18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

Prototypical answer:

18.2 How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?

NABP believes that a proposed .PHARMACY gTLD has the potential to offer the following benefits to Internet users and consumers:

-Establish a trusted online marketplace for consumers seeking legitimate pharmaceuticals from lawful online pharmacies;
-Safeguard consumers from the 95 percent of pharmaceutical websites that are operating out of compliance with applicable laws and regulatory standards;
-Provide consumers with access to short, memorable, and intuitive domain names that will facilitate the navigation of .PHARMACY namespace, especially from mobile devices;
-Safeguard consumers from counterfeit⁄substandard pharmaceuticals that put the patient’s health at risk. By way of example, “the FDA in recent years has found cases of a counterfeit HIV⁄AIDS drug that contained non-sterile tap water instead of an active ingredient; a fake schizophrenia medication that contained aspirin; a counterfeit influenza vaccine; and a misbranded cough suppressant that caused the death of five consumers.” See “Intellectual Property: Observations on Efforts to Quantify the Economic Effects of Counterfeit and Pirated Goods”; United States Government Accountability Office, April 2010;
-Eliminate the need of defensive registrations because .PHARMACY domain names will be allocated only to properly vetted and qualified entities; and
-Incorporate post-registration safeguards, both active and passive, to ensure that registrants continue to act in compliance with the terms and conditions of their registration agreements.

18.2.1 What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?

The primary mission and purpose of the .PHARMACY gTLD is to provide a trusted, hierarchical, and intuitive online marketplace in which consumers can research and purchase legitimate pharmaceuticals from pharmacies that operate in compliance with applicable national and local laws. Consumers will also have confidence that the online pharmacies using a .PHARMACY gTLD are properly vetted and audited to ensure best-in-class standards, thus minimizing the potential of receiving counterfeit or substandard pharmaceuticals.

Another potential benefit of the .PHARMACY gTLD through the “look to the right of dot” awareness campaign (see Section 18.2.6) is to raise public awareness of the problem of existing counterfeit pharmaceuticals on the Internet and the danger that they pose to consumers. While some consumers who do not have proper prescriptions will continue to use illegal online drug sites, this initiative will give other consumers a way to avoid unknowingly subjecting themselves to potentially dangerous medicines.

18.2.2 What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?

As a community-based gTLD, the primary driving factors of a .PHARMACY gTLD are public safety and consumer trust. The success of the gTLD will not be measured by the number of domain names registered. Instead it will be measured by the level of consumer recognition and trust that is placed in the .PHARMACY gTLD. Using this benchmark, NABP and the coalition strive to build consumer recognition and trust that rise to the level of that found in the .EDU and .GOV gTLDs.

NABP and the coalition members will work together to ensure there are appropriate safeguards, both pre- and post-registration. With proper education and awareness, this gTLD will provide a means to prevent consumers from unknowingly subjecting themselves to potentially dangerous medicines.

18.2.3 What goals does your proposed gTLD have in terms of user experience?

NABP and the coalition believe that the .PHARMACY gTLD will provide a single trusted ecosystem where every registrant in the gTLD will be properly vetted prior to registration, subjected to ongoing monitoring for compliance, and operated in accordance with applicable laws. Additional goals include:
-Increasing public awareness of the problem of rogue online drug sellers and the danger they pose to consumers;
-Cracking down on the number of non-compliant websites, and lowering the percentage of counterfeit⁄substandard pharmaceuticals being trafficked on the Internet;
-Increasing navigation options for consumers, especially for those using mobile devices;
-Providing valuable information portals for consumers operated at the premium generic and geographic domain names initially reserved⁄allocated by the registry; and
-Saving lives.

18.2.4 Provide a complete description of the applicant’s intended registration policies in support of the goals listed above.

As previously stated, NABP will have safeguards in place to ensure that only authorized online pharmacies that meet all regulatory standards, including pharmacy licensure, drug authenticity, and valid prescription requirements, are able to register in the .PHARMACY namespace.

One of the members of the coalition identified above in Section 18.1.2 is LegitScript, the largest Internet pharmacy verification program in the world, and the only Internet verification program identified by the NABP, other than its own, that meets NABP standards. NABP and LegitScript are looking at authentication processes to speed the review and vetting of potential registrants within the .PHARMACY gTLD. While both parties have extensive experience in connection with North American pharmacies, they will seek to develop a best practice verification process for all pharmacies globally, working with international coalitions such as FIP and agencies such as the WHO.

In addition, NABP is looking at how to access and analyze registry data to proactively monitor the .PHARMACY zone file to identify any potential non-compliance. The active post registration auditing would be coupled with a passive reporting feature whereby third parties could report potential non-compliant activity within the .PHARMACY gTLD.

While these are the initial policies that NABP will adopt for the operation of the gTLD, they recognize that protecting the safety of consumers in the .PHARMACY namespace will require diligence and a continued evolution of the policies. Therefore NABP is evaluating the potential creation of a policy advisory body that could draw upon a larger cross section of the community to propose best practices and technological innovation within the gTLD. It is envisioned that the policy advisory board will function as other such boards within NABP and be comprised of subject matter and process experts in critical areas with a legitimate interest in the .PHARMACY gTLD. The policy advisory board will serve as a resource for remaining current with the environment, issues of importance, and other matters impacting the .PHARMACY gTLD.

In addition, NABP will incorporate all required ICANN consensus policies and other legal⁄policy requirements imposed on new gTLD applicants into the terms and conditions of the domain name registration agreement that each registrant will execute.

18.2.5 Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.

NABP and the coalition recognize that this is an evolving area of law in which no international standard exists. However, due to fact that every domain name will be registered to a legitimate online pharmacy or other qualified business meeting the requirements of the registration agreement (e.g., premium domain name registrations), NABP and the coalition have a vested interest to ensure that accurate and current domain name information is readily available in connection with every domain name. Therefore no privacy services are anticipated. In fact, NABP and the coalition have considered prohibiting proxy registrations within the gTLD, but have deferred any decision on this policy until a larger cross section of the community can be consulted.

In addition, NABP intends to incorporate contractual language in its Registry-Registrar Agreement (RRA) modeled after language that has been included in the template Registry Agreement and that has been successfully utilized by existing ICANN gTLD Registry Operators.

The template Registry Agreement states, “Registry Operator shall (i) notify each ICANN-accredited registrar that is a party to the registry-registrar agreement for the TLD of the purposes for which data about any identified or identifiable natural person (“Personal Data”) submitted to Registry Operator by such registrar is collected and used under this Agreement or otherwise and the intended recipients (or categories of recipients) of such Personal Data, and (ii) require such registrar to obtain the consent of each registrant in the TLD for such collection and use of Personal Data. Registry Operator shall take reasonable steps to protect Personal Data collected from such registrar from loss, misuse, unauthorized disclosure, alteration or destruction. Registry Operator shall not use or authorize the use of Personal Data in a way that is incompatible with the notice provided to registrars.”

18.2.6 Describe whether and in what ways outreach and communications will help to achieve your projected benefits.

As noted above, NABP’s driving factor in securing a .PHARMACY gTLD is to educate the public as to the danger of rogue online drug sellers, and empower consumers to avoid unknowingly subjecting themselves to potentially dangerous medicines. In furtherance of this goal, NABP and the coalition are currently evaluating the potential of a “look to the right of the dot” marketing initiative to help educate and empower consumers to research and purchase pharmaceuticals from reputable online pharmacies. In addition, NABP plans to leverage its existing AWARxE™ consumer protection program to educate the public about the .PHARMACY gTLD.

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