Since the shocked are not a member of the community, there is no legal issue of obscenity. Where this breaks down is that it was not Miller's intention to encourage the creation of communities to evade obscenity laws. Looked at this way, the EFF is asking for greater independence for citizens of cyberspace. I think that Miller itself was outmoded. It was a cop-out in 1972.
Obscenity is a free speech issue, thus a First Amendment matter.
There is no other constitutional question on which community standards are relevant. No other type of speech may be free in New York and restricted in Tennessee. Acts of racial discrimination that are illegal in California may not be legal in Georgia. A search and seizure that violated a defendant's rights in Wisconsin is not legal in Minnesota. Miller was marginally acceptable as a compromise solution in 1972 because a defendant could choose not to send questionable materials into communities that would object to them.