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Comment sent again

  • To: <comments-gac-safeguard-advice-23apr13@xxxxxxxxx>
  • Subject: Comment sent again
  • From: "Patrick Weber" <patrick.weber@xxxxxxxxxxxxxxxx>
  • Date: Tue, 14 May 2013 17:53:42 +0200

"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


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. 


As an NGO with European Federation for Medical Informatics Association
(EFMI) we believe 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




European Federation for Medical Informatics

Patrick Weber 


Ch de Maillefer 37

CH-1052 Le Mont-sur-Lausanne

Tél: +41 21 641 04 20

Fax: +41 21 641 04 29

Mobile: +41 79 212 88 85

Email: patrick.weber@xxxxxxxxxxxxxxxx

URL: www.efmi.org




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