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