Dear Epik Abuse Team,
I fully understand the seriousness of your concerns and your decision to suspend my domain and account. I want to respectfully ask for one final opportunity to clarify or correct the situation, if possible.
It was never my intention to host content in violation of any laws, including § 1466A of the Protect Act. If any material was interpreted as such, I sincerely apologize and am more than willing to permanently remove or revise it. My aim has always been to follow all applicable laws and your Terms of Service as best I can.
If reinstatement of the domain is absolutely off the table, I humbly ask whether you would allow a one-time exception to transfer the domain elsewhere, so that I can work to resolve any issues directly and responsibly with another provider — without further involving your platform.
Please know that I take this matter very seriously, and I would be grateful for any opportunity to make things right.
Thank you for your time and consideration.
Sincerely,
Kutay DemirI am writing to formally contest the suspension of my domain heyuri.net on the grounds of a purported violation of 18 U.S. Code § 1466A. I fully support the enforcement of laws protecting against the sexual abuse of children and take these matters very seriously. However, I believe there may have been a misapplication of the statute in this case.
The content in question consists solely of drawn, fictional imagery that does not involve real individuals. Under well-established First Amendment protections, such material - however controversial to some - is not illegal per se unless it meets specific obscenity criteria as defined in Miller v. California, or is otherwise linked to criminal conduct. The Supreme Court’s ruling in Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002), further clarified that purely fictional representations that do not involve real minors are protected speech.
Furthermore, I want to stress that I was not given any prior warnings or notices regarding potential violations. Had I received even a single warning, I would have promptly investigated and taken action to resolve any concerns. The immediate and final nature of this suspension, without opportunity to respond or remedy, seems disproportionate and unfair.
Additionally, while 18 U.S. Code § 1466A criminalizes certain obscene visual depictions, it explicitly states that "it is not a required element of any offense under this section that the minor depicted actually exist.” However, the Supreme Court in Ashcroft v. Free Speech Coalition, 535 U.S. 234 (2002), struck down similar provisions that banned fictional depictions not involving real minors, ruling that such restrictions were overbroad and violated the First Amendment. Applying § 1466A in isolation to fictional artwork not meeting the strict legal definition of obscenity raises serious constitutional concerns and risks overstepping the bounds of protected speech.
In light of the above, I respectfully request a reconsideration of your decision and the opportunity to address any concerns directly. I remain open to cooperation and correction, but I ask that due process and constitutional protections be observed.
Thank you for your attention to this matter.
Sincerely,
Kutay Demir
kaguy4@protonmail.com