This is the wiki page for At-Large comments on "Limited Public Interest" and "Community Objection" Grounds for the applied for string ".health".

The ALAC has standing to object to a gTLD application on Limited Public Interest Objection Grounds and community objection grounds

The following are the applicants for the ".health" applied for string.


Primary Contact
Application ID
HEALTHDotHealth, LLCUS  Mr. Andrew Ryan Weissbergweissberga@gmail.com1-1684-6394YesYes
HEALTHGoose Fest, LLCUS  Daniel Schindlergoosefest@donuts.co1-1489-82287 Yes
HEALTHdot Health LimitedGI  Mr. Geir Andreas Rasmussenicanntas6@famousfourmedia.com1-1178-3236YesYes
HEALTHAfilias LimitedIE  John Kanejkane@afilias.info1-868-3442 Yes


Note: on the RG call on the 25 February 2013, concerns by several RG members regarding the suitability of inclusion of the objection of the application for the "健康" string being grouped with the four applications for the "health" string.

The objection comments and draft statement of the application for the "健康" string was moved to its own wiki page 健康_OG




NOTE: You must be logged in to post comments. If you do not have a wiki account, please email your comment to the gTLD RG group at

The gTLD RG reserves the right to remove comments that do not adhere to ICANN's Expected Standards of Behavior and Open Comment Forum Process and Standards.


Decision by the gTLD RG (8 February 2013)

Members of the gTLD RG considered the comments from the At-Large community as of February 8 2013 and ranked each factor of the four tests for community objection grounds based on these comments and discussions. 

Objection statements on community grounds will be drafted for the applications for .health given that the four tests for community objection grounds were passed. The gTLD RG will attempt to put together the objection statements to the applications for .health in time for RALO review around 22 February 2013.


Draft Objection statement




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  1. Limited Public Interest Grounds

    Please reply under this comment thread if your comment is on Limited Public Interest Objection Grounds

  2. Community Objection Grounds

    Please reply under this comment thread if your comment is on Community Objection Grounds

  3. Comment received from International Medical Informatics Association 

    Request to consider an Objection for the “.health” new gTLDs

    Dear Sir or Madam,

    This note is to request the ALAC to consider filing an objection for the applications for the “.health” new gTLD, on Community objection grounds. Currently there are five applications for “.health”, four of which are in English and one in Chinese script. These five proposals are seen as problematic by the global health community for the following reasons:

    1. None of the applicants demonstrates that the name will be operated in the public interest.
    2. None of the applicants demonstrates adequate consumer protection mechanisms.
    3. All of the applicants are commercial in nature and none represent the health community.


    Basis for Community Opposition to the ‘.health’ TLD applications

    In 2012, a number of stakeholders expressed concerns about the creation of the new “.health” gTLD by current applicants and requested that its allocation, in all UN languages, be postponed to allow for the consultation of global health stakeholders. Examples include:

    • The governments of France and Mali have issued ‘Early Warnings’ for the five “.health” applications

    • A number of NGOs in official relations with the World Health Organization (WHO) have posted Comments on the ICANN Public Forum and written to ICANN and the Government Advisory Committee (GAC)

    • WHO has written to ICANN and the GAC 

     • The European Commission has issued a letter to ICANN, noting ‘.health’ among others, as a sensitive string 

    The concern of the Community is along the following lines:

    • The “.health” TLD should be a trusted resource for health, in particular to counter current international challenges such as fraud, identity theft, illicit sale of pharmaceuticals, security, protection of minors and so on. 
    • There is no guarantee that the new “.health” TLD will be operated in the interest of global public health and consumer protection.
    • The “.health” TLD without the adequate quality assurance and consumer protection mechanisms in place will undermine credibility and harm the growth of the health online market place. An open and unrestricted TLD will help to bypass regulatory controls creating new risks for the whole industry sector. 
    • Developing countries will suffer the most in this scenario, due to their difficulties in enforcing national policies to regulate, monitor, and stop fraud and misuse. 

    We have read the conditions for Community Objection grounds, and believe there are sufficient grounds on which to make an objection. We would be pleased to provide further detailed information, based on an analysis of the applications and with the health community, to support the Objection, should you decide to proceed.


    Best regards,


    Antoine Geissbuhler
    President of the International Medical Informatics Association

      1. Email received from Antonine Geissbuhler, International Medical Informatics Association:

        Dear Dev,
        Please find attached an Overview file and the Health Community Objection Table, as requested.


        Health Community Objection 20 Feb2013.docx

        Health Community Objection-table.docx


        1. Email received from Andrew Weissberg

          Hello Dev,
          In this case that Antoine may have not shared this information with
          you or your colleagues in the ALAC New gTLD Review Group, I thought it
          might be useful toward your continued preparation of objection
          statements against applications for the .health gTLD, including the
          DotHealth, LLC application.
          Very truly yours,
          Andy Weissberg
          From: Andrew Weissberg <andyw at>
          Date: Wednesday, February 20, 2013 12:05 AM
          To: <antoine.geissbuhler at>
          Cc: Neil Posner <neil.posner at>, Richard
          Butcher <richardobutcher2 at>, "john.horton at"
          <john.horton at>, "Neuman, Jeff"
          <Jeff.Neuman at>, Jose Rasco
          <jose.rasco at>
          Subject: Information Regarding DotHealth, LLC and its .health TLD Application
          Hello Antoine,
          I am reaching out on behalf of DotHealth, LLC in response to the
          comments and recommendations you shared with the ALAC New gTLD Review
          Group on 1/26/13.

          We have prepared the attached information for your review in support
          of the IMIA's continued deliberations with the ALAC New gTLD Review
          Group surrounding the potential filing of community objections against
          applications for .health.  The attached document aims to ensure that
          you and the RG have a clear understanding of our proposed plans and
          approaches for the .health TLD, and how these are fully aligned and
          credibly positioned to address the issues and concerns that you have
          raised to the ALAC in support of public health interests.
          Respecting and appreciating that the IMIA is an important and
          prominent NGO constituency of the World Health Organization (WHO), and
          given the numerous references to the WHO's concerns and positions
          regarding .health as referenced within your comments, I also feel that
          it is important, timely and appropriate to also share this information
          with the Innovation Directorate of the WHO.  Apart from our views that
          an ALAC community objection against the DotHealth, LLC application for
          .health is neither reasonable or plausible, we believe such an
          objection does not fall in alignment with the WHO Executive Board's
          recent policy paper and Member State discussions surrounding .health
          and health-related domain names.
          As you and your colleagues in the ALAC New gTLD Review Group continue
          to review and finalize plans surrounding .health, I would welcome the
          opportunity to engage directly regarding these matters.
          Andy Weissberg
          Andy Weissberg
          Co-founder and CEO
          DotHealth, LLC
          Andyw at


        2. Dev,

          In reviewing the details of this objection in preparation for the RG statement I have come to some curious questions. The IMIA did not file an objection to .MEDICAL which is a word that actually appears in title of the International Medical Informatics Association. The .MEDICAL application is also by Donuts, so all of the IMIA's objections to the Donuts .HEALTH application would not only apply to .MEDICAL and in a more targeted sense. .MEDICAL is also uncontested which would make the objection less complicated. A similar question could be asked about the .HEALTHCARE application, also an uncontested Donuts application. I am interested in knowing why "health" is more important or potentially harmful than these other strings (also .DENTIST, .DENTAL, .DOCTOR, .HOSPITAL, .SURGERY).


          1. Reply from Antoine Geissbuhler :

            Dear Dev,
            Apologies for the late answer, but I was travelling in poorly connected areas. We had discussions about the issue of the many names that are related to health and healthcare,
            not even considering their possible translations. IMIA's priority is to make sure that one TLD can be protected and identified as a
            safer place for health information. The name is well within the scope of IMIA's mission, and meets the need to preserve
            the name for the global health community. Regarding the other names mentioned,
            some are also facing the issue that they may be regulated in some
            countries, e.g., .doctor, .dentist, but these names are all too limited and specialized
            to be a good fit for IMIA to object to (even medical). I hope that this clarification helps,
            With kind regards, Antoine Geissbuhler
  4. Email received from Andrew Weissberg Feb 25 2013  :

    Hello Adela and Dev,
    In continuing to review the draft of the community objection being prepared, and having seen in the draft's section on "targeting," I thought it would be helpful to clarify a few important items with respect to this issue as it relates to the DotHealth, LLC application for the .health TLD.
    In the current draft, there is a statement:
    "Point 18(a) and (b) descriptions mention as stakeholders the following categories: physicians and healthcare professionals, institutions (health services) and patients (consumers), as well as the associated industries (pharmaceutical industry, medical tourism, food industry, health insurance, etc)." 
    Clarifying points and for the RG's consideration:
    1. Question 18(b) in the AGB requested that applicants provide answers to the following questions (note those words which are italicized or bold-faced type below):
      • How do you expect that your proposed gTLD will benefit registrants, Internet users, and others?  Answers should address the following points:
    • What is the goal of your proposed gTLD in terms of areas of specialty, service levels, or reputation?
    • What do you anticipate your proposed gTLD will add to the current space, in terms of competition, differentiation, or innovation?
    • What goals does your proposed gTLD have in terms of user experience?
    • Will your proposed gTLD impose any measures for protecting the privacy or confidential information of registrants or users? If so, please describe any such measures.
    At no point has DotHealth suggested in its application that it would explicitly or implicitly target a “community of health” as part of its standard application to ICANN for the .health TLD.  However in order to adequately, sufficiently and appropriately answer the above questions, we expressed our expectations that 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. Furthermore,  appropriate reasoning was provided and further explained by example. As contained within the DotHealth, LLC application and specifically as part of its answer to Question 18(b), the following statements were made:
    “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."
    "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.
    Throughout our application to ICANN, we have repeatedly stated that our mission is to establish .health as a safe, trustworthy and secure top-level domain for global health stakeholders.   To ensure success, we have identified and orchestrated a policy framework and numerous safeguards that are designed to mitigate abusive registrations and malicious behaviors which may pose harm to registrants and consumers, or which may otherwise threaten the integrity and stability of the .health registry.
    None of the above, however, should serve to inappropriately construe that DotHealth, LLC will explicitly or implicitly target the broad and diverse addressable market of registrants we have identified, particularly with respect to doing so as a matter of "detriment" or "harm" for that matter.  Furthermore, many other portions of our answers to Question 18(b) and throughout our application — specifically within our answers to Questions 22, 28, 29 and 30 serve to reinforce the important reasoning for which we have identified and committed to implementing the numerous policies, safeguards, security protocols, and governance measures in support of the safety and protection of public health and end-users — and particularly those cited by the IMIA in support of the ALAC's proposed community objection to applications for .health.     
    Lastly, the Review Group may want to revisit other information that ICANN has requested of new gTLD Registry applicants throughout the AGB which are relevant to issues of "targeting."  
    For example, in Question 48, ICANN provides "criteria" to which applicants must address with respect to the "target markets" an applicant has identified:
    "Funding commitments may be conditional on the approval of the application. Sources of capital funding required to sustain registry operations on an on-going basis are identified. The projected revenues are consistent with the size and projected penetration of the target markets."
    Although ICANN has not publicly posted any of the applicants confidential information or answers in support of these questions, I feel it is important that the review group recognizes these issues as being relevant and considered in the context of targeting.  
    As the ALAC New gTLD Review group continues its deliberations surrounding community objections to the DotHealth, LLC application, I hope all of the above is useful and would be happy to discuss on a call if needed.
    Best regards,
    Andy Weissberg
    Andy Weissberg, Co-founder and CEO
    DotHealth, LLC