18(b) How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?
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At DotHealth, LLC (“DotHealth”), our goal is to make the Internet a safer, reliable and genuinely trustworthy resource for all stakeholders in health. We believe that the .health TLD will greatly enhance and improve the ways that health information and resources are discovered, accessed and utilized via the Internet.
To achieve these goals and objectives, DotHealth will adopt and enforce a series of registry policies, active safeguards and procedures, and work in cooperation with its partners, Neustar and LegitScript to formally distinguish the .health TLD as a “quality label” for health-related websites that adhere to a set of guidelines for safety, reliability and trust. Affirmations of support for these policies and procedures have been secured from numerous global and regional health and wellness industry associations and non-governmental organizations throughout the world. These include the Inter-American College of Physicians, National Association of Boards of Pharmacy (NABP), the World Federation of Chiropractic, the Association of Black Cardiologists and the Regulatory Harmonization Institute.
We envision that .health will appeal to a large, broad, diverse and international addressable market of registrants spanning all major segments of the human health, personal care and animal health industries. DotHealth forecasts that the life sciences and consumer health product segments will comprise the largest segments of the addressable market for .health, as these segments are aggressively shifting their promotional and educational spending from traditional mediums (television, radio, print etc.) to digital channels, including the Internet and mobile devices. Digital resource allocation in support of these goals and campaigns has also shifted from traditional banner advertising toward the creation of “custom online health centers” devoted to a particular disease, condition, or health-related matter. In particular, we believe the pharmaceutical industry will find .health domain names as an attractive alternative to their existing .com or other TLD counterparts for distinguishing non-promotional product-related content or labeling information in order to comply with recently established or newly emerging FDA regulatory guidance for domain names and online resources. Because hundreds of major disease state or condition-related strings are unavailable for registration, the availability of these names in .health will also foster competition in the current domain name space and among those seeking to “own an online health category.”
DotHealth also envisions that physicians, hospitals and other provider organizations throughout the world will value .health as a safe and reliable resource for communicating and exchanging information with patients and caregivers about their practice or services. In 2011, in the U.S., President Obama ratified the HITECH Act which will make it easier for doctors and other health care professionals to receive incentive payments for adopting and meaningfully using health information technology modules, including patient education web sites and portals which can leverage .health domain names in support of these interventions.
Because “health” can be associated beyond “wellness” or “disease,” we believe that numerous other market segments and industries outside of the “health” industry will find .health to be an attractive domain name solution for positioning their organizations, products, programs and services. For example, restaurants, which offer “health-conscious” menu options, could utilize .health domain names for specifically marketing or promoting them to consumers. For those engaged in the medical tourism arena, travel and hospitality-related businesses (e.g., hotels or cruise ships) could utilize .health domain names to promote their locations on a “health-related” basis. Employers may wish to utilize .health names for their businesses in support of disseminating information about health insurance programs or services they make available to employees. Major technology companies which provide solutions and services to multiple industries might find .health useful for distinguishing their product⁄service information and resources that specifically cater to health or health stakeholders. For example, IBM could utilize IBM.health instead of http:⁄⁄www-935.ibm.com⁄services⁄us⁄gbs⁄industries⁄healthcare⁄?cm_re=masthead-_-solutions-_-ind-health in this regard.
As previously stated above, our goal is to make the Internet a safer, reliable and genuinely trustworthy resource for all stakeholders in health. For the .health TLD, in order to enable a safe and reliable online experience for end-users, and in recognition of the challenges and risks that exist in the current online landscape for registrants and end-users, numerous policies, safeguards and standard operating procedures have been identified for the .health TLD which will be enforced and actively monitored for compliance by DotHealth in conjunction with Neustar and LegitScript. Online content on websites discoverable via general search engines is still the mainstay of the digital health landscape. For the average consumer, finding accurate and trustworthy health information can be difficult. When a trusted source isn’t known, online health seekers become especially vulnerable to the dangers of inaccurate or misleading information when they take action with the information they find. Abusive practices and malicious behaviors including email spam, search-engine optimization, social network abuse, typo-squatting, and others are commonplace in online health, and virtually all rely on domain name resolution to direct recipients. These practices and behaviors are commonly classified as “false association,” whereby the information that is discovered or accessed may appear recognizable or trustworthy, but the associated hyperlinks actually resolve to domain names and web sites that aren’t authentic, safe or reliable. Whether accessed through direct navigation, through an organic search result, an e-mail message or otherwise, just clicking on the links themselves can be dangerous, particularly when a user is directed to a domain name that automatically installs malware or poses other threats to user privacy or security. While major search engines like Google now have strong governance in place to restrict rogue online pharmacies from placing paid search advertisements, these do not prevent or inhibit organic searches and email messages with links utilizing health-related keywords or brand names are increasingly at the center of click-fraud and scams that pose harm to health consumers and rightsholders alike. Recently, there has been a push for domain registrars to take a more active role in addressing these risks, although at DotHealth and for the .health gTLD, we intend to eradicate them in the interest of consumer safety and registrant protection at the Registry level. False association also poses various risks to rightsholders, which are of major concern to intellectual property stakeholders throughout the global health sciences industry. Online counterfeit drug sales and “rogue” sources utilize abusive domain name registrations, typo squatting and brand-jacking to exploit health-related trademarks at the expense of rightsholders. According to the World Intellectual Property Organization (WIPO), the biotechnology and pharmaceutical industry sectors rank among the highest of all domain name complainant activity, with over 8% of all cases reported in 2011.
With 173 million U.S. adults using the Internet for health, and 116 million online specifically for prescription drug or pharmaceutical company resources, our proposed approaches are fully justified and are at the center of DotHealth’s plans and strategies for differentiating .health as a safer and more reliable namespace as compared to its other current and future TLD counterparts. In recognition of these challenges and risks, as the .health Registry Operator, we intend to expressly reserve the right to deny, cancel or transfer any registration that it deems necessary, in its discretion, to protect the integrity and stability of the registry. The DotHealth Registration and Acceptable Use policies we have developed will expressly prohibit the use of .health domain names to support of the illicit promotion or sale of prescription drugs, controlled substances, tainted dietary supplements, ingredients for psychoactive highs, and other substances or ingredients which are have been validated as safety concerns by the U.S. Food and Drug Administration (FDA), the Drug Enforcement Administration (DEA), The European Medicines Agency (EMEA) and⁄or other regional or international regulatory authorities or law enforcement agencies. Registrant compliance with the DotHealth Acceptable Use Policy will be vigilantly monitored and strictly enforced on a daily basis in conjunction with Neustar and LegitScript.
In the interest of protecting rightsholders and intellectual property stakeholders, as well as end-users, numerous operating procedures, safeguards and policies have been identified and orchestrated in conjunction with our proposed efforts to operate the .health TLD registry. These include an extended Sunrise phase as well ongoing cooperation with the newly formed Trademark Clearinghouse and registrars to provide notification services and alerts to ensure rightsholders can stopgap risks for abusive domain name registrations before they are enabled in the .health DNS zone.
To protect the privacy or confidential information of registrants and end-users, The .health TLD registry solution will leverage Neustar’s architecture which includes multiple layers of security, diversified firewall and networking hardware vendors, multi-factor authentication for accessing registry systems, physical security access controls, a 24x7 manned Network Operations Center that monitors all systems and applications, and a 24x7 manned Security Operations Center that monitors and mitigates DDoS attacks.
Outreach and communications will play an important role in helping DotHealth to achieve our projected benefits. Stakeholders of all kinds – commercial, non-commercial, government organizations and others will need to be educated about the benefits of new gTLDs as they relate to their meaningful use interests, use cases and business models. To establish awareness and adoption of the .health TLD, we plan to utilize various types of health sciences and consumer media channels, events and conferences, and social networks to strategically and regularly deliver key messages regarding the value and benefits of .health, and to communicate our progress and growth. DotHealth also plans to feature a “Resource Center” on our Website for registrants to utilize in order to find an authorized .health registrar, to access our policies, as well as other recommended resources for launching and optimizing the discovery of .health domain names. The Resource Center will also feature examples of .health web sites as credible and trusted sources, identified across various categories in conjunction with accreditation programs that will be executed our industry partners and premium name customers.
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