I am possessed of a very bad habit. Sometimes I write hectoring letters of advice to complete strangers, in which I tell them how to run (or how not to run) their businesses. Do I actually know how internet strangers should run their businesses? Probably not. Thus, the people who get these letters of mine may conclude that I am a complete crank and net-loon. It’s possible they’re right.

In my defense: I’m getting better! Decades ago, I needed less provocation. Once in the early 1990s, the owner of a small dialup ISP sent me a polite email asking me not to be dialed-in from work and from home simultaneously. (I was in fact running multiple “news robots” against his company’s NNTP server, downloading lots of porn from Usenet.) I apologized, and with the apology sent him many paragraphs of enthusiastic opinion about his business and how it could (from my perspective as a happy power user) be improved. He took my feedback positively, wrote back in good humor, and we maintained a friendly email correspondence for some years, until he sold out to a telecoms giant and went off to Silicon Valley to play startup games with the big boys.

Before the internet, I had a job where I would sometimes write a “micro memo” on a single sheet of paper to summarize and transmit an important press clipping to my bosses, along with a couple of sentences about why it was important to our business. Sometimes I would write these opinionated little micro memos as fax cover sheets and then fax them to random members of my local business community who I thought might need the clippings (and my opinions). They might respond with gratitude, or with confusion; mostly they didn’t respond at all. I justified the effort as “business development” but mostly it was just a cranky hobby. My joke with my friends and colleagues was that I was running a charity business consultancy. Free business advice! (That you never asked for — uh, sorry.)

I told you: I’m getting better. These days, it’s mostly people who write to me first who are at risk of getting an unsolicited session of free business consulting. Usually they are asking for something like marketing help or free exposure, but they make the mistake of pretending they are asking for my advice or feedback because “Please have a look at my stuff and tell me what you think” sounds better than “Please have a look at my stuff and then blog about it for free.”

On the list of recent victims: the perfectly nice folks who run Mikandi, the adult app store for Android devices. Several of you have asked me why I did not blog about the excellent article in Wired magazine last month called The Porn Business Isn’t Anything Like You Think It Is. That article featured, among much other excellent stuff, profiles of Mikandi’s Chris O’Connell (chief architect) and its founders, Jesse Adams and Jen McEwen.

Porn and smartphones are a natural mix. I called Steve Jobs an asshole (until I had to transition to metaphorical spitting on his grave) for inventing the smartphone and then for locking it up so tight that porn apps can’t practically be installed on it by a typical user. Android looked better to me when it came along (this was back when Google still took a stand against being evil) but when Google entered its modern “fuck it, evil pays better” phase, they locked porn out of the default Android app store too. Mikandi (“the app store that treats you like an adult”) stands against all that, and runs what everyone says is a fine adult app store for Android. I want to like them for that, indeed I do like them for that, and I’ve been saying positive things about them for awhile.

I am not, however, a Mikandi customer. The reason for this is embarrassing and economic. I get free iPhones from a family member who wound up on the “Oooh, shiny!” Apple early-adopter treadmill, and so they give me free barely-used phones on a regular basis. I’ve never owned an Android device because of my endless supply of free IOS ones. It’s OK. I get plenty of porn on my desktop, I guess I don’t really need it on my phone, too.

But still. In theory I’d rather be an Android user, and if I were one, I’d be a Mikandi customer too.

Back in June I got a nice email (a real letter, not just a form template) from Jennifer McEwen at Mikandi. She identified herself as co-founder and VP of Product Development at Mikandi, she reminded me that we’d chatted on Twitter via their company account (@mikandistore), and she wanted to “share with me” that Mikandi had officially released its feature supporting the sale of adult comics as apps in the Mikandi store. She invited me to take “take the comic reader for spin” and offered to set me up with some free Mikandi Gold (presumably Gold is their app-store currency) to facilitate that.

She didn’t expressly ask me to write about the new Mikandi product line here on ErosBlog, nor did she explicitly ask me to tell her what I thought of her new offering. Nonetheless I assume she wanted at least one of those. My guess is that she wanted something like what Violet Blue gave her over at Tiny Nibbles: an enthusiastic and visually-appealing blog post saying nice things about the Mikandi comics publishing platform and about the hot dirty sex comics you can enjoy there.

Surprise, dear reader: Jennifer McEwan from Mikandi did not get that from me.

Nope, she got the detailed feedback on why I don’t think her business model is a good one for adult comics publishers. Whoopsie…

Y’see, I have issues with the media-packaged-in-an-app business model. I also have issues with simplistic policies about depictions of consent in porn, and it turns out that Mikandi’s policy is cartoonishly simplistic:

“MiKandi does not accept any non-consensual material, actual or implied. Consent is sexy!”

Reader, I shared my issues with Jennifer. I totally did. Here is an edited-down (yes, really!) version of what I wrote to poor Jen:

Hi, Jen. I’m actually quite glad to hear from you! I’ve become rather a big fan of Mikandi based on your fundamental market positioning and blog postings. (Although I am in theory a big fan of the more-open Android platform and its potential to allow adult products and services that Apple bans from the IOS world, the sorry truth is that I am an IOS user. Thus I don’t actually have an Android device in the house, which means I don’t have the familiarity with your platform and business processes that I would like.)

Sadly that means I’m afraid I have to decline your kind offer of some test Gold — an offer which I would otherwise accept with alacrity.

I must confess I find myself less than excited about your new comic book publishing platform, although I expect a great many comic book publishers will find benefit in it. My concerns with it are at least
partly philosophical: I see a distinction between software (like games and such) and media (like comics). Although I’m not happy buying software that has the potential to get DRM-bricked upon failure of the platform (years pass, the platform gets acquired, the servers stop responding, the app phones home, no answer, so sorry, you lose) I’ve mostly resigned myself to it. But when it comes to media, I am extremely old-school about my purchases. Basically if I can’t load it into my Calibre library (as I do with ebooks), convert it to whatever device-specific format I’m using this week, and then side-load it onto my devices, I’m not going to shell out good money for it. I realize this makes me a crusty curmudgeon. Nonetheless I have all good wishes for your venture; I’m just not excited about this specific business model of shoving media into app-wrappers that need to phone home periodically.

I’ve also got concerns about your Terms Of Service regarding non-consent content, as you were discussing on Twitter yesterday with @eroticawriter. I fundamentally understand that your interface with the banking system leaves you very constrained, but a 10-word policy from 2011 is simply way too vague. If you can’t get more certainty out of your CC processor, you’re not ready to release the platform; and if you HAVE gotten more specific terms regarding what the CC processor will tolerate, those terms ought to be revealed to potential developers.

We all know you don’t want (and the banks won’t process for) endless reams of rape manga, but I am imagining some comics producer like my friend Dr. Faustus who publishes his Tales of Gnosis College comics in old-fashioned comic-book-sized segments, where a plot-essential rape scene might theoretically show up for the first time across four panels in the middle of the seventh book. Indeed, Dr. Faustus does have several sex scenes scattered throughout his comic books, some of them featuring bondage, wrestling, complicated inducements, complicated risk environments, and other complex circumstances that might call consent into question. He avoids the squeamish-publisher problem (and many others) by releasing everything under GPL for free, but I feel like a for-profit publisher trying to distribute an ongoing series via your platform would be put in a terrible bind. Either they have to abandon your platform or they have to decide that artistically, they can’t go where the series otherwise needs to go.

Asking publishers to work in that sort of chilling-effect environment, it seems to me, requires offering them more than ten words of guidance about what is and is not allowed. This is especially so in the case of comics. What does consent even mean in the context of brightly-colored line drawings? It would be fairly easy to exclude material where the fact of rape was the deliberately-titillating fetish element; you could exclude material that advertises rape in titles or summaries, contains dialog or visual elements making the lack of consent explicit, and so forth. But you can’t do it in ten words, and it’s not fair to do it at all without also including some sort of guarantee that a publisher will get a warning or a pre-review process or an opportunity to discover where the line is without being summarily ejected from the platform.

I assume Mikandi is good to developers and publishers because that’s the impression I get about your overall approach to business; but so many #pornocalypse-ready platforms have burned so many people with irregular bannings and subsequent refusal to engage or explain! I would advise any would-be publisher of adult comics not to adopt or invest resources into building out on a new platform or marketplace unless the people running the platform make a public and contractual commitment to providing what is called “due process” in the legal realm. No arbitrary bannings, no unexplained bannings, no loss of ongoing access to the platform because of a transgression that is deemed to exist at the platform’s discretion based on policies not fully disclosed or not even fully-defined internally. It may be (and I hope!) that your internal process incorporates all of these publisher protections, but if so, your documentation doesn’t hint at them. We know you’re adult-friendly, but if the underlying reality is that you have to completely dump some long-running publisher without notice or warning because you got an unhappy phone call from a banking executive, all your good intentions are not so useful. If all of the app-wrapped comics that publisher has sold then suddenly stop working (I have no idea if this risk exists, another “reassurance opportunity” not yet seized by your documentation) it becomes a calamity for readers as well as publishers.

I apologize for turning this into another one of my #pornocalypse rants. I know from your twitter responses yesterday that you’re sensitive to at least some of these issues, and that you’re operating under billing constraints that you can’t do anything about. But I’m very passionate about advising adult-industry people not to get invested in platforms that don’t have their backs. I’m pretty sure you WANT to have the backs of the people who publish through you, but it’s unclear from the TOS whether you’ve got the necessary procedures in place, or the necessary freedom negotiated with your billers, to actually offer publishers what they need: clarity, certainty, and security from arbitrary business disruption when the limits of clarity and certainty have been reached or passed.

Finally, consent issues are at the emotional heart of a lot of BDSM fantasy literature, including in adult comic books. Ambiguity about consent is part of that, whether the ambiguity arises from the limited information available to a third-party viewer (if the opening panel is a handcuffed character fucking, we just don’t have facts to answer the consent question) or whether it arises in the notional mind of the character. (Are they undecided? Have they changed their mind since inviting the handcuffing, but not said anything? How do we know? How would we ever know? Since the mind we are interrogating doesn’t exist, what do these questions even mean?) It seems to me that there’s just a huge realm of adult “comics” literature that is just INCOMPATIBLE with your current ten-word policy on consent. It’s not because non-consensual themes are predominant, but simply because there’s no way to evaluate the work against the 10-word policy and reach any kind of sensible, predictable, or reproducible answer.

Oops! Ranting again. I’ll stop now. Please believe me when I say that I love what I can see of what y’all have been doing, and I’m delighted that your platform exists to challenge the prudishness of Apple and Google. Whatever my reservations about the current offering, I want to see Mikandi thrive and grow and prosper.

Thanks again for getting in touch!

She never wrote me back, poor woman. And what’s more, I don’t blame her. In her shoes, I would have have carefully closed the email from the internet crazyman and gingerly deleted it from my inbox.

How not to be an e-commerce business consultant? I am totally your dude for that!

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