New gTLD Board Committee Consideration of GAC Safeguard Advice - particular focus on ".health"

[Peter Murray <imia@xxxxxxxxxxxxxxxxx>]

Dear Sir/Madam.

While our comments below relate specifically to the issue of the .health
gTLD, the broader principles apply to many of the other gTLDs identified
within Annex I, Safeguards on New gTLDs, of the GAC Beijing Communique of
April 11, 2013.

The health Internet is a vital means of health information access
worldwide. Thus, ".health" and health related top level domains should be
trusted and reliable resources which take the public interest into
account. We share the concerns expressed by the GAC, and support the
objections submitted by the ALAC and the Independent Objector regarding
health-related names. We believe it to be necessary for ICANN to take into
account the opinions of professional organisations and governments.

The GAC has proposed general safeguards for a set of names related to
health, with no assurance that they will be enforced, meaning that there is
no guarantee that a new ".health" TLD will be operated in the interest of
global public health and consumer protection. A " .health" TLD without
adequate quality assurance and consumer protection mechanisms in place will
undermine credibility and harm the growth of the online health
marketplace. Despite GAC advice, an open and unrestricted TLD will help
bypass regulatory controls creating new risks for the whole industry
sector, including in emerging markets. Developing countries will suffer the
most in this scenario, due to their difficulties in enforcing national
policies to regulate, monitor, and stop fraud and misuse.

IMIA (the International Medical Informatics Association), an NGO with
member organisations in 60 countries, representing tends of thousands of
professionals, believes that ".health" should be managed as a global asset,
and that its governance should be based on broad-based, multi-stakeholder
consensus.  In this regard the ICANN board should note the concerns of the
health  community, GAC, ALAC and the IO, and should not proceed beyond
Initial Evaluation of the ".health" string, including its Chinese variant.
We urge the ICANN board to postpone the attribution of ".health" until such
time as following broad-based consultation of the health community,
including the public and private sectors, adequate baseline conditions
for its operation are elaborated and their implementation and
observance can be ensured.


Dr Peter J. Murray
CEO, IMIA

International Medical Informatics Association (IMIA)
c/o Health On the Net
Chemin du Petit-Bel-Air 2
CH-1225 Chêne-Bourg
Geneva, Switzerland