electronic entertainment were developed
in the United States These are known as the Recreational Software Advisory Council (RSAC),
developed by a coalition of over 25 organizations led by the Software Publishers Association
(SPA), and the Entertainment Software Rating Board (ESRB), sponsored by the Interactive Digital
Software Association (IDSA). Both were established in 1994.
Both groups are independent, non-profit organizations, but the two
content advisory systems are fundamentally different from each other. The RSAC system is a
content-based advisory system based upon self-disclosure using an interactive ratings package.
The ESRB system is an age-based advisory system based upon the decisions of a rating board. The
RSAC system has been used mainly by manufacturers of computer games, while the ESRB system has
been used for both video platform games such as Sega and Nintendo and computer games.
The RSAC System
To understand the RSAC labeling system, it is first necessary to
understand content advisory systems in general. The basis of any rating system is the way in
which it classifies content. Federman(1996) has used the terms "descriptive" versus
"evaluative" to characterize content labeling methodologies. In addition, Reagle et
al (1996) have used the terms "deterministic" versus "non-deterministic" to
characterize the labeling process itself. They also introduce the dimension of voluntary versus
mandatory to the rating process. These terms can be defined as follows:
descriptive - a rating system which provides a description of the
content of the labeled media and can provide a set of indicators about different content
evaluative - a rating system which makes a judgment about content using
a standard of harmfulness and typically provides a single rating indicator, usually based upon
deterministic - a rating process based upon some objective methodology
in which the final rating is the result of following the methodology;
non-deterministic - a rating process based upon the opinions of a
voluntary - the content producer is free to choose to rate or have
mandatory - the content producer is required to rate or to have product
rated by some other agency.
No rating system is purely descriptive or deterministic. Rather, each
system varies with respect to where it falls between extremes. Our usage of these terms is with
the understanding that no system is completely without bias or arbitrariness. Most people are
familiar with the Motion Picture Association of America (MPAA) rating system in which a board of
reviewers examines the content and then issues an evaluative, non-deterministic rating. The
process is non-deterministic because, while general rules of thumb may guide the reviewers'
decisions, the process itself is opaque and the results are sometimes at odds with other ratings.
It is evaluative because the ratings do not describe the content of the film, but what age group
may see the film.
In contrast to the MPAA, the RSAC system is voluntary with specific
deterministic criteria by which content is rated in a descriptive manner. Content producers, such
as video game makers, answer a detailed questionnaire (either in paper or electronic format)
about their content with respect to violence, nudity, sex, and language. RSAC then processes the
questionnaire, registers and returns the consequent rating to the company. The company is able to
use that label in advertising or on their product. The label consists of a number, between (0-4),
for each of the four categories. A rating of All (0) represents the minimum amount of
objectionable material. The system is represented in graphical form by a thermometer. The number,
or the temperature of the thermometer, informs the customer about the specific content of the
package as is demonstrated below in the RSAC advisories for violence:
RSAC Advisories on VIOLENCE
0: Harmless conflict; some damage to objects
1: Creatures injured or killed; damage to objects;
2: Humans injured or killed with small amount of blood
3: Humans injured or killed; blood and gore
4: Wanton and gratuitous violence, torture, and/or rape
The RSAC system does not say for whom the content is appropriate, it
merely describes the content with respect to characteristics that may be of concern to parents.
Since content providers fill out the questionnaire, it is a self-labeling and voluntary system.
To ensure public confidence in the RSAC system, the content producer is contractually obligated
to rate the content accurately and fairly. Every month a number of registered titles are randomly
sampled. Producers who have willfully misrepresented the nature of their content may be fined up
to $10,000 and may be required to recall their product from the shelves. Using this system,
RSAC has rated over 350 game titles with 94 companies including the popular "Myst" by Broderbund,
"Doom II" by id Software, and "Dark Forces" by LucasArts. Only two companies have ever requested
an appeal, and so far no suits have been filed for misrepresentation.
RSACi and PICS
During the year leading up to the passage of the Computer Decency Act at
the end of 1995, a number of Internet specific labeling activities occurred: 1)the U. S. Senate
Judiciary Committee heard testimony regarding the "Protection of Children From Computer
Pornography Act of 1995" (S. 892); 2) the Information Highway Parental Empowerment Group
(IHPEG), a coalition of three companies (Microsoft Corporation, Netscape Communications, and
Progressive Networks), was formed to develop standards for empowering parents to screen
inappropriate network content; 3) a number of standards for content labeling were proposed
including Borenstein's and New's Internet Draft "KidCode" (June 1995), and 4) a number of
services and products for blocking inappropriate content were announced, including Cyber Patrol,
CyberSitter, Internet Filter, NetNanny, SurfWatch, and WebTrack.
By August, much of the standards activity was consolidated under the
auspices of the World Wide Web Consortium (W3C) when the W3C, IHPEG, and twenty other
organizations agreed to merge their efforts and resources to develop a standard for content
selection. The result of the agreement is the Platform for Internet Content Selection (PICS)
standard that allows organizations to easily define content rating systems and enable users to
selectively block (or seek) information. It is important to stress that the standard is not a
rating system like MPAA or RSAC, but an encoding method for carrying the the ratings of those
systems. Those encoded ratings can then be distributed with documents or through third party
To aid the rating of large sites, labels may apply to whole directory
structures (hierarchies) of a Web site if the label is appropriate to all the content. Labels can
also be put on individual web pages or individual assets on a web page. This flexibility to rate
at different levels is referred to as the granularity of a particular rating. The
following example demonstrates a label for an RSAC label of langage (l=3), sex (s=2), nudity
(n=2) and violence (v=0):
on "1994.11.05T08:15-0500" until "1995.12.31T23:59-0000"
by "John Doe" ratings (l 3 s 2 n 2 v 0))
The PICS encoding specifies the rating service,
version number, the creation and expiration date, the page, the rater, and the ratings themselves
(other options may be specified but are not shown). Multiple labels can exist for any page.
Labels can be included in html documents within the meta-tag, they can be fetched from the http
server using the http get command, or they can be fetched from label bureaus. Hence, the author
of a homepage could include a variety of labels on the page itself (ie, the RSAC, MPAA, or
Golf-Fan systems). The http server on which the page resides could have a label or labels for
that particular page, and a third party label bureau like the "Good Housekeeping Seal of the Web"
could be queried for its opinion of the quality of the Web page.
The multiple distribution methods lead the authors of PICS to stress the
difference between rating systems and rating services. A rating service provides
content labels for information on the Internet. A rating service uses a rating system to describe
the content. For instance, the Unitarian rating service, and Christian Coalition rating service
could both use the MPAA rating system to describe what each thought was the appropriate age for
viewing the information.
In the rapidly evolving market of the Internet,
label systems and services have a significant stake in maintaining the public confidence in the
authenticity of their ratings. Malicious users who falsely label content could damage the
reputation of a service, a rating system, or PICS in general. To prevent the manipulation of
labels or the content to which they apply, PICS includes the capability to ensure the integrity
of a label using message integrity checks (MICS) and its authenticity using digital signatures.
In this way, compliant browsers can ensure that a document has not changed or been manipulated
since the labeling of the document and that the label is genuine. An important part of PICS
compliance is the requirement that PICS compatible clients read any label system definition from
a user accessible configuration file.
In April 1996, the RSAC rating system was
adapted for Internet content under the name RSACi using the PICS encoding standard. The RSACi
system is a Web-based questionnaire that queries the user about the content of a Web page or
directory tree based upon the content categories shown in Figure 1.
Figure 1: RSACi Content Advisory Categories
Upon completion of the questionnaire, a PICS meta-tag similar to the one
shown previously is returned to the user to be placed in the file header. There is also the
option to place the RSACi symbol on the web page. The service does not currently provide message
integrity checks or digital signatures. This service is currently free to anyone interested in
labeling the contents of a web site. It is expected that many of the attributes of the previous
RSAC system will be extended to RSACi, including the sampling of sites for labeling veracity and
compliance with the terms of service that a user agrees to before receiving the label.
Role of RSACi on the Internet
RSAC'S potential role in the labeling of Web content is complex. Just as
the production and distribution of Web content is more than a matter of placing an html document
on a server, RSACi and other PlCS-compliant rating systems are more than the voluntary insertion
of labels into documents by their creators. This simple act is only the first step in a
strategically and technically complex flow of information from origin to destination. This
section presents an analysis of RSAC'S relations to the production and distribution of
The production and flow of content is neither a vertically integrated
production chain - the same people who create the content do not necessarily provide the conduit
and browser - nor is it a purely distributed and segmented market. Although this market is
highly compartmentalized, the need for market efficiencies will drive the creation of strategic
alliances and standards between functional domains (such as on-line companies and browsers). This
consequently affects the delivery paths and quality of content. Included in this rapidly
evolving market are content producers, content hosts, other rating services, bots, search
engines, directories, filters, Internet Service Providers (ISPs), on-line services, protocol
developers, and browser/software companies (see Figure 2).
Content Producers: Commercial and non-commercial developers of
Internet information and web sites; they can range from single individuals to huge multinational
corporations. They may or may not have incentives on their own to provide content advisories
using a system like RSACi with the information they produce.
Web Farms/Content Hosts: Web farms and content hosts provide
server services to individuals and organizations that lack the means or interest to support their
own server. As a defense against charges of harboring objectionable material without proper
safeguards, these entities may encourage or require content developers to self label. For
example, CompuServe has endorsed the RSACi system through an implementation with CyberPatrol and
has encouraged individual and institutional content developers on its systems to employ the RSACi
Search Engines and Agents: Search engines and agents lay outside
of the direct path of content flow - one does not need a search engine. However, they often
provide an important value added service in channeling and selecting information. As such, search
engines may gain from being compatible to PICS because label information may improve searching
and indexing capabilities. This in turn may be a further incentive to content developers to adopt
RSACi and other PlCS-based rating systems.
Bots: Bots travel from site to site retrieving information of
interest to their owners. Since bots are personal, discriminatory spiders, their ability to
search and retrieve content with content labels has implications similar to that of search
engines As they gain the ability to communicate with each other (one could now call them
"agents"), PICS compliant labels could become the language for communicating about the
preferences of their owners.
Internet Service Providers (ISPs): Internet Service Providers
provide the means for connectivity from one point on the Internet to another. They have been
viewed by governments as convenient points of control. Legislators have been eager to make ISPs
legally responsible for the material they carry. Since ISPs have been a focus of much of the
controversy, they have been very interested in adopting or supporting content labeling systems
such as RSACi.
Figure 2: Structure of Content Flow on the Internet / World Wide
Browsers: Browsers are used to access information on the World
Wide Web. At the time this was written, Microsoft has incorporated the RSACi PICS implementation
into its most recent browser product, the Microsoft Internet Explorer. The value of such an
agreement for browser companies is that it addresses parental and institutional concerns about
restricting access to inappropriate material. One point of particular interest is that while
many of the PICS recommendations will be implemented by these and other browsers, the companies
have thus far declined to implement signature verification of the labels, an omission that may
put the trustworthiness of RSACi and other PlCS-compliant systems at risk.
On-line Services, Firewalls, Proxies, and Intranets: These
categories include both publicly accessible (AOL, CompuServe, Prodigy) and private/corporate
networks. This market has been particularly concerned with inappropriate material. While ISPs
have argued for common carrier status, on-line services have invested significantly in the
creation of a family orientated image. Hence, they have been the quickest adopters of content
selection and screen software - such as SurfWatch and CyberPatrol. Corporations are also
concerned about the inappropriate activity on their networks, and some are seeking the ability to
monitor or screen the activities of their employees using systems like NetShepard. Network
services such as Intranet servers, firewalls, and proxies are also points of control for the
dissemination of information to an organization.
The relationships between all of these entities may be looked at as more
of a plumbing system made of reservoirs (containing a variety of liquids), conduits (with a
variety of delivery capacities, operating pressures, and flow rates) and control systems
(upstream versus downstream regulation), with filtering mechanisms interposed at various points
in the plumbing. At each step, information may be redirected, collected, or amplified by a value
added service. Companies can take advantage of strategic opportunities for increasing market
efficiency and strengthening their position in the market. Given this interesting information
flow structure, the relevant question is which domains (and their boundaries) will be of the
greatest significance to labeling services?
Non-RSAC Rating Mechanisms
Some browser filtering systems have
similarities with the RSACi system in that they are PICS compliant and content descriptive, but
they may differ in significant ways. In the case of SafeSurf, itís rating system provides an
example of a PICS compliant system that is more evaluative than the RSACi system:
1) it includes an appropriateness rating with regard to age
2) it provides descriptive labels that have highly judgmental definitions
Other methods for content filtering include mechanisms like SurfWatch
which maintains lists of URL's with objectionable content. NetNanny has filters which block
objectionable material (such as curse words) in real time. Although non-RSAC filtering mechanisms
may be synergistic in some cases (meaning they may be able to cooperate at some levels), these
blocking technologies are different from the RSACi system because they:
1) require proprietary software
2) are labor-intensive
3) are not extendible to other areas of concern or interest
4) realize no economies of scale as the volume of content grows
5) employ standards that are obscure, somewhat arbitrary, and ultimately
Instability: The process of content screening and
selection will continue to be highly unstable for the near future. One must remember that it is
only within the past year that many of these standards and services became available to users of
the Internet. As an example of the tremendous pace of events, consider the case of CompuServe.
CompuServe has offered SurfWatch as part of its Internet in a Box, a suite of Internet access
applications including software from Spry. A competitor of Spry, SpyGlass, has now bought
Digital Signatures, Intellectual Property and Market Brand:
Elsewhere we discuss digital signatures with respect to the PICS standard. To engender pubic
trust in labeling systems, any organization like RSAC must ensure that its labels correspond to
the content, and that no unauthorized content developers use their labels and their respective
icons. On the Internet, while trademarked GIFS may be of some advantage in creating brand
recognition, the important "content" with respect to selection software will be the validity of
the rating that is accessed by the content seeker. How easily can this text be misappropriated?
If a digital signature is provided by RSAC and checked by the browsers for authenticity, it is
very difficult. If digital signatures are not incorporated, it can be misused very easily. One
could create such a label for an adult Web service without consulting the RSAC questionnaire, and
one may do so with malicious intent. Hence, simple encryption technologies would seem to provide
the only protection to widely-used labeling systems.
International Issues: The threat of governmental
censorship of electronic media provided the main impetus for the formation of RSAC and the
development of PICS. Until this point, we have only considered this issue with respect to the
United States. However, an oft cited characteristic of the digital realm is its global scope.
This can increase the difficulty of developing a content labeling system because the cultural
norms of violence, language, sexuality, and political freedoms differ across the globe, and there
are no cultural boundaries in cyberspace. Hence, content which may be considered appropriate
within one culture, may be considered inappropriate to others. Governments have been attempting
to legislate technical infrastructure requirements because of indecency or cultural concerns.
An immediate difficulty with evaluative labeling systems is that what may
be appropriate for one culture may be highly inappropriate for another. Fortunately, the PICS
system allows for multiple rating systems, services, and label bureaus. As an example of a
potential problem, consider the aversion for Nazi propaganda by the German government. Without
requiring draconian regulation of infrastructure or ISPs, Germany could require that all browsers
and lSPs use a labeling system and label bureau for filtering information pertaining to Nazism.
All PICS compliant browsers must be able to read label system definitions from a configuration
file, and the government could be responsible for developing the appropriate rating and labeling
services. However, this technique can also be extended even further by totalitarian nations such
as China to filter sensitive information, if all access is required to go through gateways that
employ filtering software.
Regardless, RSACi has an advantage in the international market because
systems that use straight forward content description rather than age appropriate evaluations
will have greater applicability and adaptability across multiple cultures. While there is some
cultural bias within the RSAC system, efforts to extend the system while keeping it very content
oriented would allow it to have international scope. Some countries may associate different icons
or names with the ratings differently, but the numeric value of a descriptive rating would stay
the same. Potentially, this would extend usage of the RSACi system beyond the United States to
become an international content labeling service.
A common saying among those that study the Internet is that, "three
months are one Web year." However, there are a number of observations one can make about content
labeling today. One observation is that this market is extraordinarily dynamic. Many of the
filtering companies discussed in this case study are one to three years old. Some of the
companies will likely go out of business, or be purchased or bought by larger content or
infrastructure organizations - as has happened with SurfWatch.
The dynamic nature of the Internet leads one to realize the importance of
balancing healthy competition with cooperation on sensitive social issues between the entities
discussed. With the chaotic development and flow of information on the Internet, it is also
important that standards such as PICS are being adopted at each level of information delivery to
bring some sense of order and control to concerned users. It is in this spirit of cooperation
that disparate organizations such as RSAC and Microsoft have worked together to use the PICS
encoding system to develop a content labeling and blocking mechanism and to make the system
available as widely as possible. The ultimate goal of such content advisory systems is to
provide a technical alternative to government regulation and censorship of the internet and to
empower members of the public to make informed decisions based upon their own value systems about
the appropriateness of content when accessing the Web.
Federman, Joel. Media Ratings: Design, Use and Consequences.
Mediascope, Inc. Studio City, CA. 1996.
Reagle, J. M., Jr., Evans,M. and Shareck, P. "RSACi Case
Study". Electronic Commerce and Marketing Course, MITís Sloanís School of Business
Management, Boston, MA. 1996.
RSAC Homepage, http://www.rsac.org/ and The
Recreational Software Advisory Council background web page
http://web.mit.edu/reagle/www/commerce/singles/rsac7.html /, 1996.
Much of the background information in this article was developed as
part of a case study on RSACi during an internship at RSAC by Joseph M. Reagle, Jr., Michael
Evans, and Patrick Shareck for an Electronic Commerce and Marketing Course at MITís Sloanís
School of Business Management, Boston, MA during the spring of 1996.