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National Association of Boards of Pharmacy
Limited Public Interest Objection Ground
Reject NABP control of .pharmacy domains
Comment Submission Date:14 May 2013 at 20:44:35 UTC
Demand Progress is a 1.5 million member Internet Freedom organization. We represent Internet users around the world. From our direct experience with NABP and its allies in Internet policy disputes, there is ample cause to believe the applicant seeks to control .pharmacy to the detriment of free speech & access to safe and affordable medication for consumers. Members of the pharmaceutical industry who support NABP's application have consistently conflated online retailers selling counterfeit drug sales with those selling legitimate products. Their true goal is to control markets and gain the ability to disconnect competitors from the Net. See eg: http://www.techdirt.com/articles/20110520/02012914349/senator-leahy-supports-bringing-drugs-canada-also-banning-such-sites-internet.shtml
NABP’s application is funded by drug companies with a conflict of interest. Furthermore, the Alliance for Safe Online Pharmacy (ASOP), another NABP “partner” was a strong supporter of the Stop Online Piracy Act (aka SOPA) & other online censorship bills. The pharmaceutical industry has prioritized trying to shut down legitimate pharmacies selling safe Canadian drugs to U.S. consumers (as currently allowed by the U.S. Food and Drug Administration). But their tactics to achieve these anti-consumer goals involve censorship regimes allowing government seizure of domains, blacklists of sites, or suspended hosting services for legitimate competitors.
NABP supporters have justified their actions by preying on consumer fear of counterfeiters, when their real goals include shutting down sites providing cheaper legitimate drugs. Pfizer joined the assault on the Net in 2011, testifying to Congress that: "The major threat to patients in the U.S., however, is the Internet.... Pharmacies displaying the VIPPS seal have demonstrated to NABP compliance with VIPPS criteria.... VIPPS pharmacies represent only a small percentage of online pharmacies. " Source: http://judiciary.house.gov/hearings/pdf/Clark%2011162011.pdf
NABP's supporters define "fake pharmacies" as those not registered with VIPPS, rather than only those selling actual counterfeit goods. In 2011, Eli Lilly (a supporter of NABP's application) endorsed censorship legislation called the Protect IP Act. In a blog post, they wrote: "PROTECT IP Act will help provide law enforcement with the tools they require to shut down illegal online distributors of counterfeit products.... A section in the new legislation provides safe harbor to private companies, like search engines, who want to protect patients by enforcing their own contracts and shutting off services...." Source: http://lillypad.lilly.com/entry.php?id=1465
Eli Lilly is also a member of ASOP who in 2011 published their goals of knocking entire businesses offline: "Congress introduced the Stop Online Piracy Act in the U.S. House of Representatives.... The bill encourages private companies to stop doing business with illegal online drug sellers that endanger public health. Included are companies that host these sites, provide associated advertising or help facilitate their payment transactions...." Source: http://www.washingtontimes.com/news/2011/nov/10/rogue-internet-drug-sellers-put-us-at-risk/
NABP is attempting to achieve results through ICANN that they were not able to obtain legislatively. One can fairly surmise NABP's true goal is anti-competitve, anti-consumer, and anti-speech activity. ICANN should reject their application.
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