In Support of the Policy Advisory Board Model

["Tim Smith" <tim.smith@xxxxxxxxx>]

Since our formation in 2002, the Canadian International Pharmacy Association
(CIPA) members have been safely selling pharmaceuticals and maintenance
medications online from licensed pharmacies in Canada.   Given the high
price of medication in the U.S. and its huge impediment for seniors and
others living on fixed income, it should be noted that most of CIPA's
patients are located in the United States.  In addition to Canadian
dispensing, CIPA members also have relationships with regulated
international pharmacies and inspected fulfillment centers that directly
deliver medications to patients from their respective locations. All
dispensing is performed under the supervision of a licensed pharmacist upon
receipt of a valid prescription and over our 12 year history we have
maintained a 100 percent perfect safety record while serving about a million
patients each year.   CIPA is the only online pharmacy self-regulatory body
that specializes in providing a safe and affordable prescription medication
service for people who struggle to obtain their medications where they live.

CIPA's experience illustrates how tens of millions of patients have already
made the decision to purchase medications from responsible online sources
outside their country of residence. These patients have found a safe and
trusted resource and they deserve to be guided and protected by industry
professionals irrespective of country of origin. It is for this reason that
CIPA requested clarification
<https://gtldcomment.icann.org/comments-feedback/applicationcomment/commentd
etails/12174>  from the National Association of Boards of Pharmacy (NABP)
regarding registrant eligibility to their .pharmacy gTLD application last
year.  NABP has since provided clarification in published statements
<http://www.prnewswire.com/news-releases/nabp-moves-pharmacy-program-closer-
to-launch-enters-contracting-phase-with-icann-247153101.html> , but without
any insight into how policies will be developed, which policies the NAPB
chooses to make, how those policies will impact all affected parties, and
whether the public interest will be sufficiently served. While the NABP
application states that it seeks to protect consumers through acceptance of
legitimate registrants, it does not come close to reflecting the true nature
of a global internet. Neither does it adequately address the needs of
patients who can't afford medications where they live by enabling them to
find safe and secure alternatives to maintain their health.  

For these reasons, CIPA supports the proposal for the use of Mandatory
Policy Advisory Boards for Regulated Industry Sector and
Consumer-Trust-Sensitive New gTLD Strings as proposed by ALAC.  CIPA
believes that the value of the internet is found in connecting consumers
with eCommerce specialists anywhere they may be in the world - provided that
trust, security and safety measures are met - so that consumers can be
conveniently served.  

Guiding Principles for the Policy Advisory Board (PAB) support this
objective:

...        Ensure that registrant eligibility policies are inclusive,
transparent, pro-competitive and non-discriminatory and serve the affected
community and the general public, particularly Internet users of domain
registrant services

...        Recognize that national laws, especially those related to
cross-border e-commerce, have not kept pace with the explosive growth of the
commercial internet over the past 15 years, and that therefore additional
measures are required to ensure that standard and acceptable practices guide
new gTLD policies and protect the public interest

The function of the PAB, as stated in its documentation, is of vital
importance to ensure that gTLD registries operate in a manner that benefits
consumers with the best selection of legitimate businesses to serve their
needs and that regulated industry TLDs do not act in a manner that is
anti-competitive or exclusionary. 

 

...        To ensure that the protection and promotion of the public interest
is furthered via the operation of a regulated industry/profession gTLD 

...        To ensure that new gTLD applicants for regulated industry gTLDs do
not operate the registry in a manner that is antithetical to the overriding
goals of competition and innovation 

...        To ensure that the Policy Advisory Board is inclusive of all
affected parties and reflects global diversity, participation in the Board
should be open to all parties with a demonstrated connection to the industry
associated with the gTLD string. Such parties include regulators, wholesale
and retail industry participants as well as their representative industry
trade organizations, and consumer and public interest groups 

...         

The PAB is the only mechanism that offers an opportunity to provide input
from online pharmacy specialists such as CIPA and the millions of consumers
who benefit from, and need the services of legitimate pharmacies, wherever
they may be located in the world.  

 

Therefore, on behalf of the Canadian International Pharmacy Association, we
add our voice to the chorus of strong support for the acceptance of the PAB
model to ensure and strengthen the Public Interest Commitment Specifications
(PICS) called for by the Government Advisory Committee are met by applicants
like the NABP before they are given the right to operate the .pharmacy gTLD
registry.  All new gTLD registries should have a mandate to serve the best
interest of consumers and the global internet community, but that mandate is
a must if they are to be given the right to manage a regulated industry
space.

 

Thank you.

Respectfully submitted,

Tim Smith

General Manager

Canadian International Pharmacy Association

Winnipeg, Manitoba, Canada