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18(a) Describe the mission/purpose of your proposed gTLD

gTLDFull Legal NameE-mail suffixDetail
.PHARMACYNational Association of Boards of Pharmacyfairwindspartners.comView
I. Mission and Purpose of .PHARMACY

The National Association of Boards of Pharmacy (“NABP”) is submitting this application on behalf of international pharmacy coalitions and national pharmacy associations to ensure that the .PHARMACY gTLD shall serve as a trusted, hierarchical, and intuitive namespace for legitimate Internet pharmacies. All registrants within this gTLD will be vetted prior to registration to ensure that they meet all applicable regulatory standards, including pharmacy licensure, drug authenticity, and valid prescription requirements. In addition, the registry will incorporate both active and passive safeguards into its operation to ensure that these registrants continue to abide by the terms and conditions set forth in their registration agreements.

NABP and the coalition are also filing this application for defensive purposes to ensure that a .PHARMACY gTLD is kept out of the hands of a third party that for commercial reasons, may turn a blind eye toward illegal and⁄or counterfeit activity within the gTLD. While NABP and the coalition have closely analyzed the objection mechanisms incorporated into the Applicant Guidebook, it was decided that filing this application was the most prudent course of action to protect the collective interests of the consumers who are currently subject to illegal and dangerous pharmaceuticals.

II. The Problem of Rogue Internet Drug Sellers

Online sales of unregulated and counterfeit medicines total an estimated $75 billion per year, and that total is growing. According to NABP research, over 95% of websites selling prescription drugs are out of compliance with applicable laws and regulations. LegitScript estimates that at any one time, there are over 40,000 Internet drug sites in operation. In September 2011, over 50,000 packages shipped from rogue Internet drug sites were seized and found to contain more than 2.4 million illicit and counterfeit pills worth $6.3 million.

In the U.S., prescription drug abuse is now the second-highest drug abuse problem ahead of cocaine, methamphetamine, and heroin use combined. This problem is perpetuated by the availability of dangerous and addictive drugs from illicit sellers online; one in six Americans has purchased medication via the Internet without a valid prescription. According to the World Health Organization (WHO) it is estimated that 8% of bulk drugs imported into the U.S. are counterfeit, unapproved, or substandard.

In addition to risking the health and safety of patients, illegal online drug sales present broader security and criminal risks to society as a whole. According to recent statistics, pharmacy spam constituted 31% of all spam in the fourth quarter of 2011. Also, many of the groups behind these illegal online drug sites have ties to international organized crime syndicates.

III. Partners in the .PHARMACY gTLD Initiative

Although NABP is the formal applicant submitting this application, the .PHARMACY initiative involves a much larger coalition of stakeholders. Below is a representative list of some of the founders behind this initiative. A full and current listing will be available on the NABP website at www.NABP.net.

NABP, founded in 1904, is an impartial professional organization that supports state boards of pharmacy in protecting public health. NABP’s member boards of pharmacy are grouped into eight districts that include all 50 United States, the District of Columbia, Guam, Puerto Rico, the Virgin Islands, Australia, eight Canadian provinces, and New Zealand.

The International Pharmaceutical Federation (FIP) is the global federation of national associations of pharmacists and pharmaceutical scientists and is in official relations with the WHO. Through its 126 member organizations, FIP represents more than two million practitioners and scientists around the world.

The Alliance for Safe Online Pharmacies is an informal international alliance of stakeholders led by a steering committee the purpose of which is to protect patient safety globally and ensure patient access to safe and legitimate online pharmacies in accordance with applicable laws.

The National Association of Chain Drug Stores (“NACDS”) is a membership organization consisting of over 39,000 community pharmacies with over $750 billion in sales. Its mission is to advance the interests and objectives of the chain community pharmacy industry by fostering its growth and promoting its role as a provider of health care services and consumer products.

Eli Lilly and Company is the tenth-largest pharmaceutical company in the world, and has developed productive alliances and partnerships around the world to develop innovative medicines at lower costs.

LegitScript is the leading Internet pharmacy verification and Internet monitoring service in the U.S. Its staff is made up of individuals with extensive background in law, law enforcement, government, health care, technology, and Internet compliance.

IV. Potential Business Models

NABP is still analyzing potential use case options regarding the type of domain names and registrants that will be permitted to be registered within .PHARMACY. While at the outset the coalition consisted primarily of North American entities, the coalition recognized the global scope of this undertaking and has been actively engaged in ongoing education and outreach throughout the global community. Following this initial outreach, the members of the coalition will discuss potential best practices within the .PHARMACY gTLD, which will be mandatory in all domain name registration agreements. However, initially, the following minimum business models and practices are currently anticipated to be incorporated into the gTLD at the time of its launch.

The current best thinking involves a business model in which generic terms (e.g., ʺcholesterol,ʺ ʺblood pressure,ʺ ʺHIV,ʺ etc.) and geographic names (city⁄state) would initially be reserved⁄allocated to develop information portals. The coalition is keenly aware that any new gTLD must be seeded with relevant content to drive traffic and build consumer recognition and trust. Based on an evaluation of the dotAsia Pioneering program, which was incorporated into the launch of the .ASIA gTLD, it is critical that this content be available as soon as possible, ideally before any general registration periods. At the time of filing this application there have been no decisions made regarding how the information portals for .PHARMACY will be developed or who will run them.

NABP is currently evaluating a validation process whereby only online pharmacies and related entities that meet all regulatory standards in the jurisdictions in which they are based and in which they do business, including pharmacy licensure, drug authenticity, and valid prescription requirements, as applicable, would be permitted to register in .PHARMACY. These qualified online pharmacies would only be permitted to register a domain name corresponding to their business or trade name. Specifically, generic domain names not initially reserved⁄allocated by the registry would not initially be permitted to be registered until a proper discussion could take place within the broader community.

All domain names within .PHARMACY would be subject to suspension and⁄or cancellation upon the violation of the terms and conditions set forth in the domain name registration agreement. In addition, the registry will incorporate active and passive safeguards into its operation to ensure that these registrants abide by the terms and conditions set forth in their registration agreements.

As explained in response to Question 22 of this application, NABP would like to make prominent use of geographical identifiers within .PHARMACY in a fair and clear way. It is believed that this hierarchical, intuitive framework of short, memorable domain names will facilitate the ease with which consumers navigate the namespace.
gTLDFull Legal NameE-mail suffixDetail
.dataRomeo Birch, LLCdonuts.coView
Q18A CHAR: 7985

ABOUT DONUTS
Donuts Inc. is the parent applicant for this and multiple other TLDs. The company intends to increase competition and consumer choice at the top level. It will operate these carefully selected TLDs safely and securely in a shared resources business model. To achieve its objectives, Donuts has recruited seasoned executive management with proven track records of excellence in the industry. In addition to this business and operational experience, the Donuts team also has contributed broadly to industry policymaking and regulation, successfully launched TLDs, built industry-leading companies from the ground up, and brought innovation, value and choice to the domain name marketplace.

DONUTS’ PLACE WITHIN ICANN’S MISSION
ICANN and the new TLD program share the following purposes:
1. to make sure that the Internet remains as safe, stable and secure as possible, while
2. helping to ensure there is a vibrant competitive marketplace to efficiently bring the benefits of the namespace to registrants and users alike.

ICANN harnesses the power of private enterprise to bring forth these public benefits. While pursuing its interests, Donuts helps ICANN accomplish its objectives by:

1. Significantly widening competition and choice in Internet identities with hundreds of new top-level domain choices;
2. Providing innovative, robust, and easy-to-use new services, names and tools for users, registrants, registrars, and registries while at the same time safeguarding the rights of others;
3. Designing, launching, and securely operating carefully selected TLDs in multiple languages and character sets; and
4. Providing a financially robust corporate umbrella under which its new TLDs will be protected and can thrive.

ABOUT DONUTS’ RESOURCES
Donuts’ financial resources are extensive. The company has raised more than US$100 million from a number of capital sources including multiple multi-billion dollar venture capital and private equity funds, a top-tier bank, and other well-capitalized investors. Should circumstances warrant, Donuts is prepared to raise additional funding from current or new investors. Donuts also has in place pre-funded, Continued Operations Instruments to protect future registrants. These resource commitments mean Donuts has the capability and intent to launch, expand and operate its TLDs in a secure manner, and to properly protect Internet users and rights-holders from potential abuse.

Donuts firmly believes a capable and skilled organization will operate multiple TLDs and benefit Internet users by:

1. Providing the operational and financial stability necessary for TLDs of all sizes, but particularly for those with smaller volume (which are more likely to succeed within a shared resources and shared services model);
2. Competing more powerfully against incumbent gTLDs; and
3. More thoroughly and uniformly executing consumer and rights holder protections.

THIS TLD
This TLD is attractive and useful to end-users as it better facilitates search, self-expression, information sharing and the provision of legitimate goods and services. Along with the other TLDs in the Donuts family, this TLD will provide Internet users with opportunities for online identities and expression that do not currently exist. In doing so, the TLD will introduce significant consumer choice and competition to the Internet namespace – the very purpose of ICANN’s new TLD program.

This TLD is a generic term and its second level names will be attractive to a variety of Internet users. Making this TLD available to a broad audience of registrants is consistent with the competition goals of the New TLD expansion program, and consistent with ICANN’s objective of maximizing Internet participation. Donuts believes in an open Internet and, accordingly, we will encourage inclusiveness in the registration policies for this TLD. In order to avoid harm to legitimate registrants, Donuts will not artificially deny access, on the basis of identity alone (without legal cause), to a TLD that represents a generic form of activity and expression.

DONUTS’ APPROACH TO PROTECTIONS
No entity, or group of entities, has exclusive rights to own or register second level names in this TLD. There are superior ways to minimize the potential abuse of second level names, and in this application Donuts will describe and commit to an extensive array of protections against abuse, including protections against the abuse of trademark rights.

We recognize some applicants seek to address harms by constraining access to the registration of second level names. However, we believe attempts to limit abuse by limiting registrant eligibility is unnecessarily restrictive and harms users by denying access to many legitimate registrants. Restrictions on second level domain eligibility would prevent law-abiding individuals and organizations from participating in a space to which they are legitimately connected, and would inhibit the sort of positive innovation we intend to see in this TLD. As detailed throughout this application, we have struck the correct balance between consumer and business safety, and open access to second level names.

By applying our array of protection mechanisms, Donuts will make this TLD a place for Internet users that is far safer than existing TLDs. Donuts will strive to operate this TLD with fewer incidences of fraud and abuse than occur in incumbent TLDs. In addition, Donuts commits to work toward a downward trend in such incidents.

OUR PROTECTIONS
Donuts has consulted with and evaluated the ideas of international law enforcement, consumer privacy advocacy organizations, intellectual property interests and other Internet industry groups to create a set of protections that far exceed those in existing TLDs, and bring to the Internet namespace nearly two dozen new rights and protection mechanisms to raise user safety and protection to a new level.

These include eight, innovative and forceful mechanisms and resources that far exceed the already powerful protections in the applicant guidebook. These are:

1. Periodic audit of WhoIs data for accuracy;
2. Remediation of inaccurate Whois data, including takedown, if warranted;
3. A new Domain Protected Marks List (DPML) product for trademark protection;
4. A new Claims Plus product for trademark protection;
5. Terms of use that prohibit illegal or abusive activity;
6. Limitations on domain proxy and privacy service;
7. Published policies and procedures that define abusive activity; and
8. Proper resourcing for all of the functions above.

They also include fourteen new measures that were developed specifically by ICANN for the new TLD process. These are:

1. Controls to ensure proper access to domain management functions;
2. 24⁄7⁄365 abuse point of contact at registry;
3. Procedures for handling complaints of illegal or abusive activity, including remediation and takedown processes;
4. Thick WhoIs;
5. Use of the Trademark Clearinghouse;
6. A Sunrise process;
7. A Trademark Claims process;
8. Adherence to the Uniform Rapid Suspension system;
9. Adherence to the Uniform Domain Name Dispute Resolution Policy;
10. Adherence to the Post Delegation Dispute Resolution Policy;
11. Detailed security policies and procedures;
12. Strong security controls for access, threat analysis and audit;
13. Implementation DNSSEC; and
14. Measures for the prevention of orphan glue records.

DONUTS’ INTENTION FOR THIS TLD
As a senior government authority has recently said, “a successful applicant is entrusted with operating a critical piece of global Internet infrastructure.” Donuts’ plan and intent is for this TLD to serve the international community by bringing new users online through opportunities for economic growth, increased productivity, the exchange of ideas and information and greater self-expression.