U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

31–737 

" ! COMMITTEE PRINT 109TH CONGRESS

2d Session 

COMMITTEE

2007

Print 109–F 

SEXUAL EXPLOITATION OF CHILDREN 

OVER THE INTERNET 

A STAFF REPORT 

PREPARED FOR THE USE OF THE 

COMMITTEE ON ENERGY AND 

COMMERCE 

U.S. HOUSE OF REPRESENTATIVES 

109TH CONGRESS 

JANUARY 2007 


E:\Seals\Congress.#13
(II) 

COMMITTEE ON ENERGY AND COMMERCE 

JOE BARTON, Texas, Chairman 

RALPH M. HALL, Texas 

MICHAEL BILIRAKIS, Florida 

Vice Chairman 

FRED UPTON, Michigan 

CLIFF STEARNS, Florida 

PAUL E. GILLMOR, Ohio 

NATHAN DEAL, Georgia 

ED WHITFIELD, Kentucky 

CHARLIE NORWOOD, Georgia 

BARBARA CUBIN, Wyoming 

JOHN SHIMKUS, Illinois 

HEATHER WILSON, New Mexico 

JOHN B. SHADEGG, Arizona 

CHARLES W. ‘‘CHIP’’ PICKERING, 

Mississippi, Vice Chairman 

VITO FOSSELLA, New York 

ROY BLUNT, Missouri 

STEVE BUYER, Indiana 

GEORGE RADANOVICH, California 

CHARLES F. BASS, New Hampshire 

JOSEPH R. PITTS, Pennsylvania 

MARY BONO, California 

GREG WALDEN, Oregon 

LEE TERRY, Nebraska 

MIKE FERGUSON, New Jersey 

MIKE ROGERS, Michigan 

C.L. ‘‘BUTCH’’ OTTER, Idaho 

SUE MYRICK, North Carolina 

JOHN SULLIVAN, Oklahoma 

TIM MURPHY, Pennsylvania 

MICHAEL C. BURGESS, Texas 

MARSHA BLACKBURN, Tennessee 

JOHN D. DINGELL, Michigan 

Ranking Member 

HENRY A. WAXMAN, California 

EDWARD J. MARKEY, Massachusetts 

RICK BOUCHER, Virginia 

EDOLPHUS TOWNS, New York 

FRANK PALLONE, JR., New Jersey 

SHERROD BROWN, Ohio 

BART GORDON, Tennessee 

BOBBY L. RUSH, Illinois 

ANNA G. ESHOO, California 

BART STUPAK, Michigan 

ELIOT L. ENGEL, New York 

ALBERT R. WYNN, Maryland 

GENE GREEN, Texas 

TED STRICKLAND, Ohio 

DIANA DEGETTE, Colorado 

LOIS CAPPS, California 

MIKE DOYLE, Pennsylvania 

TOM ALLEN, Maine 

JIM DAVIS, Florida 

JAN SCHAKOWSKY, Illinois 

HILDA L. SOLIS, California 

CHARLES A. GONZALEZ, Texas 

JAY INSLEE, Washington 

TAMMY BALDWIN, Wisconsin 

MIKE ROSS, Arkansas 

BUD ALBRIGHT, Staff Director 

DAVID CAVICKE, Deputy Staff Director and General Counsel 

REID P.F. STUNTZ, Minority Staff Director and Chief Counsel 

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

ED WHITFIELD, Kentucky, Chairman 

CLIFF STEARNS, Florida 

CHARLES W. ‘‘CHIP’’ PICKERING, 

Mississippi 

CHARLES F. BASS, New Hampshire 

GREG WALDEN, Oregon 

MIKE FERGUSON, New Jersey 

MICHAEL C. BURGESS, Texas 

MARSHA BLACKBURN, Tennessee 

JOE BARTON, Texas, 

(Ex Officio) 

BART STUPAK, Michigan 

Ranking Member 

DIANA DEGETTE, Colorado 

JAN SCHAKOWSKY, Illinois 

JAY INSLEE, Washington 

TAMMY BALDWIN, Wisconsin 

HENRY A. WAXMAN, California 

JOHN D. DINGELL, Michigan, 

(Ex Officio) 

(III)

LETTER OF TRANSMITTAL

U.S. HOUSE OF REPRESENTATIVES

COMMITTEE ON ENERGY AND COMMERCE

SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

JANUARY 2, 2007. 

To Members of the Committee on Energy and Commerce: 

We are pleased to forward to you the bipartisan report prepared 

by Committee staff entitled ‘‘Sexual Exploitation of Children Over 

the Internet.’’ This report summarizes what was learned during a 

one-year investigation by the Subcommittee on Oversight and Investigations. 

During nine days of public hearings, the Subcommittee found 

that the sexual exploitation of children over the Internet has 

reached a crisis point. Current estimates indicate that, at any 

given time, approximately 50,000 child predators are online searching for children. Commercial child pornography websites are increasing in number and may generate billions of dollars a year in 

revenue. To date, the National Center for Missing and Exploited 

Children’s (‘‘NCMEC’’) Child Victim Identification Program 

(‘‘CVIP’’) has reviewed to date over six million individual images related to apparent child pornography. 

Even more disturbing is the fact that the images now being 

found on the Internet are becoming more violent in nature, including depictions of rape and torture, and the children abused in these 

images are younger and younger. According to NCMEC, more than 

80 percent of the images found on the computers of those individuals caught with images of child sexual abuse include children who 

are 12 years old or younger. Thirty-nine percent of those persons 

caught with images of child sexual abuse possessed images of children younger than 6 years old and 19 percent of those persons arrested on child pornography charges between July 2000 and June 

2001 possessed images of children younger than 3 years old. While 

law enforcement is making great strides, additional resources must 

be dedicated to combating this problem, including the resources of 

the Internet Service Providers and financial services companies, as 

well as other firms whose systems have been exploited by child 

predators and commercial child pornography businesses. 

Already, the Subcommittee’s investigation has resulted in some 

important changes in the way the United States government and 

the private sector are combating the sexual exploitation of children 

over the Internet. These changes, which are described more fully 

in the text of the report, include the voluntary agreement of some 

Internet Service Providers to increase their data retention policies; 

the creation of the Technology and Financial Services Coalitions at 

NCMEC; increased cooperation internationally among law enforceVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000003 Fmt 07633 Sfmt 07633 E:\HR\OC\31737.XXX 31737
IV

ment agencies; the growing consensus that legislation may be necessary to aid law enforcement investigations of Internet child pornography; and passage in the House of Representatives of a provision that places certain network providers at risk if they fail to prevent the distribution of child pornography over their systems. We 

expect that this investigation will lead to additional reforms aimed 

at identifying child predators and preventing the transmission of 

child pornography images over the Internet. 

Respectfully submitted, 

ED WHITFIELD, Chairman, 

BART STUPAK, Ranking Member, 

Subcommittee on Oversight and Investigations. 

(V) 

C O N T E N T S 

Page 

I. Key Findings ........................................................................................................ 1 

II. Background ......................................................................................................... 6 

III. The Subcommittee Investigation ..................................................................... 13 

A. Law Enforcement Efforts to Combat the Sexual Exploitation of Children 

Over the Internet ................................................................................................. 14 

B. The Role of Internet Service Providers and Social Networking Websites 

in Combating the Sexual Exploitation of Children Over the Internet ............ 19 

C. The Role of the Financial Services Industry in Combating the Sexual 

Exploitation of Children Over the Internet ....................................................... 24 

D. The Psychology of Pedophiles and Child Predators ......................................... 30 

(1) 

SEXUAL EXPLOITATION OF CHILDREN OVER THE 

INTERNET 

BIPARTISAN STAFF REPORT FOR THE USE OF THE COMMITTEE ON

ENERGY AND COMMERCE

January 2007 

I. KEY FINDINGS

The Subcommittee on Oversight and Investigations examined 

several different components of the U.S. effort to combat the sexual 

exploitation of children over the Internet. Broadly, these entities 

included: (1) U.S. law enforcement; (2) the National Center for 

Missing and Exploited Children (‘‘NCMEC’’); (3) Internet Service 

Providers (‘‘ISPs’’); (4) the financial services industry; and (5) social 

networking websites. The Subcommittee also reviewed the efforts 

of several foreign governments and industries with respect to the 

sexual exploitation of children over the Internet, including the 

United Kingdom’s Home Office, the Internet Watch Foundation 

(‘‘IWF’’), the Child Exploitation and Online Protection (‘‘CEOP’’) 

Centre, Interpol, the European Union, the Dutch National Police 

Agency and Ministry of Justice, and Europol. The Subcommittee’s 

investigation also encompassed examining Internet safety educational programs, as well as exploring issues related to the psychology of pedophiles and online child predators in order to educate 

parents and children on how children can avoid becoming a victim. 

Key findings from the Subcommittee’s investigation include: 

• Crimes involving the sexual exploitation of children over the 

Internet are a growing problem in the U.S. and around the world, 

due to the ease with which pedophiles and child predators can 

trade, sell, view, and download images of child pornography from 

the Internet. 

• The number of sexually exploitative images of children over 

the Internet is increasing, the victims are becoming younger, and 

the substance of the images is growing more violent. 

• Commercial websites involving the sexual exploitation of children over the Internet are a growing and lucrative business. Current estimates indicate that on any given day there may be more 

than 100,000 sites with commercially available child pornography 

and that this is likely to be a multi-billion-dollar-a-year industry. 

• Together with the development of digital photography and web 

cameras (‘‘web cams’’), the ability to communicate anonymously 

over the Internet through online chatrooms, Instant Messaging 

services, and social networking websites has made it easier for 

pedophiles and child predators to contact children and to ‘‘groom,’’ 

or befriend and seduce, them. The Federal Bureau of Investigation 

(‘‘FBI’’) estimates that 50,000 child predators are online at any 

time searching for potential victims. 

2 

• The U.S. law enforcement effort to combat online child pornography involves several different federal agencies, with sometimes 

overlapping jurisdiction in these cases, as well as federally funded 

state law enforcement officers specially trained in these cases, referred to as Internet Crimes Against Children (‘‘ICAC’’) Task 

Forces. Each of these agencies performs vital investigative functions necessary to combat the sexual exploitation of children over 

the Internet. Federal law enforcement agencies either need increased funding or better prioritization and organization within 

their agencies, or both, specifically to combat child exploitation over 

the Internet, including additional agents dedicated to investigating 

these types of crimes, additional forensic laboratories and specialized training for investigating these cases. 

• The U.S. Postal Inspection Service (‘‘USPIS’’), which has a 

long-standing role in investigating cases involving the sexual exploitation of children, does not currently have statutory authority 

to issue administrative subpoenas in child exploitation cases, 

whereas other federal agencies, such as the FBI and Immigration 

and Customs Enforcement (‘‘ICE’’), now part of the Department of 

Homeland Security, do have this power. In order to further enhance the ability of the USPIS to investigate child sexual exploitation crimes, an amendment to 18 U.S.C. § 3486 should be considered by Congress to include authority for the Postmaster General 

to issue administrative subpoenas in criminal investigations involving child exploitation. 

• While the federal sentencing guidelines for criminal offenses 

relating to the sexual exploitation of children involve strict penalties, there is a wide discrepancy in state criminal codes both in 

covering all the substantive offenses, as well as, in sentencing. Because approximately 70 percent of all cases involving the sexual exploitation of children over the Internet are prosecuted at the state 

level, state legislatures should consider enhancing the penalties for 

these offenses and, in some instances, passing additional criminal 

laws that address the sexual exploitation of children over the Internet. 

• Given that the vast majority of prosecutions for crimes involving the sexual exploitation of children over the Internet take place 

at the state level, it is vitally important that state law enforcement 

officers are trained in investigating these crimes and have access 

to forensic laboratories. 

• Additional resources should be assigned on both the federal 

and state level to investigate and prosecute these cases. These resources include federal and state law enforcement agents and prosecutors, forensic laboratories and law enforcement and prosecutorial training. 

• The use of anonymizers and other encryption methods poses a 

substantial threat to law enforcement’s ability to investigate and 

bring charges against individuals who create, trade, or otherwise 

distribute images of child pornography over the Internet. Industry 

and law enforcement need to work together to develop methods 

that will allow law enforcement agents to access data related to 

child sexual exploitation cases while protecting customers’ needs to 

secure their private data unrelated to those cases. 

3 

• Currently, NCMEC houses a central database of known images 

of child sexual exploitation, which includes images found through 

investigations conducted by U.S. law enforcement, such as the FBI, 

ICE, and USPIS. It is important that all U.S. law enforcement 

agencies at the federal and state level have access to this centralized database to consult when investigating crimes involving the 

sexual exploitation of a child online. • ISPs that provide connectivity to the Internet do not retain 

Internet Protocol (‘‘IP’’) address data linked to a subscriber for the 

same amount of time. ISPs that provide content also have a wide 

variety of data retention times for IP addresses and subscriber information. • It is critically important to investigations involving the online 

sexual exploitation of children that law enforcement agents are 

able to access IP address data linked to a subscriber—particularly 

that information kept by ISPs that provide connectivity to the 

Internet. Pursuant to 18 U.S.C. § 2703(f), once a law enforcement 

agent sends a data preservation request to an ISP, the ISP must 

retain the data described in the request for 90 days, a period which 

can be extended an additional 90 days if law enforcement requests. 

Once a preservation request or subpoena has been issued, ISPs 

should make every effort to respond to law enforcement as expeditiously as possible. Without this information, the investigation is 

likely to hit a dead end and a child in danger may not be rescued. • Child pornography investigations often take months to develop, 

during which time critical data, such as IP addresses linked to a 

subscriber’s account, may be lost if the Internet Service Provider 

does not have an adequate retention policy. • Law enforcement agents who testified at the Subcommittee’s 

April 6, 2006 hearing supported a data retention policy of at least 

one year for IP address information. Due to the fact that harm may 

be occurring to a child in real-time during an investigation involving the sexual exploitation of children over the Internet, Congress 

should consider requiring ISPs that provide connectivity to the 

Internet to retain such IP address information linked to subscriber 

information necessary to allow law enforcement agents to identify 

the IP address being used to download or transmit child pornography images and only for so long as necessary to accomplish that 

purpose. 

• When law enforcement agents are able to identify harm that 

is occurring to a child in real-time, it is essential that they gain immediate access to the IP address and customer information that 

will allow them to locate and rescue that child. In response to a 

lawful request, ISPs must provide this information as quickly as 

possible after the administrative subpoena or other lawful request 

is received. 

• The transmission of a sexual exploitative image of a child over 

the Internet is a borderless crime because it cuts across state, federal and, in many cases, international jurisdictions. Federal and 

state law enforcement in the U.S. should consider implementing 

the Child Exploitation Tracking System, or ‘‘CETS,’’ developed by 

Microsoft and the Royal Canadian Mounted Police, to enhance communication about ongoing investigative subjects in cases involving 

the sexual exploitation of children between and among U.S. state 

4 

and federal law enforcement agencies. This program provides a 

platform for law enforcement agencies to track investigations that 

are being conducted across the country. This system also enhances 

the information-sharing critical to these types of investigations as 

well as reduces the likelihood of unnecessary duplicative efforts. 

Currently, CETS is being used by Canadian law enforcement officers throughout the territories, and the U.K., Spain, and Italy are 

beginning to implement this program among their law enforcement 

agents. • The current reporting statute for ISPs, 42 U.S.C. § 13032(B)(1), 

requires ‘‘electronic communication service’’ providers or ‘‘remote 

computing service’’ providers to report any ‘‘apparent’’ images of 

child pornography to NCMEC’s CyberTipline. Under the statute, it 

is ambiguous whether cellular phone carriers, social networking 

websites, and web hosting companies are required to report into 

the CyberTipline. • Congress should consider amending 42 U.S.C. § 13032(B)(1) to 

include mandatory reporting into the CyberTipline for cellular 

phone carriers, social networking websites, and web hosting companies. • Currently, 42 U.S.C. § 13032(B)(4) provides that only providers 

that are found to have ‘‘knowingly and willfully’’ failed to report an 

‘‘apparent’’ image of child pornography will be liable for civil penalties. To date, there have been no federal prosecutions under this 

statutory scheme. • Congress should consider ways to ensure that all ISPs are 

proactively searching for and promptly reporting the images of apparent child pornography on their networks. • Internet Service Providers should develop best practices and 

technology that will allow them to proactively search their networks and systems in order to identify the transmission of apparent child pornography images, including those transferred by peerto-peer networks. Such proactive efforts should not expose these 

companies to potential liability under the current reporting requirements found in 42 U.S.C. § 13032, criminal liability under 18 

U.S.C. § 2252 et seq., or other criminal and civil liability pursuant 

to Department of Justice antitrust enforcement actions. We recommend that the Department of Justice provide ISPs with guidance on these points to ensure that ISPs continue to cooperate with 

law enforcement agents on these investigations. These guidelines 

should also permit ISPs to perform proactive measures on their 

networks to block images of child pornography and, if the ISP is 

conducting such measures and blocking child pornography images 

on their networks, provide assurance to the ISP that they are not 

in violation of the crimes they are trying to prevent, such as possession and distribution of child pornography images. 

• Social networking websites are not enforcing their Terms of 

Use as vigilantly as they could and, thus, sexual predators are 

using these websites to find potential victims. 

• Social networking websites must take proactive steps to start 

cross-referencing state sex offender registry lists with those individuals that have profiles on their site, and notify law enforcement 

immediately of their findings for further investigation. States 

should consider enacting legislation, such as that proposed in the 

5 

Commonwealth of Virginia, to require sex offenders to provide their 

email address when registering as a sex offender so that social networking websites can use the registries to block those offenders 

from their websites. • Digital currencies are being used more frequently on commercial child pornography websites and provide another layer of anonymity to the purchaser and seller of these materials. Digital currencies on the Internet are not regulated anywhere in the world. • The U.S. Department of Treasury and the U.S. Department of 

Justice should propose legislation to Congress aimed at providing 

effective controls over the burgeoning digital currency industry 

over the Internet. • According to the Internet Watch Foundation (‘‘IWF’’) in the 

United Kingdom, approximately 50 percent of the child pornography content the IWF is discovering on the Internet appears to be 

hosted in the U.S. It is possible that this content may appear to 

be hosted in the U.S. but in fact is re-routed from another hosting 

company outside of the U.S. Currently, there is no registration requirement in the U.S. for web hosting companies and thus, it is difficult to know how many companies in the U.S. are hosting content 

over the Internet. It would benefit law enforcement investigations 

as well as provide uniformity in the number of web hosting companies that report to the CyberTipline if a registry for web hosting 

companies was created in the United States. • U.S. law enforcement investigations have uncovered instances 

where obvious child pornography domain names were registered 

with a domain registry company based in the U.S. It would benefit 

U.S. law enforcement’s effort to combat child pornography over the 

Internet if domain registry companies registered with an international body and a set of best practices were developed for domain 

registry companies. • The IWF provides a valuable service to ISPs in the U.K. by 

identifying child pornography websites to ISPs and the ISPs in 

turn block access to the sites identified by the IWF. In September 

2006, NCMEC announced that they would be working with law enforcement and the ISPs to provide a similar function to the IWF. 

Under this initiative, NCMEC will work with law enforcement 

agents to identify websites that are not the subject of a current investigation. ISPs that report into NCMEC will be advised of these 

websites and should block them. 

• Currently, NCMEC and the IWF do not share with each other 

the lists of child pornography websites that each has identified. 

Both organizations should do so and, if NCMEC requires statutory 

authority both to share and receive these lists, Congress should 

consider enacting such legislation. 

• ISPs in the United States should be encouraged to employ 

technology that allows them to block customer access to URLs containing child pornography images. In the U.K., ISPs and mobile 

phone companies use this technology to block a customer’s attempt 

to connect to certain URLs identified by the IWF as containing 

child pornography, regardless of where such websites are hosted. 

• The Department of Justice should explore working with 

NCMEC and its counterparts in international law enforcement to 

create a central database of website addresses and URLs that have 

6 

been identified as containing images of child pornography. This 

central database should be continuously updated by the member 

countries as additional websites and URLs containing child pornography are identified, and these URLs and addresses should be 

shared with the ISPs of the member countries so that they may 

block access to those websites. • The proliferation of child pornography images on the Internet 

demonstrates this is a global problem, with the content originating 

in many different countries. Under the current U.S. code, NCMEC 

is not explicitly authorized to transmit images of child pornography 

to international law enforcement agencies. In order to facilitate the 

sharing of images among law enforcement necessary to identify and 

rescue children throughout the world, Congress should consider 

adding a provision to 42 U.S.C. § 13032, 42 U.S.C. § 5573, and 

other relevant statutes to explicitly authorize NCMEC for law enforcement purposes to share images contained in their database 

with law enforcement agents in other countries. • Many pedophiles collect ‘‘series’’ of child pornography images 

and these images are circulated around the world thousands if not 

millions of times. Further, pedophiles tend to build large collections 

of sexually exploitative images of children. It is critical that every 

feasible measure be taken to stop the transmission of these images. 

• Some ISPs are taking proactive measures to block known images of child pornography that they become aware of on their network. This is done by taking a hash mark (digital fingerprint) of 

the images; however, an ISP’s database of known images is only a 

fraction of the size of NCMEC’s database. 

• Under the current U.S. code, NCMEC is not explicitly authorized to share information embedded in the digital fingerprint of an 

image to any ISP reporting into the CyberTipline. Congress should 

consider amending 42 U.S.C. §13032, 42 U.S.C. §5773, and other 

relevant statutes to grant explicit authorization for NCMEC to 

share the digital fingerprint of an apparent image of child pornography to ISPs that report into the CyberTipline. This will enable 

ISPs to block access to many more identified images of child pornography. • ISPs that report into the CyberTipline for law enforcement 

purposes should be granted a limited safe harbor provision for the 

‘‘transmission’’ or ‘‘possession’’ of child pornography as it pertains 

to receiving digital fingerprint information from NCMEC and performing proactive measures on its network to block images of apparent child pornography. 

II. BACKGROUND

Crimes involving the sexual exploitation of children, including 

child pornography, have long been a challenge for U.S. law enforcement. Until the advent of the Internet, the primary obstacle facing 

law enforcement agents investigating these cases was the sheer 

number of ‘‘purchasers’’ and ‘‘possessors’’ in the U.S. In addition, 

most of the producers of child pornography images were outside the 

United States, further hindering law enforcement agents’ investigations and prosecutions. 

Despite these challenges, by the late 1980s, U.S. law enforcement 

was able to significantly reduce the creation and distribution of 

7 

1 458 U.S. 757 (1982). 

2 495 U.S. 913 (1990). 

3 Hereinafter, a reference to the ‘‘Internet’’ means the World Wide Web. 

child pornography through the mails and other commercial avenues. These investigations were led by the U.S. Customs Service 

and the U.S. Postal Inspection Service, who focused their efforts on 

vigilantly monitoring the U.S. mail system and engaging in aggressive border inspection of incoming materials. Law enforcement officials attributed their success, in large part, to the fact that those 

who desired to purchase or trade child pornography images were 

constricted to a limited, and largely underground, distribution network. Up until the mid-1990s, the primary means of transporting 

and obtaining images of child pornography was through the mail 

system; individuals who sought to obtain child pornography images 

typically did so by responding to mail solicitations and advertisements in the back of magazines or newspapers. The stigma attached to this criminal conduct also limited the commercial sources 

for child pornography because the ‘‘community’’ of pedophiles did 

not have an easy way to communicate and distribute images among 

themselves. In addition, most producers did not have the capability 

of developing photographs or film within the privacy of their home 

and were forced to go to brick and mortar businesses, further 

heightening the chances of law enforcement agents intercepting the 

images. 

Law enforcement’s success in curbing child pornography during 

the 1980s was significantly bolstered by several Supreme Court decisions and by subsequent congressional legislation. In 1982, the 

U.S. Supreme Court held in New York v. Ferber 1 that possession 

of child pornography is not entitled to First Amendment protection 

and may be criminalized. In Ferber, the Court recognized that the 

use of children as subjects of pornographic material has long term 

harmful effects on the physiological, emotional and mental health 

of the child. The Ferber decision triggered the passing of additional 

state and federal criminal statutes which criminalized possession, 

manufacturing, and distribution of child pornography. Eight years 

later, the Supreme Court held in Osborne v. Ohio 2 that mere possession or viewing of child pornography may be criminalized. 

Although considerable progress was made in preventing the distribution of child pornography images through the mails, by the 

1980s and early 1990s, many pedophiles were already experimenting with the precursors to the World Wide Web,3

‘‘newsgroups’’ and Internet Relay Channels (‘‘IRC’’), in order to 

communicate and facilitate buying, selling and trading of images. 

At that time, U.S. law enforcement agents were not yet focused on 

these methods of communication and distribution of child pornographic materials. The growing reliance on the Internet, as well as 

the development of digital cameras, resulted in a significant increase in the amount of child pornography images and in the number of participants in this criminal enterprise. There are three 

main reasons for this: (1) the Internet provides an anonymous and 

quick method of transporting images, particularly since broadband 

was introduced; (2) the Internet provides an anonymous forum for 

pedophiles to communicate and connect with one another; and (3) 

digital photographs preclude the need for going to a photography 

8 

4 In Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002), the U.S. Supreme Court held that 

only child pornography involving actual children may be considered ‘‘child pornography’’ for purposes of criminal prosecution under 18 U.S.C. § 2252 et seq. Id at 254. Therefore, prosecutors 

in the U.S., unlike the rest of the world, have the burden of showing that an image is one of 

an actual child. Hence, the identification of minor victims in child pornography images is critical 

to proving a criminal violation in these cases. 5 In addition to NCMEC, Interpol, which houses a database of all known images of child pornography world-wide (including NCMEC’s images), also attempts to identify victims in the images. Interpol seeks to identify the country the child is from and then forwards the image and 

any information it can uncover from the image to the law enforcement agency in that country 

in the hopes that the child may be rescued. Like NCMEC, Interpol also tries to determine if 

a previously unidentified image of child pornography has been discovered. As of May 2006, 

Interpol had assisted in identifying and rescuing 426 victims of online child pornography from 

the 475,899 images it has collected in its database. 6The Cybertipline is primarily supported by funding from the Department of Justice. In addition, it receives some funding from the Departments of Homeland Security and State. 7 Ernie Allen Testimony, Subcommittee on Oversight and Investigations, ‘‘Sexual Exploitation 

of Children over the Internet: What Parents, Kids and Congress Need to Know about Child 

Predators,’’ April 4, 2006. 

shop to have the photographs developed, hence making the transmission of the images more private. 

Although it is impossible to know the exact number of child pornography images on the Internet, to date, the National Center for 

Missing and Exploited Children’s (’’NCMEC’’) Child Victim Identification Program (‘‘CVIP’’) has reviewed more than six million individual images related to apparent child pornography. NCMEC, as 

well as various U.S. law enforcement agencies, house a database of 

known apparent images of child pornography. The CVIP database 

is comprised, in part, of images submitted by United States law enforcement agencies. The purpose of this database is two-fold. First, 

the database can be used to determine if a child-victim has already 

been identified. Second, the database is used by U.S. law enforcement agents and prosecutors as a mechanism to establish whether 

the image is of a ‘‘real’’ child, as opposed to a virtual image.4 Currently, NCMEC has been able to identify and, with the assistance 

of law enforcement agents, rescue 880 minor children who were 

being subjected to sexually exploitative conduct.5

Just as the number of child pornography images available on the 

Internet has increased, the number of websites offering child pornography images is multiplying. Ernie Allen, President and Chief 

Executive Officer (‘‘CEO’’), of NCMEC, testified at the Subcommittee’s April 4, 2006 hearing, that NCMEC estimates there are 

100,000 websites offering images of child pornography. Arnold Bell, 

who currently heads the FBI’s Innocent Images Unit, which is 

charged with investigating child pornography and child exploitation 

crimes on the Internet, testified that a search on Google using a 

single search term revealed 130,000 child pornography websites. 

The number of reports to NCMEC’s Cybertipline,6 the entity created by Congress that is responsible for gathering reports from 

Internet Service Providers and the public regarding Internet child 

pornography, further demonstrates the growth of the sexual exploitation of children over the Internet. In its first year of operation 

in 1998, the Cybertipline received 4,800 reports of child pornography. Since then, reports to the Cybertipline have increased almost 400 percent to approximately 385,000 total complaints. In 

2004, the Cybertipline processed 112,000 reports. Currently, the 

Cybertipline handles an average of 1,500 reports a week of Internet 

child pornography.7

9 

While the explosion in the number of reports to the Cybertipline 

is a reflection of the growth in online child pornography, that number necessarily underestimates the number of child pornography 

images that exist on the Internet as not all Internet Service Providers in the United States report to NCMEC the apparent images 

of child pornography they find on their systems. In fact, only 303 

of the hundreds of ISPs operating in the United States are currently registered with and reporting to the Cybertipline. In addition, current federal law does not mandate that every entity that 

uncovers apparent images of child pornography on its networks or 

systems report them to NCMEC. Under 42 U.S.C. §13032, only 

those companies who provide ‘‘electronic communication service[s]’’ 

or ‘‘remote computing service[s]’’ must report ‘‘known’’ images of 

‘‘apparent’’ child pornography to the Cybertipline. Therefore, credit 

card companies, social networking websites, and cellular carriers 

who discover images of child pornography on their networks are 

not included in the mandatory reporting requirements of the statute, nor are they subject to any separate statutory reporting requirements. Also, under current law, ISPs and other related Internet providers are under no duty to proactively review or search 

their networks for images of apparent child pornography. Instead, 

current law only requires that they report apparent images of child 

pornography to NCMEC once they are made aware of them or otherwise discover them. 

Not only has the Internet contributed to an increase in child 

abuse images, it has also influenced the content of those images. 

According to law enforcement agents, the vast proliferation of child 

pornography images has driven a demand for ‘‘new’’ images of child 

abuse, thereby perpetuating the sexual abuse of children. Experts 

in Internet child pornography cases have explained that constant 

exposure to pornographic images of children on the Internet desensitizes the viewer. This leads the viewer to seek more violent images of children being sexually abused and also to seek images of 

younger victims in order to gratify his desires. Consequently, 

NCMEC reported that 39 percent of those persons caught with images of child sexual abuse had images of children younger than sixyears-old. In addition, NCMEC found that 19 percent of those persons arrested on child pornography charges between July 2000 and 

June 2001 possessed images of children younger than three-yearsold. 

As well as providing ready access to an increased number of child 

pornography images, the Internet has provided a new way for child 

predators and pedophiles to access their victims. Every day, more 

teenagers and children are online. The Pew Internet & American 

Life Project found in 2005 that 21 million teenagers now use the 

Internet, with 50 percent online daily. Teenagers not only ‘‘surf’’ 

the Internet, but they communicate with people they meet online 

through email, Instant Messaging services, and personal webpages 

on social networking websites such as MySpace, Xanga, or 

Facebook. Child predators often use these forms of communication 

to ‘‘groom’’ their potential child victims. By communicating with 

children regularly over the Internet, the child predator is able to 

befriend the child and make him or her comfortable with sharing 

personal information with someone he or she has not met face-toVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000015 Fmt 06633 Sfmt 06602 E:\HR\OC\31737.XXX 31737
10 

8Dr. Cooper and other physicians and experts in child sexual exploitation authored a treatise 

on child sexual exploitation and addressed the impact of sexual exploitation on child victims 

throughout their lives, See Sharon W. Cooper, Richard J. Estes, et al., Medical, Legal, & Social 

Science Aspects of Child Sexual Exploitation A Comprehensive Review of Pornography, Prostitution, and Internet Crimes, 2005. 9Dr. Sharon Cooper Testimony, Subcommittee on Oversight and Investigations, ‘‘Sexual Exploitation of Children over the Internet: What Parents, Kids and Congress Need to Know about 

Child Predators,’’ April 4, 2006. 

face. Eventually, these communications can become sexual in nature, often as a precursor to asking the child to meet the predator 

or to share sexual images of herself or himself. In fact, NCMEC released a study in August 2006 that found that one in seven children from the ages of 10 to 17 years-old report that they have received a sexual solicitation from someone they met on the Internet. 

Experts, including noted forensic pediatrician Dr. Sharon W. 

Cooper, agree that the physical and psychological harm suffered by 

the victims of Internet child pornography continues long after the 

abuse ends.8 In large part, this is because the image on the Internet exists in perpetuity, essentially re-abusing the child each time 

it is traded or sold and viewed by another pedophile. The image, 

which is essentially a crime scene, can never be destroyed or removed from the Internet, even if the perpetrator eventually goes to 

prison. The result is that the child is continually re-victimized each 

time someone clicks on his or her image, forwards it, or distributes 

it. This is the reason why victims of Internet child pornography 

like Masha Allen, a child victim who testified at the Subcommittee’s May 3, 2006 hearing, have pleaded for every effort to be made 

to prevent the distribution of child pornography images. As Ms. 

Allen stated in her testimony, the thing that upset her most about 

the abuse she suffered is that her images would be on the Internet 

‘‘forever.’’ 

The prevalence of online child pornography also has a distinct 

psychological impact on those who collect and possess it. According 

to psychologists who study the issue, individuals collect child pornography not only for sexual gratification but as a ‘‘plan for action.’’ 9 A study conducted by Dr. Andres C. Hernandez and published in a poster presentation entitled ‘‘Self Reported Contact Sexual Offenses by Participants in the Federal Bureau of Prisons’ Sex 

Offender Treatment Program: Implications for Sex Offenders’’ supports the notion that viewing child pornography is likely to lead to 

contact offenses involving a child. The study showed that, of the inmates who elected to participate in the Federal Bureau of Prisons 

Sex Offender Treatment Program, 76 percent of those who were 

convicted on charges related to Internet sex crimes, such as possession of child pornography or luring a child, had also committed sexual contact offenses against children. This conclusion was based on 

polygraph examinations of offenders who chose to enroll in Dr. Hernandez’s program. This link between viewing or possessing child 

pornography and molesting a child has been demonstrated in other 

studies as well, including one conducted by the United States Postal Inspection Service beginning in 1997. This study found that 33 

percent of the 2,433 individuals arrested by USPIS agents since 

1997 for using the U.S. mail and the Internet for the sexual exploitation of children had molested children. These findings are alarming and lend credence to the notice that exposure to images of child 

11 

10 A polygraph study currently being conducted in the Netherlands of convicted sex offenders 

further supports Dr. Hernandez’s finding that a link exists between possessing child pornography images and committing contact crimes against children. 11See Cassel Bryan-Low, ‘‘Dangerous Mix: Internet Transforms Child Porn Into Lucrative 

Criminial Trade—Company in Belarus Collected Millions From Pedophiles; A Landmark Prosecution—Agent’s Rendezvous in Paris,’’ Wall Street Journal, Jan. 17, 2006, at 1. 12The Internet Watch Foundation (‘‘IWF’’) and its ‘‘hotline’’ in the United Kingdom are similar 

to the NCMEC and the Cybertipline in the United States. Like the NCMEC, the IWF is responsible for gathering reports from ISPs and the public of Internet child pornography. However, 

the IWF, which partners with the U.K. Home Office and Department of Trade and Industry, 

receives most of its funding from U.K. Internet Service Providers, cellular or mobile companies, 

and the telecommunications industry. In addition, the IWF operates a ‘‘notice and takedown’’ 

system, by which it distributes the Uniform Resource Locator, or ‘‘URL,’’ of Internet child pornography images to the Internet Service Providers in the U.K. The providers then use various 

forms of technology to ‘‘block’’ the URLs of child pornography images, thereby preventing the 

public from accessing those images from the United Kingdom. 13 Under 42 U.S.C. § 13032, an ‘‘electronic communication service provider’’ is required to report ‘‘known’’ and ‘‘apparent’’ images of child pornography to the Cybertipline. It is unclear if 

web hosting companies would fall under the definition of ‘‘electronic communication service provider’’ and thus, may have no statutory obligation to report to the Cybertipline. NCMEC has 

informed Committee staff that a few web hosting companies do voluntarily report into the 

Cybertipline. 

pornography can, in fact, create child molesters, and hence, result 

in more child-victims.10

Of additional concern is that commercial Internet child pornography has become a lucrative and growing business. Although it is 

impossible to pinpoint the revenue generated by an illegal business, such as commercial child pornography, some estimates indicate that commercial child pornography may generate billions of 

dollars a year in revenue.11 To evade detection by law enforcement 

agents, the payment schemes employed by commercial child pornography websites are increasingly complex and involve the use of 

digital and electronic currencies and other forms of barter. Those 

individuals who sell child pornography images often set up fictitious businesses in order to obtain a merchant account for credit 

card processing. The technology supporting these websites is equally sophisticated. It is not unusual for websites to be registered 

using fictitious names and to use servers in several different countries to host images, thereby making it extremely difficult for law 

enforcement agents to identify the responsible individuals. Even so, 

according to several reports published quarterly by the Internet 

Watch Foundation (‘‘IWF’’) 12 in the United Kingdom, the United 

States appears to be hosting a majority of the child pornography 

content on the Internet. Law enforcement agents believe that this 

may be due to the fact that the United States has some of the fastest and most advanced Internet connectivity in the world, making 

U.S. servers especially appealing to commercial child pornography 

operators looking for servers to host their content. It is unclear, 

though, whether all of the websites that the IWF claims are hosted 

in the U.S. are, in fact, hosted here or whether a proxy server is 

being used. Currently, web hosting companies in the U.S. do not 

typically review any of the content on their servers nor do they report into NCMEC’s Cybertipline on a regular basis.13

Law enforcement agents at both the state and federal levels are 

working to combat the proliferation of sexually exploitative images 

of children over the Internet. In the U.S., there are four primary 

law enforcement agencies which investigate the sexual exploitation 

of children over the Internet. These agencies are: (1) the Federal 

Bureau of Investigation (‘‘FBI’’); (2) Immigrations and Customs Enforcement (‘‘ICE’’); (3) the U.S. Postal Inspection Service (‘‘USPIS’’) 

12 

and (4) the Internet Crimes Against Children (‘‘ICAC’’) Task 

Forces. Currently, agents from each of these law enforcement agencies as well as the U.S. Marshals Service are assigned to NCMEC 

and assist in investigating the tips reported to the Cybertipline. All 

of these law enforcement entities have jurisdiction over cases involving the sexual exploitation of children; however, each has a primary mission and jurisdiction that dictates what types of cases the 

agents will work. 

Within the FBI, the Innocent Images National Initiative is responsible for investigating Internet child pornography cases. Fifteen agents and 22 analysts are assigned to this unit, based in 

Calverton, Maryland. The FBI also has agents in field offices 

around the country that may be assigned a child sexual exploitation case; however, no field agents exclusively work on child sexual exploitation cases over the Internet. For cases with an international nexus, the Cyber Crimes Center of ICE has jurisdiction. 

Currently, 10 to 12 agents within the CyberCrimes Center are 

dedicated to investigating exclusively child exploitation crimes, and 

in the field, there are the equivalent of 221 ICE agents dedicated 

to Operation Predator cases, an initiative developed by the Department of Homeland Security and ICE to identify, investigate, and 

arrest child predators. Finally, 35 postal inspection agents are 

dedicated to investigating Internet child pornography cases that involve the use of the mails on a full-time basis. 

On the state level, the ICACs are federally funded and trained 

state and local police officers dedicated to investigate crimes related to the sexual exploitation of children over the Internet. The 

ICACs are funded primarily through the Department of Justice’s 

Office of Juvenile Justice and Delinquency Prevention (‘‘OJJDP’’) 

and work cooperatively with their counterparts in federal law enforcement. During fiscal year 2006, Congress appropriated 

$14,315,000 to OJJDP for ICAC Task Force operations. In addition 

to ICAC trained officers, there are also many state and local law 

enforcement officers that work on online child sexual exploitation 

cases, both in proactive and reactive investigations. 

Recently, the Department of Justice (‘‘DOJ’’) announced a series 

of initiatives aimed at investigating and prosecuting the sexual exploitation of children over the Internet. In February 2006, Attorney 

General Gonzales announced ‘‘Project Safe Childhood.’’ The goal of 

the project is to coordinate efforts between state, local, and federal 

law enforcement authorities when investigating Internet crimes 

against children. On May 17, 2006, Attorney General Gonzales announced that Project Safe Childhood would be implemented on a 

national level. The initiative requires each United States Attorney 

to designate a Project Safe Childhood coordinator within two weeks 

and to begin meeting with local partners to develop a plan for their 

district within 90 days. In addition, U.S. Attorneys must partner 

with their local ICACs and federal law enforcement agents in order 

to increase federal involvement in child pornography cases and to 

train state and local enforcement and educate local communities. 

On April 21, 2006, DOJ submitted proposed legislation to Congress to amend 42 U.S.C. § 13032. DOJ’s proposed amendment 

would triple the fines imposed on electronic communications services providers who knowingly and willfully fail to report to 

13 

NCMEC’s Cybertipline, as required by 42 U.S.C. § 13032. Under 

the proposed legislation, delinquent providers would be assessed 

$150,000 for an initial violation and $300,000 for each subsequent 

violation. In addition to increasing fines for those who knowingly 

and willfully fail to report, on May 15, 2006, DOJ proposed a second piece of legislation that would impose fines on providers who 

negligently fail to report. The current statute requires that the provider ‘‘knowingly and willfully’’ failed to report. Under the proposed 

legislation, the provider would be fined $50,000 for the initial, negligent failure to report and $100,000 for each subsequent violation. 

Under the current statutory scheme, DOJ has never prosecuted a 

provider. Neither proposal was enacted by the House or Senate. 

III. THE SUBCOMMITTEE INVESTIGATION

In January 2006, the Subcommittee on Oversight and Investigations initiated its investigation of the sexual exploitation of children over the Internet to examine the scope of the problem; the approach of law enforcement; the entities involved; and ways to prevent the proliferation of child pornography on the Internet. The investigation was prompted by an article in The New York Times by 

Kurt Eichenwald entitled ‘‘Through his Webcam, a Boy Joins a Sordid Online World.’’ The article featured the story of Justin Berry, 

now a 19-year-old young man. Beginning at the age of 13-years-old, 

Justin was repeatedly victimized by child predators who contacted 

him over the Internet when they saw his image on a webcam, 

which he had received as a free promotional gift to subscribers of 

Earthlink. In addition to describing the abuse he suffered at the 

hands of the individuals whom he met online, Justin also described 

how some of these individuals encouraged him and even assisted 

him in developing and operating commercial pornography websites 

featuring sexual images and videos of Justin. In that article, Justin 

also stated that he provided prosecutors in the Department of Justice’s Child Exploitation and Obscenity Section (‘‘CEOS’’), and the 

FBI with specific information about those individuals involved in 

the commercial child pornography business, including the names of 

the individuals who helped him host the websites and process payments. As a result of the information Justin voluntarily provided 

to DOJ, he was granted immunity. According to the article, Justin 

was concerned about how DOJ and the FBI handled the information that he provided to them about a commercial child pornography enterprise. 

Based on the Committee’s jurisdiction over matters related to the 

Internet, telecommunications and consumer safety, Committee 

leadership instructed staff to review U.S. law enforcement efforts 

to combat online child pornography, the role of NCMEC as a conduit between law enforcement and private industry, and how private industry is responding to this threat against children over the 

Internet. As the extent of this criminal activity became clear, the 

investigation was expanded to include all methods by which the 

Internet was used in the sexual exploitation of children. 

14 

A. Law Enforcement Efforts To Combat the Sexual Exploitation of Children Over the Internet 

In addition to investigating Justin Berry’s allegations regarding 

the Justice Department and FBI, the Committee also began investigating information reported by Kurt Eichenwald with regard to 

the ease with which he could locate images of child sexual abuse 

on the Internet and the commercial enterprises that are associated 

with child exploitation over the Internet. To that end, Committee 

staff met with and interviewed various law enforcement agencies 

and other groups to gain a better understanding of the scope of the 

problem and how they are working to combat the proliferation of 

sexually exploitive images of children over the Internet. In particular, Committee staff met with officials from NCMEC and visited NCMEC’s offices in Alexandria, Virginia, in order to better understand how the Cybertipline operates. 

Committee staff also visited the offices of the federal law enforcement agencies that are responsible for investigating the online exploitation of children, including the FBI’s Innocent Images unit and 

ICE’s Cyber Crimes Center, and met with agents and officials from 

the U.S. Postal Inspection Service. Committee staff learned that 

while there is an active federal law enforcement effort to combat 

Internet child pornography, the vast majority of investigations—approximately 70 percent—take place at the state or local level. For 

this reason, Committee staff also interviewed several state ICAC 

Task Force investigators. 

Interviews and meetings with law enforcement officials and 

agents revealed several key factors which have contributed both to 

the proliferation of child abuse images on the Internet as well as 

the obstacles law enforcement agents face when they try to identify 

the individuals who possess and distribute these images. First, and 

perhaps most daunting, is the number of child abuse images on the 

Internet. As mentioned previously, United States law enforcement 

estimates that there are approximately 3.5 million known child 

pornography images online. In addition, the individuals who trade 

and distribute child pornography images use sophisticated technology and other means to evade identification by law enforcement 

agents. For example, law enforcement agents said that individuals 

who download images can use ‘‘anonymizers’’ or encryption technology which makes it difficult to find the individuals, much less 

prove that they possessed or downloaded the images. Law enforcement agents also stated that most Internet Service Providers often 

do not retain Internet Protocol, or IP, address data for a sufficient 

period of time. Without this data, law enforcement agents are unable to identify the individual at a certain IP address who has 

downloaded or distributed child pornography. Further, law enforcement agents are concerned that the response time of ISPs to law 

enforcement inquiries or subpoenas seeking the identity of a customer assigned to a particular IP address varies and is not always 

timely. Dr. Frank Kardasz, a member of the Arizona ICAC Task 

Force, testified that a two-day response time to law enforcement 

subpoenas for IP address information would be ideal. 

Law enforcement officials also explained that the payment 

schemes used by commercial child pornography websites are becoming increasingly complex and sophisticated, again, as a method 

15 

14 Immediately following the hearing, Mr. Gourlay’s residence was searched pursuant to a 

search warrant obtained by the Michigan Attorney General. Just one month later, on May 15, 

2006, Mr. Gourlay was arrested on 10 felony counts related to the allegations made by Justin 

Berry during the Subcommittee hearing, including Criminal Sexual Conduct, Child Sexually 

Abusive Activity, Using a Computer to Commit a Crime, Distribution of Child Sexually Abusive 

Activity and Accosting a Child for Immoral Purposes. On September 19, 2006, Mr. Gourlay was 

charged with 18 additional felony counts of Criminal Sexual Conduct. The charges are currently 

pending before a Michigan state court. 

to evade detection. One example cited by law enforcement officials 

and by NCMEC is the increasing use of digital currencies as a 

method of payment on commercial child pornography websites. 

Payment by digital currencies makes it more difficult for law enforcement agents to trace the payment, and thus, the source. 

In addition to examining how law enforcement officials investigate and prosecute those who exploit children over the Internet, 

Committee staff reviewed and analyzed existing federal law with 

regard to criminal penalties for possession, creation, and distribution of child pornography. A review of federal and state law showed 

that while penalties for federal charges can be quite severe—for example, the federal sentence for distribution of child pornography is 

up to 20 years, with a five year minimum mandatory sentence, per 

image—there is great disparity among state penalties for crimes involving child pornography. Because the vast majority of these online child sexual exploitation cases are prosecuted on the state 

level, it is imperative that all states consider adopting strict sentencing schemes for these crimes and laws that clearly address the 

online environment in which these crimes are now committed. For 

example, all states should consider adopting laws that make clear 

that sexual solicitation of a person believed to be a minor online 

is a felony offense, with automatic jail time. In addition, Committee 

staff learned that possession of child pornography currently is not 

a felony offense in all 50 states. This needs to be considered immediately by the states. 

The Subcommittee on Oversight and Investigations held its first 

two days of hearings on the issue of sexual exploitation of children 

over the Internet on April 4 and 6, 2006. This hearing, entitled 

‘‘Sexual Exploitation of Children Over the Internet: What Parents, 

Kids and Congress Need to Know about Child Predators,’’ focused 

on explaining the scope of the problem, U.S. law enforcement’s approach to investigating and prosecuting child pornography crimes, 

the impact of sexual exploitation on its victims, and efforts by 

Internet safety groups to educate parents and children. 

On April 4, the witnesses included Mr. Ernie Allen of NCMEC; 

a child victim, Justin Berry; The New York Times reporter Kurt 

Eichenwald; Dr. Sharon Cooper, a forensic pediatrician specializing 

in child sexual exploitation; and Ms. Teri L. Schroeder and Ms. 

Parry Aftab, advocates for Internet safety from i-Safe and Wired 

Safety, respectively. In addition, Mr. Kenneth Gourlay of Michigan, 

whom Justin Berry had identified as the man who first molested 

him after meeting him online, appeared pursuant to Committee 

subpoena. Mr. Gourlay asserted his Fifth Amendment right against 

self incrimination and refused to testify in response to the Subcommittee’s questions.14

Testifying on April 6 were Mr. William E. Kezer, Deputy Chief 

Inspector, and Mr. Raymond C. Smith, Assistant Inspector in 

16 

Charge, on behalf of the U.S. Postal Inspection Service; Dr. Frank 

Kardasz, Phoenix Police Department Sergeant, and Mr. Flint Waters, Lead Special Agent of the Wyoming Division of Criminal Investigation, on behalf of the Arizona and Wyoming ICAC Task 

Forces, respectively; Mr. John P. Clark, Deputy Assistant Secretary, and Mr. James Plitt, Director of the Cyber Crimes Center, 

on behalf of the Department of Homeland Security, Immigration 

and Customs Enforcement; and Mr. Greer Weeks, an expert in 

state child pornography laws and sentences. In addition to these 

witnesses, in order to better understand the approach of law enforcement to investigating and prosecuting crimes involving the online sexual exploitation of children, the Committee requested that 

the Honorable Alice S. Fisher, the Assistant Attorney General for 

the Criminal Division, and Mr. Andrew Oosterbaan, Chief of the 

Child Exploitation and Obscenity Section, testify on behalf of the 

Justice Department, and that Mr. Raul Roldan, Section Chief, 

Cyber Crime Section of the Cyber Division, and Mr. Arnold E. Bell, 

Unit Chief, Innocent Images Unit, testify on behalf of the FBI. In 

lieu of the requested witnesses, the Department of Justice and the 

FBI designated Mr. William Mercer, Principle Associate Deputy Attorney General and United States Attorney for the District of Montana, and Mr. Chris Swecker, Acting Assistant Executive Director 

of the FBI, to testify on their behalf. Subsequently, at the Committee’s hearing on May 3, 2006, Ms. Fisher, Mr. Roldan, and Mr. Bell 

appeared before the Committee and testified about their departments’ approach to sexual crimes against children over the Internet. 

On May 3, 2006, the Subcommittee held a third day of hearings 

dedicated to law enforcement’s approach to online child pornography crimes, specifically, the efforts of the FBI and Department 

of Justice. As mentioned previously, testifying on behalf of the Justice Department was Ms. Fisher and, on behalf of the FBI, Mr. 

Roldan and Mr. Bell. The witnesses described recent initiatives by 

the Justice Department to combat Internet crimes against children, 

including Project Safe Childhood, prosecutions by the Child Exploitation and Obscenity Section (‘‘CEOS’’) of DOJ, and FBI investigations. In addition, Ms. Fisher, Mr. Roldan, and Mr. Bell were asked 

to address their departments’ action with respect to charges made 

and information provided by Justin Berry. In large part, the witnesses testified that they were not able to respond to questions 

about Mr. Berry’s allegations due to ongoing investigations related 

to his case. 

In addition, the Subcommittee also heard testimony from Ms. 

Masha Allen, a 13-year-old girl, who was adopted from Russia 

when she was 5 years old by a divorced man from Pittsburgh, 

Pennsylvania, named Matthew Mancuso. Masha was accompanied 

at the hearing by her attorney, James Marsh; her advisor, 

Maureen Flatley; and, at her request, television news reporter 

Nancy Grace. From the time she arrived in the U.S. with Mancuso, 

she was repeatedly sexually assaulted by him and images of her 

abuse were posted on the Internet by Mancuso. After approximately five years of sexual abuse, Masha was rescued as the result 

of an undercover Internet investigation by the Chicago Police Department. Mancuso is currently serving a 30-year federal sentence 

17 

and will then serve a consecutive state sentence on charges related 

to his abuse of Masha. In addition to describing her harrowing ordeal at the hands of Mancuso, Masha also raised questions about 

the conduct of the U.S. adoption agencies that worked with 

Mancuso to place a 5-year-old girl with him. The Subcommittee 

held a hearing on September 27, 2006 to follow-up on Masha’s 

questions and concerns. 

The April and May hearings revealed important information 

about the scope of the problem, law enforcement’s efforts to fight 

it, and the efforts to educate parents and children about the dangers that exist online. In short, the sexual exploitation of children 

over the Internet is a problem of great urgency. As Mr. Ernie 

Allen, President and C.E.O. of NCMEC, testified, sexual abuse images of younger children and even toddlers are becoming more 

prevalent over the Internet. For example, on March 15, 2006, the 

Department of Justice and ICE announced a bust of an Internet 

child pornography ring in the United States, Canada, the United 

Kingdom, and Australia in which the images seized included a live, 

streaming video of an infant who was less than 18 months old 

being raped by an adult male. 

It is also clear that while both federal and state law enforcement 

agents are actively pursuing investigations of online child pornography, law enforcement either needs additional resources or better 

prioritization and organization within their agencies, or both, to 

allow additional funding for personnel, forensic assistance, and 

training for state agents. In addition, law enforcement agents explained that the data retention policies of some Internet Service 

Providers are inadequate and, in some cases, their failure to retain 

for a sufficient period of time the information that links an IP address to an Internet customer has prevented law enforcement 

agents from identifying child predators and rescuing children. For 

example, Mr. Flint Waters of the Wyoming ICAC testified that, in 

one case, an ICAC investigator intercepted the transmission over 

a peer-to-peer network of a video showing the rape of a 2-year-old 

child and was able to trace the video to a computer in Colorado. 

When the ICAC agent approached the Internet Service Provider, 

Comcast, to request the customer information for the IP address in 

Colorado, Comcast informed the agent that it had not retained the 

customer records for that address. As of the date of the hearing, 

to Mr. Waters’ knowledge, the child in the video had not been identified. 

Following the April hearings, Committee staff traveled to the 

United Kingdom and to Interpol headquarters in France to meet 

with government, law enforcement, and industry officials to discuss 

how they are working to combat Internet child pornography. In the 

United Kingdom, Committee staff met with officials from the 

United Kingdom’s Home Office, the equivalent of the United States 

Department of Justice; the Department of Trade and Industry; the 

Internet Watch Foundation; members of the mobile telephone industry; the Internet and telecommunications industries; and child 

advocates. In addition, Committee staff met with the Chief Executive and Staff of the Child Exploitation and Online Protection Centre (‘‘CEOP’’), a new quasi-government organization that partners 

law enforcement with the business sector, charities, and other orgaVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000023 Fmt 06633 Sfmt 06602 E:\HR\OC\31737.XXX 31737
18 

15The website of the IWF can be found at www.iwf.org.uk. 16 Internet Watch Foundation 2006 Half Yearly Report. 

nizations. CEOP is dedicated solely to fighting and investigating 

sexual crimes against children, particularly Internet sex crimes. 

Committee staff also traveled to Lyon, France to meet with agents 

from Interpol, the international police organization, in order to 

learn more about Interpol’s database of child abuse images and its 

efforts to identify and rescue the children abused in these images. 

The meetings with British officials and with Interpol revealed 

important differences between the approach of U.S. law enforcement and its international counterparts. For example, the United 

Kingdom employs a ‘‘notice and takedown’’ approach in fighting 

child pornography. Under this approach, which was first implemented by some companies in 2004, Internet Service Providers voluntarily agreed to block access to URLs identified by the IWF as 

containing images of child pornography.15 British officials attribute 

the fact that only .2 percent of websites containing child pornography images are currently hosted in the U.K.—down from 18 percent in 1997—in part to this blocking approach, whereas the IWF 

has found that 51.1 percent of websites containing child pornography content are hosted in the United States.16 According to these 

officials, in the United States, websites with child pornography are 

not immediately taken down after law enforcement learns of them; 

instead, the websites are left up so that law enforcement agents 

have an opportunity to investigate and prepare charges against the 

individuals operating the site. 

A recent proposal by NCMEC supports a dual approach of furthering law enforcement investigations and shutting down the 

websites. NCMEC, which announced the initiative at the Subcommittee’s September 26, 2006 hearing, explained that they are 

working with law enforcement and the industry to devise a system 

that is similar to the U.K.’s notice and takedown model. Notably, 

this approach was suggested by NCMEC after the Committee expressed an interest in setting up a system in the U.S. similar to 

the IWF’s ‘‘notice and takedown’’ approach to child pornography 

websites. According to NCMEC’s proposal, law enforcement agents 

will first be notified of child pornography websites so that they 

have the opportunity to investigate the website and gather evidence. Then, if the law enforcement agents agree, NCMEC will forward the Internet address for the website to the ISPs so that the 

ISPs may block the website on their system. By involving law enforcement from the beginning, the NCMEC approach might avoid 

an issue faced by those systems that primarily rely on notice and 

takedown to put an end to the proliferation of online child pornography: child pornography websites move Internet addresses constantly to avoid detection and, if subject to a takedown, simply 

move their content to a new Internet address. In addition, peer-topeer systems, rather than websites, are becoming a popular way to 

trade child pornography images because these systems make it difficult for law enforcement agents to trace and intercept the transmission of images. A notice and takedown approach is largely ineffective against this type of technology. 

19 

The cooperation and sharing of ideas among U.S. and international law enforcement, NCMEC, the IWF, and other international groups must continue so that the fight against online child 

pornography can be won. NCMEC’s recent notice and takedown 

proposal is a prime example of how law enforcement can improve 

its tools and methods by learning from the experience of other 

countries. The experience of foreign industry in preventing child 

pornography can also be a resource for U.S. businesses. In the 

United Kingdom, British telecommunications companies and some 

mobile telephone companies that provide connectivity to the Internet have developed systems intended to prevent their customers 

from connecting to child pornography websites. 

B. The Role of Internet Service Providers and Social Networking Websites in Combating the Sexual Exploitation 

of Children Over the Internet 

In order to examine the role of the U.S. Internet Service Provider 

industry in the fight against child pornography, the Subcommittee 

convened two days of hearings on June 27 and 28, 2006 entitled 

‘‘Making the Internet Safe for Kids: The Role of ISPs and Social 

Networking Sites.’’ The Internet Service Providers testifying at this 

hearing included representatives from America Online (‘‘AOL’’), 

Microsoft, Google, Yahoo, Earthlink, Comcast, and Verizon; the social networking websites included MySpace, Xanga, and Facebook. 

Commissioner Pamela Jones Harbour of the Federal Trade Commission, and Diego Ruiz, Deputy Chief, Office of Strategic Planning 

and Policy Analysis, of the Federal Communications Commission, 

also testified about the role of their agencies in regulating Internet 

companies. 

Also testifying was television news journalist Chris Hansen, who 

led a multi-part investigative series that aired on Dateline NBC, 

entitled ‘‘To Catch a Predator.’’ The series focused on the activities 

of child predators on the Internet and showed how actual child 

predators contacted and groomed individuals they believed were 

potential child- victims. The individuals that the predators communicated with online were actually adult volunteers for an online 

watch-dog group, Perverted Justice. The adult volunteers posed online as 13- or 14-year-old children who were home alone and receptive to an in-person meeting with an adult whom they had met on 

the Internet. In his testimony, Mr. Hansen described the online 

grooming process he observed between child predators and the 

‘‘children’’ and noted how quickly the predator would turn the conversation into one overtly sexual in nature. Mr. Hansen also noted 

that the individuals who were identified and arrested as a result 

of the series—at the time of the hearing, 98 of whom had been 

charged criminally—defied characterization. They came from all 

walks of life and, upon meeting them, many did not seem to be particularly dangerous or suspicious. 

The primary issue addressed at these hearings was whether the 

Internet industry as a whole was doing enough proactively to prevent the transmission of child pornography images over their systems and networks. In addition, the Committee was interested in 

whether the policies of these companies, particularly the companies 

who provide content and accept advertising on their websites, 

20 

17 At this time of the hearing, AOL retained the data that links an IP address to a customer’s 

name for 90 days; Earthlink for seven years; Comcast for 180 days; Verizon for nine months. 

clearly prohibited content or advertising that involves the sexual 

exploitation of children. Each company discussed the measures 

they take to keep child pornography from being either hosted or 

distributed over their systems. The type of approach adopted by a 

company is dictated by several factors including: (1) the type of 

service provider they are, that is, whether the company provides 

‘‘content,’’ like Yahoo!, or is primarily a ‘‘pipeline,’’ like Verizon; (2) 

the types of products they offer on their network, such as email, 

instant messaging (‘‘IM’’), news groups, and search functions; (3) 

the size of their customer base; and (4) the extent to which the 

company expends resources in both reactive and proactive measures to review its network for violations of the law, its ‘‘Terms of 

Use’’ or both. 

AOL, a content provider with paid subscribers, explained that it 

creates a ‘‘digital signature’’ of apparent child pornographic images 

it finds on its network and then collects those signatures in a digital library. Any image files transmitted over AOL’s network are 

compared to the digital library. In this way, AOL can identify and 

block the distribution of images that it has previously identified as 

child pornography. Other providers, like Yahoo! and MSN, use filters as well as algorithms in an attempt to identify child pornography images transmitted over their networks and shared through 

their programs, such as chatrooms. 

Network service providers, or ‘‘pipelines,’’ like Verizon or 

Comcast, are in a somewhat different position. Unlike content providers, network service providers mainly provide access to the 

Internet but do not provide other services like chat, groups, or 

search functions. At this point, network service providers do not 

employ the proactive measures that content providers use to identify the transmission of child pornography images over their networks. Whether this is due to legal or technical constraints their 

efforts with respect to child pornography images are mostly reactive. As some pipeline providers explained to the Subcommittee, 

the primary way they discover child pornography images on their 

networks is by customer reports or complaints, which the pipeline 

provider then forwards to NCMEC. Pipeline providers also respond 

to law enforcement agents’ requests and subpoenas for customer information. 

In addition to their proactive measures, the Internet Service Providers also explained their data retention policies and addressed 

the announcement of the Department of Justice that it intended to 

explore with ISPs establishing a uniform data retention policy for 

the purpose of enhancing law enforcement’s investigations of Internet child pornography.17 As discussed previously, law enforcement 

agents who testified at the Subcommittee’s April and May hearings 

explained that inadequate data retention policies had prevented 

them in some cases from identifying individuals who create or distribute child pornography images over the Internet. 

While all the Internet Service Providers testified that they report 

images of apparent child pornography to NCMEC when they discover it on their networks and that they attempt to respond to law 

21 

18 At the time of the hearing, MySpace had 80 million registered users; Xanga had 27 million; 

and Facebook had more than 8 million. While Facebook, MySpace, and Xanga are each social 

networking websites, they operate differently with respect to how users can obtain access to the 

website. MySpace and Xanga are open to the general public. Anyone with Internet access can 

open a MySpace or Xanga account and build a personal webpage. In contrast, to join Facebook, 

a user must be validated into one of Facebook’s online communities. The communities are largely organized by high schools and colleges, but there are also work networks. In order to be validated, a potential user must have either a ‘‘.edu’’ email address or similar associated with a 

school or university email domain or, if a high school does not have a domain, high school users 

can join if they receive an invitation from a college user who graduated from that high school. 

The high school user who received the invitation will then invite other students from his high 

school to join; to ensure that individuals who do not have a .edu domain name are, in fact, students at a particular high school, Facebook places a computer code within the invitation email 

that confirms the individual who joined was the same individual who received the invitation. 

Additionally, members of Facebook only have access to the profiles of members within their 

school community. In this way, Facebook users only have access to their school communities. 

To view the profile of a user outside that community, Facebook members must receive permission from that user. Members of work communities only have access to the profiles of other 

users who have joined the same regional network they have joined. As MySpace and Xanga are 

not organized according to work, school, or regional communities, MySpace and Xanga users 

have access to any other webpage on the website, unless a user has activated a privacy setting 

that limits access to approved MySpace or Xanga users. 19On September 7, 2006, the Federal Trade Commission (‘‘FTC’’) announced that it had 

reached a settlement with Xanga related to Xanga’s alleged violations of the Children’s Online 

Privacy Protection Act (‘‘COPPA’’). The FTC found that Xanga, in violation of COPPA, had improperly collected, used, and disclosed personal information from children under the age of 13 

without first notifying their parents and obtaining consent. Under the settlement Xanga paid 

a $1 million fine to the FTC. 

enforcement agents’ requests and subpoenas as expeditiously as 

possible, the data retention policies of the ISPs that testified at the 

hearing vary widely, from 60 days to seven years. Testimony provided at the hearing suggests that the cost of data retention is a 

determining factor in setting the retention period. AOL, for example, testified that retaining the IP addresses for each user session 

of every AOL user would cost $44 million per year. Several factors 

have a bearing on the cost, for example, the types of services offered by the provider, the number of users, and whether the site 

is free or available only to paid subscribers. However, law enforcement officials have stressed that it is the ISPs that provide 

connectivity to the Internet which need to retain IP addresses for 

at least one year for purposes of child pornography investigations. 

The operations of social networking websites were also examined 

at the June hearing. These websites have become increasingly popular in recent years, especially among preteens, teenagers and 

young adults. Registered users with social networking websites are 

able to build personal webpages. These webpages often contain personal information about the user, such as where he or she attends 

school or works, their likes and dislikes, links to their friends’ 

webpages or other websites, contact information, and photographs. 

Recently, social networking websites have received a great deal 

of scrutiny as child predators have used the information on children’s webpages to contact them and to groom them in anticipation 

of meeting them in person. Facebook, MySpace, and Xanga testified 

about the safeguards they have implemented on their websites.18

Users of each website have the option of making their profiles private, thereby preventing other users from viewing their personal 

webpage. On MySpace, the ‘‘private’’ setting is the default setting 

for any user who admits to being under the age of 16 years. 

Xanga 19 employs similar features which allow a user to restrict 

their webpage to only other Xanga members or to other designated 

users, respectively. Xanga has also developed a safety feature, 

22 

20 NCMEC is the designated repository in the United States of all reports of online grooming 

or child sexual abuse or exploitation, and their link is displayed on several websites in order 

for users to report abuse. Once a report is received by NCMEC, analysts are available 24 hours 

a day to review the report and forward it to the appropriate law enforcement agency. Other 

countries have adopted similar approaches. For example, in the United Kingdom and Australia, 

many websites display a link to the Virtual Global Taskforce, or VGT. The VGT is comprised 

of law enforcement agents from Australia, the U.K., Canada, and the U.S., where agents from 

ICE are members. Internet users can report grooming or online sexual abuse by clicking on the 

VGT button, or link, displayed on social networking websites or the VGT’s website, 

www.virtualglobaltaskforce.com. The link then takes the user to a reporting page, where he or 

she is asked to supply certain information such as the webpage where the abuse occurred. The 

report is then immediately sent to the appropriate country for immediate review and action by 

law enforcement. 

called ‘‘Footprints,’’ which, when activated, allows a Xanga member 

to see the usernames of individuals who have signed into his or her 

webpage. Similarly, Facebook offers a privacy option which permits 

the user to determine who can see particular pieces of information 

about them, including their entire webpage. 

In addition to offering a privacy setting, the social networking 

websites who testified at the June hearing allow their users to report inappropriate content by clicking on links or tabs displayed on 

the user webpages. Typically, these reports are sent first to the 

website itself, so that website employees can review the reports 

and take appropriate action, including terminating the account of 

a user who has violated the terms and conditions of the website. 

If the content contained apparent images of child pornography or 

grooming, each website stated that they report this activity to 

NCMEC.20

The social networking websites also conduct some human and 

automated review of the content on their webpages, however, more 

needs to be done to ensure that these reviews are as effective and 

aggressive as they can be. For example, at the June hearing, the 

social networking websites, particularly, MySpace, were asked if 

they screened their sites for registered sex offenders. At that time, 

none of the social networking websites conducted any type of 

screening for sex offenders on their websites. Now, almost six 

months later, MySpace announced on December 5, 2006 that it was 

working to develop a technology that will allow it to block convicted 

sex offenders from accessing MySpace. As the technology has yet 

to be implemented, its effectiveness remains uncertain. Even so, it 

seems that the websites primarily rely on their users to ferret out 

and bring inappropriate content to their attention. As Facebook 

testified, they believe user reporting works best because Facebook 

users are best able to recognize individuals who do not belong in 

their school communities and do not tolerate behavior or content 

that does not meet the community’s standards. While Facebook is 

unique in that its users webpages are organized according to high 

school, college, or regional communities and only available to other 

users within the same community, Xanga also found that its reporting or ‘‘flagging’’ system has proved reliable in identifying child 

pornography or other inappropriate content. 

Despite these safeguards, children’s webpages on social networking websites are still vulnerable to child predators as the success of the safeguards largely depends on a child’s ability to recognize a dangerous situation, and report it, or to affirmatively activate the safeguards and privacy settings. The search functions of 

a website also pose a risk to children’s safety online. While Xanga 

23 

21MySpace does not permit users who are under the age of 18 years old to specifically browse 

for users who are 16 years old or younger. In addition, adults can never browse for users who 

are 18 years old or under. 

and Facebook do not permit its members to search other member’s 

webpages for personal characteristics, such as height, sex, or interests, MySpace users can search member profiles for a variety of 

factors including sex, age, marital status, body type, and interests. 

Though the webpages of MySpace users who are under age 16 have 

a default privacy setting and, even if that setting is deactivated, 

they are available only to other users under the age of 18, child 

users are still at some risk because the system can easily be manipulated by users who lie about their age.21 It takes only minutes 

to search for and find children who are under 16 years old on 

MySpace. For example, Committee staff did a search on MySpace 

for persons 4′11′′ or shorter. This simple search uncovered numerous underage users who accurately stated their height in their profile, but who over-reported their age, a common tactic by underage 

users to evade the MySpace age restrictions. 

Although all the social networking sites testified that they have 

been unable to develop a viable age verification system to weed out 

underage users, it appears that with some basic search techniques 

and development of more refined search algorithms, these companies should be able to detect underage users and those violating 

their Terms of Use in a more effective fashion. The lack of effective 

methods for protecting the adolescent membership of these 

websites, or limiting the websites to adults only, necessarily means 

that children are placed at risk of exposure to child predators. Social networking websites could require a verifiable credit card in 

order to confirm the age of the user, however, credit card companies have resisted allowing their systems and databases to be used 

for such confirmation without a purchase first taking place. 

In addition, children often are not able to accurately assess the 

risk presented by revealing personal information and communicating with individuals they meet in an online community. Detective Frank Dannahey of the Rocky Hill, Connecticut Police Department testified at the Subcommittee’s June 28 hearing that children’s personal information was often easily available or readily 

volunteered on the MySpace webpages he reviewed while conducting an experiment on Internet safety. This personal information included where the child lived, worked, the child’s full name 

and date of birth, and cellular and home telephone numbers. According to Detective Dannahey, teenaged users of social networking 

websites are often very trusting of the people they meet online and 

do not perceive them as strangers but as friends. For this reason, 

teenagers are not able to recognize when they are sharing personal 

information that might identify them to a child predator. These 

characteristics necessarily undermine safeguard systems that depend on a child’s ability to recognize and report inappropriate content. 

The risk posed to children by predators who are intent on communicating with them and befriending them online demands that 

Internet Service Providers and social networking websites take an 

aggressive approach in developing safeguards to protect children. 

Already, since Committee staff began meeting with the ISPs and 

24 

22Member countries are handling the legislation in different ways; the U.K. has opted to pay 

for the cost of retention and storage up to an agreed upon amount. 

social networking websites early in 2006, these companies have implemented several improvements to their systems. For example, 

when Committee staff first met with Comcast, its data retention 

period for a customer’s IP address assignments was 30 days. Just 

prior to the June hearing, Comcast announced that it was increasing this data retention period to six months beginning in September 2006. AOL, Yahoo!, Microsoft, and Earthlink announced 

that they were joining together to create the Technology Coalition 

at NCMEC, the purpose of which is to establish a central clearinghouse of known images of child pornography and to develop technology solutions to combat online child pornography. Also, in response to staff concerns, Google strengthened its advertising policies to ensure that it was not accepting advertising from companies 

with links to websites that promote the sexual exploitation of children. Finally, as mentioned previously, MySpace recently announced that it will build a sex offender database in order to screen 

its site for users who are also registered sex offenders. 

Following the June hearings, Committee staff traveled to the 

Netherlands and Belgium in order to meet with Dutch and European Union officials to discuss their progress in implementing a 

European Union data retention directive. The directive, which was 

issued on March 15, 2006, is broader than the policies discussed by 

the Internet Service Providers who testified at the Subcommittee’s 

June hearing because it applies not only to data that links an IP 

address to a particular individual, but to network and cellular telephones including the records of telephone numbers called and the 

date and time of Internet access. Pursuant to the directive, European Union member countries must adopt a data retention policy 

of at least six months and no more than two years for the data covered by the directive. Committee staff discussed with European 

Union and Dutch officials the response of the European Member 

countries to the directive; the reaction of the Internet Service Provider industry; technical issues posed by the directive; and cost projections for implementing the initiative. According to the directive, 

Member countries must have approved implementing legislation for 

Internet Service Providers data retention by March 15, 2009. 

Therefore, any U.S. ISP that is also doing business in an E.U. 

member country will need to comply with this legislation. Notably, 

no ISPs were able to provide the E.U. with substantive cost estimates for implementing the data retention legislation.22

C. The Role of the Financial Services Industry in Combating 

the Sexual Exploitation of Children Over the Internet 

On September 21, 2006, the Subcommittee held a hearing entitled ‘‘Deleting Commercial Child Pornography Sites from the Internet: The U.S. Financial Industry’s Efforts to Combat this Problem’’ 

that focused on the efforts of the financial industry to prevent commercial child pornography businesses and purchasers of child pornography from using their payment systems. The purpose of the 

hearing was two-fold. First, the Subcommittee hoped to learn how 

credit card companies and the banks that are members of their sysVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000030 Fmt 06633 Sfmt 06602 E:\HR\OC\31737.XXX 31737
25 

tems, known as merchant or acquiring banks, attempt to prevent 

commercial child pornography businesses from using their payment 

networks to facilitate the sale and distribution of child pornography 

images. In addition, the Subcommittee was interested in the efforts 

of the National Center on Missing and Exploited Children to create 

the Financial Coalition Against Child Pornography at NCMEC, or 

‘‘Financial Coalition,’’ and how it intended to achieve its stated goal 

of eradicating commercial child pornography over the Internet by 

2008. 

The first panel of witnesses focused on how law enforcement 

agents investigate online commercial child pornography businesses 

and the difficulties presented in these investigations. The witnesses 

on this panel included Mr. Christopher Christie, United States Attorney for the District of New Jersey, Mr. James Plitt, Director of 

the Cyber Crimes Center at U.S. Immigration and Customs Enforcement (‘‘ICE’’), U.S. Department of Homeland Security, and Mr. 

Ernie Allen, President and C.E.O. of NCMEC. Both Mr. Christie’s 

and Mr. Plitt’s testimony focused on the RegPay investigation. 

RegPay, also known as Operation Falcon, was the first international commercial child pornography website ring to be investigated and prosecuted in the United States. Mr. Christie, whose 

office extradited and prosecuted the defendants in the U.S., and 

Mr. Plitt, whose department was the lead law enforcement agency, 

explained how a company in the former Soviet republic of Belarus, 

called ‘‘RegPay,’’ operated several commercial child pornography 

websites as well as processed payments for over 50 other child pornography websites. The Belarus firm used a U.S.-based credit card 

processing company, called Connections USA, to process the monthly payments for access to the websites containing images of child 

pornography. United States Attorney Christie described how his office worked cooperatively with federal, local and international law 

enforcement to prosecute the persons in Belarus operating the 

websites. Ultimately, the investigation led to the arrest of over 300 

persons in the United States that purchased child pornography 

from this website and over 1,400 arrests worldwide. The two defendants from Belarus involved in the RegPay case were extradited 

to the United States, pled guilty on the eve of trial and were sentenced in August 2006 to 25 years in prison and a fine of $25,000 

each. Also, $1.15 million was seized as part of their illegal business 

operations that sexually exploited children. 

In addition to using the RegPay case as a model for future investigations, United States Attorney Christie, Mr. Plitt, and Mr. Allen 

noted that the payment methods used by commercial child pornography businesses are evolving. Specifically, law enforcement agents 

have witnessed the rapid growth of anonymous forms of payment 

to purchase child pornography images over the Internet. These 

forms of payment include digital currencies. Typically, digital currency is created when an Internet user makes a deposit to an account either from a bank account using an electronic funds transfer 

or by credit card. The digital currency account is then used to make 

purchases on the Internet. According to Mr. Plitt, digital currencies 

often make it difficult for law enforcement agents to identify and 

track the global financial structure that facilitates Internet child 

exploitation. As Committee staff has learned during the course of 

26 

its investigation, this is because some digital currency companies 

do not request information relating to the identity of the account 

holder or they do not attempt verify it. 

In his testimony, Mr. Allen also addressed the work of NCMEC’s 

Financial Coalition. The primary purpose of the Financial Coalition, as Mr. Allen described it, is to ‘‘follow the money, stop the 

payments, shut down the account, and put an end to this multi-billion dollar enterprise.’’ The principal obstacle to shutting down the 

websites that sell sexually exploitative images of children is identifying the merchant that is processing payments for those images. 

In order to shut down the merchant’s website and prevent it from 

processing payments, law enforcement agents must first identify 

the merchant bank or acquiring bank that actually approved a 

merchant for participation in the credit card networks. Usually, the 

credit card companies, like VISA, MasterCard, and American Express, do not have control over the website or a direct relationship 

with the merchant that is selling the illegal material. Therefore, it 

is impossible for the credit card companies themselves to immediately terminate the child pornography websites that are purportedly accepting their credit cards for payment. The role of the Financial Coalition is to assist in quickly identifying the merchant or 

acquiring banks that process payments for the commercial child 

pornography businesses, and facilitate the transmission of that information to law enforcement. To do so, NCMEC and the Financial 

Coalition launched a pilot ‘‘Clearinghouse’’ in the summer of 2006 

to facilitate better and faster communication between the financial 

industry and law enforcement, when a commercial child pornography site is identified. The methods which the Financial Coalition 

are using to detect and track down the merchant associated with 

the particular commercial child pornography site, however, are confidential and cannot be discussed in detail in this report. As of the 

hearing, Mr. Allen stated that 87 percent of the United States payments industry, as measured in dollars running through the payments system, has joined the Financial Coalition. 

Mr. Allen also described another new initiative being undertaken 

by NCMEC to combat online child pornography. According to Mr. 

Allen, based on the Committee’s suggestion, NCMEC is working 

with several U.S.-based Internet Service Providers to develop a 

proactive program for terminating websites that contain images of 

child pornography. Under this program, a NCMEC analyst will 

first identify the websites that contain images of child pornography. The addresses of those websites will then be forwarded to 

federal and state law enforcement agents so that they can initiate 

an investigation, if appropriate. After law enforcement is notified, 

NCMEC will then forward the websites’ addresses to the Internet 

Service Providers who are registered with and reporting to NCMEC 

and request that they enforce their terms of service, which prohibit 

illegal content. These ISPs have agreed to terminate the website 

upon such notice and use filters to block access through their systems to those websites. This is an important step toward implementing a system that will block Internet subscribers’ attempts to 

access websites containing child pornography images. We remain 

concerned, however, that, this initiative may not have the support 

of all U.S. ISPs. While many major ISPs in the United States are 

27 

23 American Express operates differently from MasterCard and VISA in that American Express itself both issues credit cards to its credit card holders and acquires, or approves, the merchants who can accept American Express. In addition, the companies’ policies differ with regard 

to the categories of business they will accept. American Express has a blanket prohibition 

against signing up merchants involved in the adult pornography industry. Companies such as 

MasterCard and Visa have terms within the bylaws of their association agreements that may 

prohibit certain adult content. Some acquiring banks may have an expanded definition of prohibited businesses that goes beyond what the credit card association rules prohibit. 

interested in the initiative, hundreds of others are not even registered with or reporting into the Cybertipline and their support for 

this initiative is unclear. 

The second panel was comprised of witnesses from the credit 

card associations, including American Express, MasterCard, and 

VISA, and other payment companies, including e-Gold and PayPal. 

The purpose of this panel was to examine the payments industry’s 

efforts to prevent individuals from using their systems to process 

child pornography transactions. Although MasterCard and VISA do 

not sign up merchants or card holders directly—this is the responsibility of their member banks, known as merchant banks—they do 

set the policies and conditions their merchant banks must follow 

for approving a merchant.23 In addition to determining the categories of business in which their merchants may engage, 

MasterCard and VISA dictate the procedures and guidelines the 

merchant banks must follow with regard to screening prospective 

merchant accounts both before and after they begin processing payments as well as closely monitor the merchant banks’ credit policies. As MasterCard, VISA and American Express explained in 

their testimony, their standards for approving Internet merchants 

are stricter than for ‘‘brick and mortar’’ merchants because Internet merchants inherently present a greater risk. 

In addition to adopting standards intended to identify potential 

or approved merchants who engage in illegal activity, such as commercial child pornography, American Express, VISA, and 

MasterCard also have implemented, with varying degrees of success, proactive measures to ensure that their Internet merchants 

are not selling or dealing in child pornography. The principal 

proactive measures adopted by these companies is ‘‘spidering,’’ or 

crawling the web, in order to identify websites that claim to accept 

American Express, MasterCard, or Visa and are participating in illegal activity or are violating the intellectual property rights of the 

companies by purporting to accept credit cards in an effort to make 

the website look legitimate. Once the credit card association determines that the website accepts their credit cards and is engaged in 

child pornography, the credit card association may shut down the 

merchant’s account or fine the merchant. In addition, the credit 

card companies report the website to NCMEC or, in some cases, directly to law enforcement, or both. 

Interestingly, the credit card associations explained in their testimony and in meetings with Committee staff that they have discovered relatively few instances where merchants were participating 

in a commercial child pornography business. They maintain that 

the majority of child pornography websites that claim to accept 

major credit cards, such as American Express, MasterCard, or 

Visa, in fact do not. Instead, when a child pornography purchaser 

clicks on the payment link, the website will lead the purchaser to 

28 

other payment methods. According to the credit card associations, 

their strict policies and procedures for approving merchants are 

successful in screening out merchants who intend to engage in this 

illegal activity. 

Like the credit card associations, PayPal and e-Gold, which are 

alternative payment mechanisms or digital currencies, have also 

adopted policies and procedures that prohibit their users from 

using their account to purchase child pornography. PayPal, a subsidiary of eBay, has taken steps to identify and minimize the use 

of its services for illegal transactions. For example, PayPal’s policies state that its users may not use their accounts to purchase 

‘‘any obscene or sexually oriented goods or services.’’ While their 

policies prohibit the purchase of child pornography, the critical 

issue with digital currencies with respect to commercial child pornography is the anonymity it offers its users. PayPal testified, however, that its system provides accountability and traceability because each individual user is required to provide his or her name, 

full address as it appears on the financial instrument funding the 

account, and home telephone number. Similarly, business users are 

required to provide information about their business, the name of 

the business owner, and work telephone and address information. 

PayPal then verifies this information against external and internal 

databases. Also, PayPal, like the credit card associations, performs 

some due diligence on its merchants as well as ongoing fraud and 

credit review after the merchant is approved to accept PayPal. 

While e-Gold is also a digital currency, it operates differently 

from PayPal in that its accounts are purportedly backed by actual 

gold reserves. To establish an account, an individual completes a 

short form online, including some identifying information. However, e-Gold does not verify this identification information or require that a credit card or other financial instrument be presented 

to verify identity. Further, e-Gold does not maintain sufficient 

records reflecting the activity of e-Gold accounts or, unlike credit 

card associations and merchant banks, conduct any due diligence 

on the merchants that accept e-gold. 

The Subcommittee’s investigation into the use of financial instruments to purchase child pornography over the Internet revealed a 

much larger problem touching upon the burgeoning industry of digital currencies: the lack of regulation of digital currencies by any 

government entity, domestic or foreign. Digital currencies that do 

business in the U.S. are not subject to any of the U.S. banking requirements. This has created a dangerous loophole in commercial 

transactions occurring on the Internet with virtually no accountability. It is imperative that the U.S. and other countries address 

the rise of digital currency and begin to subject this industry to 

some form of oversight and regulatory consistency. As of now, operations such as e-Gold are available to individuals who wish to 

transfer money anonymously for any purpose, whether legal or illegal. 

The third panel focused on the efforts of acquiring banks or merchant processing companies to prevent commercial child pornography merchants from having access to a traditional method of online payment, such as a credit card, to offer on their site. The witnesses included Chase Paymentech and Bank of America, which 

29 

24First Data and NOVA are not banks; various acquiring banks may contract out certain of 

their merchant banking functions, such as performing due diligence on prospective merchants 

and other functions, to these companies. Therefore, given the large size of their portfolio of merchant banks, much of the due diligence on the merchant side is frequently done by merchant 

processing companies like First Data or NOVA 

are both acquiring banks, and NOVA and First Data, which are 

merchant processors.24 As the witnesses explained at the hearing, 

before an acquiring bank or merchant processor can conduct merchant processing, that merchant must first be approved by the 

bank. The acquiring bank or processing company will first determine whether the merchant’s business is consistent with its credit 

policies, as well as the association’s policies. Bank of America, First 

Data Corporation, and NOVA each testified that their credit policies forbid them from approving any merchant who engages in certain types of businesses, including any illegal activity, such as child 

pornography, as well as certain legal activity, such as adult pornography. 

After the merchant bank concludes that the merchant’s business 

is consistent with its credit policies and the credit card association’s policies, the merchant bank will then conduct an underwriting and risk review. Most institutions conduct a more rigorous 

review of Internet merchants, as opposed to brick and mortar merchants, because Internet merchants are a greater credit risk. For 

example, Bank of America and Chase review each page of a prospective Internet merchant’s website to determine that the links on 

the site are operational, that they do not link to illegal or prohibited content, and that the merchant has appropriate customer service and product information. Once a merchant has been approved, 

the acquiring banks or processors then conduct varying levels of 

ongoing review to ensure that the merchant does not begin to offer 

banned products or services, such as adult content or child pornography. According to the witnesses, this review is primarily automated and involves monitoring trends in sales volume and average 

sales ticket size in order to identify patterns that may indicate illegal activity. If unusual activity is noted, the acquirer will conduct 

a more extensive review of the merchant’s business. In addition, 

some acquirers, like Bank of America, attempt to visit the websites 

of Internet merchants at least one time a year, even if abnormal 

activity is not present; other acquirers, such as First Data, will revisit a merchant’s website only if certain risk factors are triggered 

during its ongoing review. Finally, MasterCard and American Express acquiring banks are required to check the prospective merchant information against a database known as the MATCH system, which houses information about terminated merchants. 

In addition to ongoing monitoring of merchants, the merchant 

banks or processors also take additional proactive steps to identify 

merchants engaged in commercial child pornography. NOVA Information Systems uses a web crawler to search for certain search 

terms that may suggest a site contains child pornography. However, not all merchant banks or processors do so, contending it is 

unnecessary because the card associations already use web crawling services and inform their merchant banks when the crawlers 

find child pornography. Like the credit card associations, the merchant and acquiring banks identified only a handful of merchants 

30 

engaged in commercial child pornography in a given year. Typically, according to the banks, when the merchant applied for an account, its business and its website appeared to be legitimate; however, sometime after obtaining an account, the merchant then 

began to engage in commercial child pornography. The witnesses 

believe that the number of child pornography businesses they identify is minimal because their credit policies prohibit all pornography, even adult pornography, and their credit and underwriting 

review is successful in identifying risk factors that are linked to illegal activity. 

There is an obvious discrepancy between the number of websites 

that engage in commercial child pornography—approximately 

100,000 or more as estimated by the FBI—and the number of child 

pornography merchants identified by mainstream credit card companies. This discrepancy may be attributable to several factors, including the popularity of alternative payment methods, such as digital currencies; the use of barter, such as providing new images of 

child pornography to ‘‘pay’’ for child pornography received from a 

website; and the fact that commercial child pornography websites 

are skilled at masking the true nature of their business. 

D. The Psychology of Pedophiles and Child Predators 

On September 26, 2006, the Subcommittee convened a hearing 

dedicated to exploring the psychology of pedophiles and child predators as well as how the commercial child pornography industry is 

evolving over the Internet. 

The first panel of witnesses addressed the psychology and behavior of child predators. The witnesses included Dr. Anna C. Salter, 

a clinical psychologist in Madison, Wisconsin who treats and studies sex offenders; Dr. Andres C. Hernandez, Director of the Bureau 

of Prisons’ Sex Offender Treatment Program at the Federal Correction Institution at Butner, NC; and Dr. Philip Jenkins, a Professor 

of Religious Studies and History at Pennsylvania State University 

who wrote a book in 2001 entitled Beyond Tolerance: Child Pornography on the Internet which described what he observed after joining pedophile forums on the Internet and observing pedophiles’ 

conversations. 

The New York Times reporter Kurt Eichenwald also joined the 

panel to discuss his two recent articles published on August 20 and 

August 21, 2006, entitled ‘‘With Child Sex Sites on the Run, Nearly 

Nude Photos Hit the Web’’ and ‘‘From Their Own Online World, 

Pedophiles Extend Their Reach,’’ respectively. The first article discussed websites commonly referred to as ‘‘child modeling websites,’’ 

where young girls are posed provocatively in sexual clothing. According to Mr. Eichenwald’s investigation, the owners and operators of these websites have deliberately posed the girls in clothing 

because they believe that the current definition of ‘‘child pornography’’ requires the genitalia to be somehow visible in order for the 

images to be illegal. The second article focused on the online forums and chatrooms visited by pedophiles and child predators, 

where Mr. Eichenwald observed child predators encouraging one 

another and rationalizing their behavior. 

Dr. Hernandez’s testimony focused on the treatment of sex offenders within the Bureau of Prisons (‘‘BOP’’). Dr. Hernandez runs 

31 

the BOP’s only Sex Offender Treatment Program. Currently, that 

treatment program can only house 112 inmates at a time, out of 

the almost 12,000 federal prisoners now incarcerated for sexual 

crimes. The program is wholly voluntary for offenders. The treatment program lasts 18 months and is conducted in seven phases; 

these phases include a complete psychiatric evaluation and group 

and individual therapy. The final phase includes a polygraph. During the polygraph, inmates are questioned about whether they have 

committed contact offenses for which they have not been arrested 

or convicted. The information provided during the polygraph was 

the basis for a presentation Dr. Hernandez gave in 2000 entitled 

‘‘Self-Reported Contacted Sexual Offenses by Participants in the 

Federal Bureau of Prisons’ Sex Offender Treatment Program: Implications for Internet Sex Offenders.’’ With regard to the inmates 

he had treated, Dr. Hernandez found that 76 percent of the inmates convicted on charges related to the possession of child pornography or luring a child had also committed sexual contact offenses against children. Dr. Hernandez believed that this finding 

suggested that the majority of sex offenders convicted of Internet 

sex crimes had ‘‘similar behavioral characteristics as many child 

molesters.’’ 

In her testimony, Dr. Salter confirmed that a ‘‘considerable percentage’’ of individuals convicted for child pornography crimes had 

also committed contact offenses. More disturbingly, in her testimony, Dr. Salter’s suggested that this number may be underestimated, as one report found that only three percent of individuals 

who have committed contact offenses are caught. In addition to 

finding a link between possessing child pornography and committing contact offenses, Dr. Salter also testified that she believes 

there is a link between viewing online pornography and committing 

contact offenses. With regard to reducing the number of contact offenses against children, both Dr. Jenkins and Dr. Salter testified 

that reducing online child pornography would also reduce contact 

crimes, especially among those offenders who are emboldened to 

act on their sexual desires or urges by viewing child pornography. 

According to Dr. Salter, ‘‘child pornography increases the arousal 

to kids and is throwing gasoline on the fire.’’ 

As Dr. Salter acknowledged, while recidivism is common among 

sex offenders, treatment can be successful in reducing it. One report cited by Dr. Salter found that recidivism among sex offenders 

can be reduced by as much as 40 percent with proper treatment. 

Dr. Salter and Dr. Hernandez agreed that cognitive behavioral 

therapy or treatment was most effective in treating sex offenders; 

however, Dr. Salter testified that many states do not have the resources to provide the treatment that might decrease recidivism 

and, in fact, that some states have waiting lists for treatment. 

Mr. Eichenwald’s testimony focused on the online pedophile community. Mr. Eichenwald described the online pedophile community 

as being very sophisticated and cunning. For example, Mr. 

Eichenwald testified that there are Internet podcasts and even an 

Internet radio station organized by pedophiles for adults who are 

attracted to children. During the four months Mr. Eichenwald 

spent examining pedophile forums and chatrooms, he observed 

pedophiles discussing the best ways to get access to children, inVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000037 Fmt 06633 Sfmt 06602 E:\HR\OC\31737.XXX 31737
32 

cluding serving as camp counselors, foster care parents, and other 

community events where children gather, and rationalizing their 

behavior. For example, some of the pedophiles Mr. Eichenwald observed believe their relationships with minors are consensual and 

that the child, in fact, instigated the relationship. In fact, Mr. 

Eichenwald found that some pedophiles see themselves as leaders 

of a ‘‘cause’’ to advance the rights of children to have sex with 

adults. The pedophiles Mr. Eichenwald observed also rationalize 

their behavior in other ways, arguing that adults who attempt to 

protect children from them are ‘‘child haters’’ and impeding children’s happiness. 

Perhaps even more disturbing is the physical proximity to children the pedophiles observed by Mr. Eichenwald online seemed to 

enjoy. Mr. Eichenwald testified that the pedophile conversations he 

observed included daily accounts of their observations of children. 

Many of the people who visited the forums were teachers and 

school administrators, pediatricians, and other individuals with access to children. 

The second panel of witnesses focused on the role of web hosting 

companies. The witnesses included Mr. Thomas Krwawecz, the 

C.E.O. and President of Blue Gravity Communications, Inc., and 

Ms. Christine Jones of GoDaddy.com. Blue Gravity is a relatively 

small web hosting business located in Pennsauken, N.J., with servers located in Philadelphia, PA; GoDaddy.com is the number one 

registrar of domain names in the world and is also a large web 

hosting company. Web hosting companies provide the connection to 

the Internet for website operators and own the servers where 

websites upload their content. Mr. Krwawecz and Ms. Jones discussed how their companies identify possible child pornography or 

child modeling websites either when those websites register their 

domain names or during the hosting process. 

As Ms. Jones described, the first step in creating the website is 

registering, and therefore reserving, the domain name. At 

GoDaddy.com, the domain registration process is entirely automated. Ms. Jones testified that it would be very difficult to prevent 

an online child pornography or child modeling website from registering for a domain name because it is difficult, if not impossible, 

to verify the legitimate use of the domain name even if the name 

suggests it may be a child pornography website. 

According to the witnesses, once a website name is registered 

and a web hosting company begins hosting content, it is still difficult for the web hosting company to search proactively the 

websites it hosts in order to uncover child pornography content. 

Mr. Krwawecz testified that, in his experience, employing a web 

crawler service that uses certain terms found on child pornography 

websites would be impractical because the search would turn up 

thousands of results, most of which do not contain child pornography content. As mentioned previously, financial services companies do employ web crawlers as well as conduct other searches in 

order to identify inappropriate content. 

Ms. Jones and Mr. Krwawecz also explained that they typically 

learn that websites they host contain inappropriate content 

through reports or complaints from outside parties. Once a report 

is made, Ms. Jones testified that GoDaddy.com initiates an invesVerDate Aug 31 2005 04:12 Jan 19, 2007 Jkt 31737 PO 00000 Frm 000038 Fmt 06633 Sfmt 06602 E:\HR\OC\31737.XXX 31737
33 

tigation to determine if the website contains child pornography or 

child modeling and immediately suspends and reports websites 

that contain child pornography content. With regard to child modeling websites, Ms. Jones stated that GoDaddy.com routinely suspends websites that show images of children posed in a manner intended to be ‘‘explicitly sexy’’; posed in adult lingerie; or children 

who are partially nude or in very little clothing ‘‘not associated 

with normally acceptable situations.’’ Similarly, Mr. Krwawecz 

stated that it is the policy of his company to investigate the reports 

it receives and to disable the accounts of websites that contain ‘‘blatant illegal content.’’ However, with regard to potential child modeling websites, Mr. Krwawecz states that his company requests 

proof of age for the models from the website, and if ‘‘satisfactory 

proof’’ cannot be provided, the website is terminated. Although 

websites hosted by Mr. Krwawecz’s company included sexually solicitous posing of children who appeared as young as 8 or 9 years 

old, there is no evidence that Mr. Krwawecz was aware of this content and, once notified of the websites prior to the hearing, immediately terminated them. 

As noted earlier, web hosting companies, domain registries, credit card companies, social networking sites, and cellular telephone 

carriers, are not clearly subject to the reporting requirements of 42 

U.S.C. § 13032 or other provisions. While certain financial services 

companies have taken a proactive approach to working with 

NCMEC on the problem of commercial child pornography websites, 

and in reporting into the CyberTipline without a legal obligation to 

do so, not all firms that profit from these websites have followed 

suit. More importantly, many industries do not even know about 

the CyberTipline or whether they can, should, or must report into 

the CyberTipline. For example, due to the urging of NCMEC and 

a question posed by the Subcommittee at the June 28th hearing, 

in August 2006, the FCC issued an advisory opinion that cellular 

telephone carriers would not be precluded by other statutory requirements from complying with the reporting requirements of 42 

U.S.C. § 13032. 

Without any mechanism by which to track the number of Internet Service Providers, web hosting companies or domain registries 

in the U.S., it is also difficult to give notice to these entities of their 

statutory obligations, the existence of the CyberTipline, NCMEC, 

and the VGT, as well as the development of best practices. Clearly, 

neither current legal requirements nor voluntary action have been 

apparently sufficient to put a significant dent in the problem of 

sexual exploitation of children over the Internet. 

Æ