Application Comment Details

Public Citizen is a consumer advocacy group founded in 1971 and based in Washington, DC. We have more than 300,000 members and supporters. Our areas of organizational focus include, among others, pharmaceutical safety and efficacy as well as access to medicines.

ICANN should reject the National Association of Boards of Pharmacy’s application for the generic top level domain “.pharmacy,” for reasons of public interest.

Granting the .pharmacy domain to NABP would confer legitimacy on pharmacies sanctioned by NABP, to the detriment of those that are not.

NABP has proposed an unfair standard that would bar online pharmacies that serve US consumers but are located outside of the United States from using the domain (see NABP’s application at Section 18(a) IV*). This would exclude many licensed pharmacies which offer American consumers low-cost medicines of quality.

Whether a pharmacy is located in the United States does not determine whether a pharmacy is licensed and provides medicines of quality.

Consumer access to medicines depends in significant part on price and competition. It would be inappropriate to allow NABP to control such an important gTLD while it maintains exclusionary plans for the domain, which work against the consumer interest in a robust market of quality affordable pharmaceuticals.

Peter Maybarduk, JD

Global Access to Medicines Program Director

Public Citizen

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* “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.” [Emphasis added.] Virtually no US states license non-US pharmacies.