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Username: Dr. Lewis Eigen
Date/Time: Sat, October 28, 2000 at 12:37 AM GMT
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Subject: Opposition to WHO top level domain proposal for .health


                          First, the precedent creates the possibility of .justice, .education, .environment etc with the benefit of assuring reliability of other critical areas of public information.  I am not sure that it is desirable to "reserve" major portions of the web for perticular areas of "truth" "rectitude" and professional vetting.  It is a terrible image in a world where many nations worry about controlling their version of the truth.  In the worst of hypothetical cases certain nations, institutions or whatever will block all sites unless they are among the exalted few in the TLD's for health, justice, air quality, parenting, education, etc.  It is a terrible idea, in my judgment, to give any organization cntent control over areas of cyberspace.

Second, it there were to be ceded this control, why should it not be to the governments.  Is WHO more competent vetting for France than the French Government; for America than the U. S. Surgeon General; for China than the Chinese Ministry of Health?

Third, if WHO feels they have a useful role to play by vetting health sites, then they should do so.  Put on their web site a list of endorsed or approved sites with links.  Those people who want to filter through WHO can do so.  They can even have a "WHO Seal of Approval" which can be displayed only by approved sites.  The public can use the vetting skill of WHO if they want to.

Fourth, if there is to be a single vetting organization for each (or any) areas for the entire world, why should it be WHO?  There are other organizations which have similar or arguably better skills.  Why should there not be a competitive process?

Fifth, WHO has a serious defect as a vetter of health information itself.  Realistically WHO is the operator of many of the world's critical public health programs.  In order to do their work they need the good graces of the Governments of the world.  As such, they have to walk a very tight line in disclosing all information and supressing information that individual governments consider detrimental, insulting, culturally insensitive etc.  A system which is dependent on them to vet sites has the potential of "conflict of interest" and/or the appearance thereof.  Already WHO has been accused of supressing much information for various reasons.  Why make the web structure a battleground for these issues?  Why put WHO in the position where national governments will hold them resonsible for the content on vetted sites?  It potentially impairs the WHO main mission.

Sixth.  There is no guarantee that WHO will perform properly.  Although intentions are good, the ability to properly vet sites requires a good bit of work.  Where will the funds come from?  No serious vetting can take place for $10.  So WHO will have to subsidize the process or have an exclusive area to run the registration price up.

Seven.  Fairness and redress.  What criteria will be used?  Supporting commentators welcome the fact that there will be assurance of "truth" and accuracy of health information.  In the US, CDC, FDA, AMA and the Surgeon General are sometimes in disagreement.  Whose truth does WHO use?  What happens if a .health domain is "sold" or tansferred to one of the exploiters?  What happens if a vetted site starts to include "improper material."  First we censor organizing sponsors; then we have to check on ownership and control transfers; finally, on the content of the material itself.  Is there any other noun but censorship to describe this.  And what are the redresses that the world has if they disagree.  Who sees to it that WHO has acted properly.  Because of it's unique role, iit is immune from various kinds of legal action and should be.  But sould that immunity extend to this censorship role.  The onlything worse than having a public censor is to have one which is not accountable and controlled by the legal system and courts of the various countries.  Who does an aggrieved party sue?  In what jurisdiction?  And what property is surity for the judgment?  If we must have a censor, please make sure that it is one that is very vulnerable other authority for redress.

Eight.  WHO is itself a major player in the health world.  Arguably one of the most important organizations in the world.  As such they themselves have been and will be the target of much criticism and attack, much undeserved by some perhaps appropriate.  Whould a leading player in a field be selected as the vettor and censor of a major information channel in the field.  Consider the absurdity of having a TLD .routers and giving the control to CISCO or .software and ceding it to Microsoft or .bloodsupply and choosing the Red Cross.

Nine.  Unfortunatly, there are many people in the world who do not like the United Nations or related organizations like WHO.  In America, there are many for whom the name and concept is anathema.  For the most part, the Internet and the World Wide Web has steered clear of politics except for the political issues about its own governance such as American dominated or third world lack of access.  Why add a political dimension to the Web governance that has NOTHING TO DO WITH THE WEB.  There are those who will now see ICANN as part of an International Conspiracy to control the world, by starting with giving the WHO and the "internationalists" control of a part of the web.  What part goes to the UN itself?  What part to the Trilateral Commission?  While these issues seem paranoid to many of us, they represent real belief structures.  Consenting to the WHO proposal will only reinforce those irrational structures, bring more distrust upon the UN and other international organizations and involve ICANN in teh middle of a very complex, emotional debate that it has nothing to do with and should not have anything to do with.

The proposal for a vetted .health domain is a poor one, which becomes tragically flawed if WHO becomes the selected organization.

Dr. Lewis Eigen
President, Social and Health Services Ltd.    


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