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Username: Arnold I. Friede
Date/Time: Fri, November 3, 2000 at 3:13 PM GMT
Browser: Netscape Communicator V4.61 using Windows NT
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Subject: Top Level Domain Name Application



November 3, 2000


TO: The Internet Corporation for Assigned Names and Numbers ("ICANN").

Re: Health Organization ("WHO")
        Top Level Domain Name Application.


These comments are submitted on behalf of Pfizer Inc ("Pfizer") in response to the application for ICANN to establish as a new top level domain name ("TLD") to be managed and operated by WHO.  Pfizer is the world's largest pharmaceutical company.  It discovers, develops, manufactures, and markets leading prescription medicines for humans and animals, and many of the world's best known over-the-counter brands. 

Pfizer strongly supports the right to use the Internet as a means for providing accurate and scientifically reliable information on medicines in a responsible manner for the benefit of patients and healthcare professionals.  In this respect, Pfizer shares the  WHO's objective to ensure the quality of health information on the Internet.  At the same time, however, Pfizer fundamentally disagrees with the proposition that a quasi-governmental organization, such as WHO, should be responsible for setting policy on how the TLD is distributed, for promulgating rules on who may register under it and how the registrations can be used, and for establishing enforceable standards and policies that it would police to determine when such a registration should be suspended or cancelled. 

Our concerns about WHO's regulatory responsibility under its TLD proposal are analogous in part to the concerns about prior government censorship under the Free Speech Clause of the First Amendment to the Constitution of the United States.  "It is not merely the sporadic abuse of power by the censor but the pervasive threat inherent in its very existence that constitutes the danger to freedom of discussion."  Thornhill vs. Alabama, 310 U.S. 88, 97 (1940).  Measures to regulate the content of health-related information on the Internet could impose inappropriate and unacceptable constraints on legitimate communication.  Experience teaches that under such a regime the "bad actors" will always find a way to evade controls while the law abiding will comply.  This, then, would result in a situation where unregulated and unreliable sources of information remain available on the Internet unchallenged by reliable authorities. 

Internet Corporation for Assigned Names and Numbers
Page Two
November 3, 2000

Moreover, the TLD may itself cause confusion and be misleading.  This is because its use may imply that the domain is the only one on the world wide web with "accurate" health-related information.  If this is the implication--and we suspect it is--then patients, health care professionals, and others who visit sites such as Pfizer's own or one of Pfizer's product-specific sites would be misled into believing that the information there is not accurate, and that it therefore must be false or misleading.  Such a misimpression would work a great disservice to millions of individuals who seek truthful and fully substantiated health-related information from pharmaceutical company web sites.

Consistent with the position articulated by the International Federation of Pharmaceutical Manufacturers in its statement on the The Use of the Internet for Pharmaceutical Information (October 1998), Pfizer believes that self-regulation, self-auditing, and implementation of Codes of Good Practice are the methods of choice for controlling the type and quality of health-related information on the Internet. In Pfizer's view, a self-regulatory approach would best serve not only the interests of the pharmaceutical industry but also those of patients, physicians, and consumers throughout the world.  Additionally, there are already places on the world wide web that provide links to health-related web sites whose content is determined to meet certain prescribed standards.  With all respect, both private sector and governmental initiatives to provide such third party verification based on objective, neutral, and equitable standards available to all applicants are preferable to any single organization, such as the WHO, being given an effective monopoly on determining the accuracy of health-related information on the world wide web through control of the TLD.

For these reasons, we urge ICANN to deny the WHO's application. 


By: Ray Jordan
           Vice-President Communication & Information




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