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

["celia.boyer@xxxxxxxxxxxxxxx" <celia.boyer@xxxxxxxxxxxxxxx>]

Dear Madam, Sir,

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, NGOs 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.
Health On the Net Foundation (HON.ch), an international NGO, with 8'000+ 
health websites members of the HONcode in 102 countries, 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 Intial 
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.
Thank you very much for your consideration.
Kind regards

CéliaBOYER

Executive Director
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______________________________________________________

CéliaBOYER

Executive Director

*H*ealth *O*n the *N*et Foundation

NGO in Special Consultative Status with the United Nations

Tél: +41 22 3726250 - Fax: +41 22 3728885 - Web: http://www.HealthOnNet.org

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