Application Comment Details


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Lee Graczyk

RxRights

National Association of Boards of Pharmacy

PHARMACY

1-1040-55064

Community Objection Ground

Concern re: NABP .PHARMACY application

26 March 2013 at 21:24:44 UTC

RxRights is a national coalition of individuals and organizations concerned with the high cost of U.S. pharmaceuticals. We are dedicated to promoting and protecting American consumer access to sources of safe, affordable prescription drugs. We sent a letter to the National Association of Boards of Pharmacy (NABP) on March 12 [http://www.rxrights.org/public/doc/NABPLetter.pdf] expressing concern with their application for the .PHARMACY gTLD, due to potential discriminatory policies that could exclude licensed, non-US pharmacies from registering .PHARMACY domains.

RxRights is concerned that the .PHARMACY registration agreement may seek to disqualify fully regulated and legitimate Canadian and other international pharmacies, including members of the Canadian International Pharmacy Association, PharmacyChecker.com and Pharmacy Accreditation Services. This would be anti-competitive and detrimental to consumers.

We sought assurances that NABP, as .PHARMACY registry operator, will refrain from adopting a registration agreement which results in discriminatory treatment. The goal of .PHARMACY should be to provide a trusted space in which only regulated pharmacies selling legitimate drugs can have websites. It should not be used to pursue an agenda best left to elected officials, trade representatives, national law enforcement, and drug regulatory agencies. However, our outreach to NABP was ignored.

Over a million Americans import prescription drugs from international online pharmacies. Empirical study shows that the biggest barrier to medication adherence is cost. Forty-eight million Americans did not fill a prescription due to cost in 2010, according to the Commonwealth Fund. Therefore, consumers will most benefit from a trusted, open, and competitive .PHARMACY space. It should not be used to protect the market share of U.S. pharmaceutical entities nor settle cross-border legal ambiguities to consumers’ detriment.

If NABP’s intent is to exclude real “rogue” sites we are fully supportive. Unfortunately, the NABP has a history of grouping dangerous “rogue” pharmacy sites with safe, licensed international pharmacies. RxRights believes consumers deserve Internet governance that maximizes safety, low prices, and innovation.

The pending .PHARMACY application should be placed on hold until the applicant revises it to open .PHARMACY to all legitimate pharmacies. Such revisions should at least address:

1) Consultation with a global set of qualified pharmacies, including international pharmacies, and their organizational representatives;

2) Fast Track development of registration criteria acceptable to potential registrants;

3) Enforcement mechanisms for registration requirement compliance;

4) Information about domain registration and other fees;

5) Impartial appeals process for registration denials;

6) Process for review and updating of registration criteria policies; and

7) Advisory role of regulatory authorities.

A .PHARMACY gTLD that caters primarily to US-based registrants, is funded by U.S. pharmaceutical companies, and denies domain registrations to legitimate pharmacies is not an appropriate use of a unique global DNS resource. There are too many unanswered questions about the .PHARMACY application and registration criteria to allow its approval and delegation without further review and significant amendment and clarification. We therefore oppose approval until all relevant issues have been satisfactorily addressed.