ELDR Focus Year

Dear Commissioner Malmström,
Dear Cecilia.

we are writing you regarding your recently published proposals for a directive to block access to websites that show images of child abuse. While we fully support you in your fight against this cruel and loathsome crime, we are deeply worried about this recent initiative of yours. We believe the approach of blocking websites is counterproductive and outright dangerous.

Blocking access to these websites does not make them go away. They are still on the internet and can be accessed by anybody capable of circumventing the filters. And since circumventing the filters is as easy as entering a new DNS server in your computer, it can be done in 10-15 seconds.

Your proposal requires the instalment of a censorship infrastructure. Experience tells us that such infrastructure can easily be misused and that it–once in place- will wet politicians’ appetite to extend it on other areas such as copyright violations, hate speech, and many more.

Even without misuse, the mechanisms employed to censor access and the technical infrastructure of the internet make it quite probable that when blocking some websites which you want to target, you also block numerous others, which are located with the same webhoster. This is what is called overblocking and which certainly is not desirable.

In our opinion, blocking websites is too easy an answer to a difficult problem and not an ambitious policy goal which really would benefit the victims or prevent further crimes. Instead of easy populist answers, the policy must be to remove pictures of child abuse from the Internet and to investigate the perpetrators. Priority must go to hunt the culprits down through international cooperation of law enforcement agencies.

Sexual abuse of children is one of the few crimes that is outlawed on a global scale. Experience from leaked blocking lists –such as from your own homecountry Sweden- indicates that most websites in question are located in the USA and Western Europe. Taking them down and getting information on who uploaded them is not black magic, but rather should be the standard.

Dear Cecilia, unlawful content should be deleted, not simply hidden by creating censorship infrastructure! Perpetrators should be investigated and jailed, not providing with shopping lists in form of leaked blacklists.

Instead of employing a useless but dangerous tool, please make sure that European law enforcement agencies finally start cooperating in fighting these awful crimes!

Kind regards,


Aloys Rigaut                      Alexander Plahr

President of LYMEC         Vice President of LYMEC