Figure 1: Australian Internet Content Filtering Global View
Mr Mark A Gregory [HREF1], Senior Lecturer, School of Electrical and Computer Systems Engineering, RMIT University [HREF2], Melbourne, Australia. m.gregory@rmit.edu.au
This paper considers the Australian Government Moratorium on Internet Gaming and the restriction of Gaming Service Providers after the end of the moratorium. The direction taken by the Australian Government at the end of the moratorium will be a pivotal moment in the history of the Internet, for no other western Government has attempted to solve one of the major issues of the last decade, that of gaining control of the Internet. This paper discusses the reasons why Internet Gaming has moved forward in leaps and bounds; with better graphics, better sound and more dynamic effects. Some say that the Internet is impossible to control; this paper will present an alternative view.
Internet Gambling has benefited from the technology advances made in the last couple of years, especially since the beginning of 2000. Improved security, better bandwidth and improved Internet web-based platforms have all made the player experience more satisfactory than in previous years. The Internet aims to provide a web-based media rich environment for users and the Internet Gambling proponents have the funds necessary to exploit the latest technologies.
Online (Internet/web-based) gambling would probably not have evolved as quickly as it has if the Web still involved plain text characters and a command line interface. The graphical nature of the Web today, with its point and click access and interactive high quality screens, is really behind the increased demand for online gambling. The World Wide Web is pivotal in driving this industry.
Online gambling is represented by a number of trade and lobby groups. The Internet Gaming Council (IGC) [HREF3] is the leading international trade association committed to the advancement of the interactive gambling industry. There are about 100 Internet Gambling portals like Gamble.com [HREF4] and Gambling.com [HREF5]. In Australia, there is a regulated Internet Casino that has been operating for several years; Lasseters [HREF6]. In nearby Vanuatu, more regulated Internet Casinos are now appearing; Gamble.com.au [HREF7].
The Australian Federal Government has enacted a one-year moratorium on the growth of Interactive Gambling in Australia. The moratorium is due to end on 18 May 2001. The reasons for the moratorium are the current Federal Government’s concerns with the growth of gambling and the possible detrimental effects of gambling within Australia. Gambling is nominally a State matter, however the Federal Government has utilised Federal control over Telecommunication matters to introduce the moratorium.
The Commonwealth Science and Industry Research Organisation (CSIRO) published a report in December 1999 on Access Prevention Techniques for Internet Content Filtering. This publication attempted to quantify the problem of Internet content filtering, however, it does not explore the options completely.
The Commonwealth has more recently instituted a study into the feasibility and consequences of banning interactive gambling. In August 2000, as part of the study, the Government also tendered for two consultancies - one on the economic impacts of a ban and one on technical considerations. The successful tenders came from Econtech [HREF8] and Comtech [HREF9] respectively. The Commonwealth Government called for public submissions to assist with the study outcomes.
This paper proposes a methodology to permit prevention, partial prevention or “no prevention with monitoring” of Interactive Gambling utilising a hierarchical approach.
Internet Gambling is interesting because advances in the core Internet technologies have permitted a parallel increase in the number of Gambling Service Providers (GSP). New Internet technologies have improved the appeal, ease of use and access to Internet Gambling Systems (IGS). GSPs are now offering Internet Gambling with:
Some of the technology advances that have facilitated the rapid growth of Internet Gambling are:
With each new version of the browsers we see enhancements that not only provide more multimedia to the customers but also increase the suite of development options for the Internet Gambling developers. An example is DHTML and the advances in effects that this provides at a low bandwidth. Previous to DHTML the “roll-over” effect for a text link required downloading one GIF for the normal image and a different GIF for when the mouse moved over the image. This is now possible as a DHTML effect and does not require GIFs.
The growth in technology at the web server permits Internet Gambling developers to operate the server side of the system using web farms and distributed transaction systems. Of all the advances in Internet technology this area has moved forward dramatically in recent times. The IGS must be able to handle large numbers of client server requests per minute. For example, customers playing a slot machine game are sending a client server request each time they push the play button. A single random number generator and logic at the server end normally satisfy these client server game play requests. To facilitate handling large volumes of traffic the load is spread across multiple game servers in the web farm. If the time from when the customer presses the play button until there is an outcome is more than a few seconds the customer may become frustrated and leave.
There are two approaches to filtering: inclusion and exclusion filtering. Inclusion filtering is to maintain a list (white list) of sites that users may access. Exclusion filtering is to maintain a list (black list) of sites that users may not access. Implementation will normally depend on what is being filtered; in this case the number of Internet Gaming sites is only a small percentage of the Internet sites so a black list may be appropriate.
Content filtering approaches are:
Content filtering can occur at the following locations:
It is important to establish the extent of the content filtering required. When considering a prohibition of Interactive Gambling there are two components of information that will be encountered:
If the intent is to prevent Australian access to GSP websites then related content can be ignored. If websites or webpages hosting related content are also to be filtered then the requirement increases in complexity and the effects may be severe.
For example, during the 1st Cricket Test between Australia and India, 27 February – 3 March 2001, the Australian Cricket Board (ACB) [HREF10] website promoted “real-time” scores provided by CricInfo [HREF11]. The CricInfo site hosts a banner advertisement for Ladbrokes [HREF12] betting service. This possibly indirect or direct involvement in promoting an Interactive “real-time” Gambling service by the Australian Cricket Board could be considered improper. It may also be contravening the cross border and unlicensed providers Interactive Gambling advertising restrictions put in place by the New South Wales State Government initially and more recently by the Victorian State Government. For the ACB to continue a relationship with CricInfo when CricInfo is deriving proceeds from Interactive Gambling advertising revenue after the recent cricket match fixing scandal, involving bookmakers, may be considered poor form and a poor example of what to expect in the future.
There is an immediate realisation that the State Governments may be failing to police their legislation. There has only been very limited public disclosure of the States acting against organisations not complying with the spirit of the new State Laws but will the Federal Government police new Laws any better?
Commonwealth Government legislation would be required prior to the hierarchy described in this paper being put in place. At the present time, it is considered unlikely that current legislation and the roles of existing State and Federal agencies would permit a comprehensive plan of action being implemented.
For the purposes of this paper a fictional Commonwealth Government Agency called FedNet will head the new Internet content management initiative. To explain the operation of the hierarchy FedNet has been charged with preventing GSPs from operating in Australia or having access to Australian consumers.
The hierarchy is made up of:
FedNet is responsible for:
- Control and management of content filtering of all International telecommunication links at the point of entry to Australia.
- Maintaining the National blacklist containing the IP address of all International Websites to be refused access to Australia.
- Maintaining the National blacklist containing the IP address of all Australian Websites to be closed.
- Controlling National Domain Name Servers (DNS).
- Maintaining a National content monitoring facility.
- Maintaining a National consumer content Help-Line.
- Maintaining a team of Internet experts to facilitate FedNet‘s role.
Telecommunication carriers are responsible for:
- Compliance with Legislation and FedNet directives.
- International telecommunication point of entry content filtering.
- Preventing Australian computers from conducting DNS queries across the International boundary.
- Preventing machines outside Australia from sending DNS queries to any machine within Australia other than the Australian National DNS.
ISPs are responsible for:
- Compliance with Legislation and FedNet directives.
- Content filtering of traffic through the ISP network.
- Monitoring of all websites hosted on ISP servers.
Consumers are responsible for:
- Compliance with Legislation and FedNet directives.
- Option to use consumer content filtering software.
The top level of the Australian Internet Content Filtering hierarchy is shown in Figure 1. The International Telecommunication companies would interact with the Australian Telecommunication Carriers through interconnects that would all have FedNet content filtering nodes and this would include International connections to the current or future Australian Internet backbone.
Within the Australian context the next level of the hierarchy involves the ISPs and broadband connected companies, Figure 2. All ISPs would be required to host Fednet content filtering nodes and to enforce customers’ use of the ISP proxy for Internet browsing.
One of the fastest ways to pull an Internet site down is to remove its DNS listing. This would prevent someone from typing http://www.gamblingsite.com/ into a browser and being able to access the gambling website. National control of DNS server roots would permit the Government to regulate the naming of websites and to regulate access to International websites through Domain Names.
Ultimately, the use of a DNS is not required to access a website. A consumer may know to type http://192.168.5.5/ into a browser and this will provide access to the website for the IP number of the website has been used directly and the DNS bypassed.
Regulation of the DNS used by consumers is one relatively inexpensive method to enhance network management and control .
The Australian Federal Government, through legislation, maintains control over external matters such as Telecommunications. Through external powers the Federal government is within its right to legislate to regulate access to any external source by an Australian resident.
Through legislation affecting telecommunications the Federal Government has the power to legislate to regulate what is transmitted over the telecommunication network. The Australian Justice System at the Federal and State levels would need to be included, for the jurisdiction over and enforcement of Federal Legislation falls to the appropriate Justice body. Users of the Telecommunication network and ISPs are responsible to the Justice System first in the state they are registered and secondly to the Federal authorities through the Federal Court.
The Internet technologies are constantly advancing and this is providing the impetuous for the growth of GSPs. Customers are now gaining access to Internet Gambling websites that have the latest in security, leading edge graphics and better access speeds. The games are now being written using Macromedia Flash, Shockwave and Microsoft DirectX. The GSPs aim to ensure the customer experience being very similar to being within a real casino. Flashing and glittering components, realistic casino, game sounds and animations are some of the tools used.
The GSPs are using new distribution techniques to provide better access to large downloads of the game files, live streaming of content and often these distribution techniques mean that the GSPs are spreading their operation across websites in more than one country or continent.
To place the burden of content filtering solely on ISPs is not technically sound because many consumers are now acquiring broadband connections to the Internet backbone and thus are not required to utilise ISP proxy servers, web hosting facilities and so on. Effectively they are outside the current solution implemented to monitor Adult content. To include this growing sector it is necessary for the Telecommunication carriers to filter content on their backbones and at any point of interconnect. To oversee the Telecommunication carriers there is a need for a Federal Agency that has access to suitably qualified technical staff.
There is a need for the Federal Government to play a far greater role if the Internet is to be regulated in a manner that the Federal Government wants. The recent Federal legislation10 affecting Adult websites is an example of the problem to be overcome. The solution found was to make content filtering the responsibility of Internet Service Providers (ISP) and the classification of content the responsibility of the Australian Broadcasting Authority. Effective access to International Adult content sites has not been reduced, though some inconvenience has occurred to Adult content providers who were forced to move their sites offshore.
A participant at the above Forum [HREF13] indicated “CSIRO’s research makes it clear that blocking is not feasible” This comment implies that there will be an unacceptable cost associated with a National content filtering strategy. This may or may not be true, however, until a solution is fully costed to make such a statement is premature. It may be found that the cost is minor compared to the human tragedy caused by problem gambling.
Another participant suggested, “Unscrupulous overseas GSPs can provide gamblers with the means to get around any technical enforcements.” This suggestion implies that technical enforcements can always be overcome. FedNet’s role is to detect new mechanisms for illegal activity through vigilant monitoring and implement countermeasures.
Any organisation can hire world-leading experts to achieve an outcome, and in this case there would be a need to collect a team of Internet Development Experts to assist with the National Content Filtering strategy. This is no different to maintaining a team of code breaking experts for the purpose of National security and this is a standard practice.
There are a finite number of IP numbers and can be considered analogous to phone numbers. The Internet Corporation for Assigned Names and Numbers (ICANN) [HREF14] allocates IP numbers to a national agency that is then responsible for IP number allocation within a country.
FedNet’s team of Internet specialists would be responsible for monitoring websites, Internet traffic and maintaining the IP blacklist. The team would be responsible for implementing procedures associated with managing the blacklist, for example owners of IP numbers on the blacklist would be able to seek removal from the blacklist. The team would also be tasked to create Internet spiders and other applications that seek out illegal content. This would be the beginning of a proactive offence against those seeking to hide illegal content.
Many companies today maintain a similar team for the purpose of website promotion. These ‘positioning’ teams monitor web search engines and constantly seek new ways to optimise their companies ranking on the search engines. This has become a very complex task, and is considered by many companies to be one of their most important daily technical activities.
A secondary benefit of the work carried out by FedNet would be to facilitate research into methods of enhancing National Security, through content filtering, eavesdropping on Internet criminals and active prevention by stopping Information or network service attacks prior to their occurrence. Several countries have put in place national agencies tasked with the responsibility of protecting Information networks within the country. Removal of the threat of information warfare by another country or a terrorist group must be a National priority.
There is a negative possibility too; that fundamentalist pressure groups, or even corporations will eventually lobby Government to use the new FedNet to ban anything they don’t agree with. Such censorship issues are not new. FedNet is Big Brother in a benign sense, but it has the potential to be oppressive and turn against the public once the architecture is in place. The Government may quietly use FedNet to block news about international events it doesn’t want the public to know about.
The authors of the CSIRO report on content filtering state, “Whilst top-of-the-range routers can implement packet filtering without performance degradation, the main problem is its granularity: packet filtering is particularly course. An IP address represents a particular computer – not a Web site – and attempting to filter an Internet site by using its IP number may also block a large number of legitimate sites hosted on the same computer.”
First note that the CSIRO report confirms that technology is available. It can be argued that this would have a negative impact on Australia from the International point of view. Ultimately economics will dictate that the International companies who want to provide content into Australia will quickly put their websites onto machines that do not host websites blocked by Australian Law and thus satisfy Australian requirements.
Rupert Murdoch’s News Corp is trying to gain a foothold in the Chinese Telecommunications market and recently moved a step closer with the announcement of News Corp’s acquisition of a stake in China Netcom, a state-owned group backed by the son of China’s president. To achieve access to China, News Corp will be acting to ensure Chinese Government sensibilities on content to be provided into the Chinese market are taken seriously. News Corp’s drive into China is an example of how an International content provider will act to ensure that content is provided to different markets as the market dictates.
China is one nation that has already put in place a national methodology for Internet content control and management. There has been some concern raised internationally about the Chinese Internet content control and management system, as would an Australian Internet content control and management system.
The principal reason for new Australian legislation is to keep pace with improvements in Internet technologies. Recently, the Internet dot com crash has signalled the end of many “new” Internet entertainment ventures, however, the Adult Entertainment and Internet Gambling sectors continue to benefit from the advances in Internet technologies and are growing apace. There is a strong rationale that legislation is needed to manage these sectors that takes into account current and future Internet technologies.
Australia has started down the path to controlling and managing Internet content. There will always be dissent about loss of the right to “Freedom of Information”, “Freedom of Speech” and “Freedom of the Internet” but the average Australian may be more concerned about Australian websites that deny the Holocaust, provide access to instructions on how to make chemical bombs at home, and how to make nuclear bombs.
As with all aspects of Australian life, our democracy provides for the people to say what controls they want through the ballot. Enabling legislation will ultimately reflect the desire of the populace.
The Australian Government has the legislative power to regulate the Internet. The technology is available to achieve a complete or partial restriction on any Internet content or to simply monitor Internet content. The methodology to achieve this outcome has been presented in this paper. There is a cost associated with any attempt to limit content available on the Internet, and ultimately the cost of this strategy is best spread between the Federal and State Governments.
Mark A Gregory carries out research with software provided by Microsoft Corporation.
Australian Government Interactive Gambling (Moratorium) Act 2000 No. 151, 2000.
Paul Greenfield, Philip McCrea, Shuping Ran, CSIRO Publication “Access Prevention Techniques for Internet Content Filtering” prepared for the National Office for the Information Economy, December 1999.
NSW Gambling Legislation Amendment (Responsible Gambling) Act 1999.
Victoria The Interactive Gaming (Player Protection) Bill 1999.
Australian Government Broadcasting Services Amendment (Online Services) Bill 1999 and Broadcasting Services Act 1992.
Adelaide Institute, Dr Frederick Toben, ‘Holocaust Website in legal debate’, The Age 17 April 1999.
HREF1
http://131.170.32.110/
HREF2
http://www.rmit.edu.au/
HREF3
http://www.igcouncil.org/
HREF4
http://www.gamble.com/
HREF5
http://www.gambling.com/
HREF6
https://www.lasseters.com.au/
HREF7
http://www.gamble.com.au/
HREF8
http://www.econtech.com.au/
HREF9
http://www.comtech.com.au/
HREF10
http://www.acb.com.au/
HREF11
http://www-aus.cricket.org/
HREF12
http://www.ladbrokes.co.uk/
HREF13
http://www.noie.gov.au/projects/consumer/gambling/forum.doc
HREF14
http://www.icann.org/
Mark A Gregory, © 2001. The authors assign to Southern Cross University and other educational and non-profit institutions a non-exclusive licence to use this document for personal use and in courses of instruction provided that the article is used in full and this copyright statement is reproduced. The authors also grant a non-exclusive licence to Southern Cross University to publish this document in full on the World Wide Web and on CD-ROM and in printed form with the conference papers and for the document to be published on mirrors on the World Wide Web.