This is the wiki page for At-Large comments on the objection statement on community objection grounds against applicant "Stable Tone Limited" for the applied for string ".健康"


Note : As per RALO advice, this objection statement is not being considered by the ALAC.

Information about the applicant Stable Tone Limited

Provided by :

(updated March 6 2013 with link to PIC)


Primary Contact
Application ID
健康Stable Tone LimitedHK  Mike Rodenbaughstabletonetld@rodenbaugh.com1-1708-88054 YesYes


The applicant details can be viewed at

Link to applicant Public Interest Commitments (PIC) : jiankang_PIC_statement.pdf

Objection Statement produced by the gTLD RG for RALO review (updated March 1 2013)

The PDF of the objection statement can be viewed at draft-objection-statement-against-applicant-Stable-Tone-Limited-for-健康-1-mar-2013.pdf

(Note : The objection statement released on 25 February 2013 was updated on March 1 2013 to remove incorrect references to another applicant in the statement.)

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.  gTLD RG members gave the factors of the 4 tests a "pass" and therefore, an objection statement was drafted by the gTLD RG based on this initial review. 

Comment on this objection statement

Please review the initial comments that were received by the gTLD RG. At-Large members are encouraged to read and post comments. 

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 and the group will update this wiki page.

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.


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  1. 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

  2. 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 Feb 2013.pdf

    Health Community Objection table.pdf

  3. Question from Garth Bruen. gTLD RG member


    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. Response by applicant received 27 February 2013 :

    View attachment Dot Healthy Statement.pdf

    Dear Dev,

    Please find attached a note I have received from Stéphane Van Gelder who
    represents the ".healthy" (Dot JianKang Chinese IDN) new gTLD applicant.
    Please be so kind to include this in your records.

    Stéphane has advised me that he would be happy to respond to any enquiry
    about this application and would be ready to participate in any
    conference call should this help the ALAC in formulating its decisions.

    Kind regards,

    Olivier MJ Crépin-Leblond
    ALAC Chair

    View attachment Dot Healthy Statement.pdf 

  5. Message from Mike Rodenbaugh sent to Alan Greenberg, ALAC member who forwarded to the gTD RG

    From: Mike Rodenbaugh <>
    To: Alan Greenberg
    Subject: Stable Tone TLD application
    Date: Thu, 28 Feb 2013 09:59:48 -0800

    I represent Stable Tone Ltd. in its application for the . $B7r9/(B TLD.  We understand that applications for .health TLDs have raised concern at the World Health Organization, and consequently among a few governments and some individuals involved with ALAC.  We understand that you are on ALAC$B!G(Bs new gTLD review committee, so I am reaching out with my this information about our position.  I am happy to discuss or answer any other questions you may have.
    Stable Tone feels strongly that its application for a Chinese-language IDN string which loosely translates to .WELLNESS or .HEALTHY should not be included in these objections.   Our string is aimed at a lifestyle. In the broadest possible sense, we aim to promote healthy living and general wellness. Our string is not focussed on the type of specific health related services that may be within the ambit of any regulated industry such as the medical industry.
    The string we are applying for will help Chinese communities gain access to content promoting a healthy lifestyle. This is a Chinese character string, in IDN format, and not an ASCII string aimed at European or North American Internet users who might misunderstand the use of the term "health".
    The string is pronounced "jiankang" and can therefore in no way be confused with the English-language term "health". This is a strong semantic difference. We will serve Chinese users interested in a certain type of lifestyle and in doing so, we will be quite distinct from the medical or pharmaceutical industry. 
    Further, as a Chinese character string, .JIANKANG will be heavily scrutinized by the Chinese authorities themselves. China has strict law and regulatory practices concerning the Internet. Should our use of the TLD .JIANKANG be considered a potential hazard to Internet users as far as health is concerned, this might be blocked by the government immediately.  Our government will be watching us carefully to ensure that we do not deviate from our intended path of providing healthy lifestyle advice.
    We are registered in Hong-Kong and 95% of our market is expected to be in China itself. We therefore intend to comply with any relevant rules and policies put in place by the Chinese government. Most of Stable Tone's management staff are Chinese citizens and could be affected under the Chinese legal system should we not comply with relevant legal standards.
    It is important to understand that our intent with this TLD is to serve the Chinese market. Our emphasis is on healthy living, very much at the heart of the Chinese culture for thousands of years, and a concept which in our country is completely integrated into our daily lives. For the Chinese, there is a clear distinction between this and the medical industry.
    Our TLD .JIANKANG will carry that distinction and be very clearly positioned as a resource providing Internet users which a beneficial service to them in their everyday lives. Our TLD is absolutely not aimed at providing medical or pharmaceutical care.
    We respectfully ask you to bear this important distinction in mind and not assimilate .JIANKANG with other applications for the ASCII term "health", which may be in a different category and aimed at serving a different use.
    Kind regards,
    Mike Rodenbaugh
    tel/fax:  +1.415.738.8087

  6. Dev,

    Thanks for posting these. Given our previous discussions on this issue, the additional information from the applicant, and the fact that ICANN has not answered our question to the specifics, I move and request that this particular objection be REMOVED from the list of objections to .HEALTH. The application criteria for the IDN  does not appear to be covered by the .HEALTH objection. It would be prejudicial, in my opinion, to subject this application to an objection under the same "blanket" as the other four objections (of which I also have concerns)

    Thanks, Garth

  7. Following to my comments given at the APRALO Monthly call on Feb.26, I assume at-large should have a second thought on whether to lodge an objection against the IDN string .健康. If we take a careful look at the IMIA's contention, we could see it states that "Currently there are five applications for “.health”, four of which are in English and one in Chinese script." As I stated at the call, the contentionis flaws because the IDN string, lingustically, is not equivalent to .health. Meaningfully, the IDN sting refers more to "private well-being" than to "public health". I also agree with Garth that it might not be prudent to lodge the objection based on an arbitral translation of the meaning of an IDN string.  

  8. Message from Stéphane Van Gelder Consulting

    Attachment : jiankang_PIC_statement.pdf

    ---------- Forwarded message ----------
    From: Stéphane Van Gelder Consulting <svg at>
    Date: Wed, Mar 6, 2013 at 4:51 PM
    Subject: PIC submission for .jiankang (.健康).
    To: DEVTee at
    Cc: Jasonscdu <jasonscdu at>
    Hi Dev,
    On behalf of Stable Tone, applicant for the .jiankang (.健康). IDN gTLD,
    please find attached the PIC submission.
    If you feel that it might be useful to do so, please share with your
    colleagues in ALAC. Please do not hesitate to contact us with any
    questions you may have.
    Kind regards,
    Stéphane Van Gelder
    Chairman and Managing Director/Fondateur
  9. Reply from Dev Anand Teelucksingh, gTLD RG chair to Joan Dzenowagis, World Health Organisation (WHO) Geneva

    Dear Joan Dzenowagis, Thanks for your email. By reply I am posting this to other members of the gTLD Review Group (gTLD RG) in charge of coordinating the process by which the ALAC can object to new gTLD applications (see PDF at for a summary of this process) Currently, 5 objection statements are undergoing Regional At-Large Organisation (RALO) review and all can be viewed at this page : Discussion by the RALOs on the applicants and the objection statements can be viewed on the RALO mailing list archives NARALO : APRALO : LACRALO : (web page) Any comments you wish to send re: objections statements will be uploaded to the appropriate webpages for the objection statements for viewing by the At-Large community as well as the ALAC which will be considering the RALO advice on Friday March 8 2013. Any such comments should be sent before the ALAC call on Friday March 8 2013. Kind Regards, Dev Anand Teelucksingh gTLD RG chair On Wed, Mar 6, 2013 at 6:57 PM, DZENOWAGIS, Joan Helen <dzenowagisj at> wrote: > Dear Dev,

    I'm aware that there are questions about the above objections, some of which relate to WHO.
    We would appreciate the opportunity to address them directly, as some of the assertions by
    an applicant are inaccurate and/or misleading and this must be corrected.

    As you know, we have previously written to ICANN about our concerns and we are working
    within the ICANN process as we understand it. A number of global NGOs also share our concerns
    and have asked how they can support the objection. I would appreciate your guidance on how
    they can do this.

    > I hope you can accommodate the time difference in your deliberations, as it is 24.00hrs in Geneva,
    to give us the chance to respond. Thank you for your consideration.

    > Joan Dzenowagis, WHO Geneva
  10. Message from Célia Boyer, Executive Director Health On the Net :

    Attachment :

    Dear Sir or Madam, Please find attached the official letter from the Health On the Net, an NGO organisation which support*s highly** At-Large New gTLD Review Group for *_*considering filling an Objection to the 5 proposed .health gTLD applications (including the .health application in Chinese).*_ Thank you very much for your consideration. Yours sincerely Célia Boyer Executive Director Health On the Net -- ______________________________________________________ CéliaBOYER Executive Director *H*ealth *O*n the *N*et Foundation NGO in Special Consultative Status with the United Nations Tél: +41 22 3726250 - Fax: +41 22 3728885 - Web:
  11. Email from David Abreu, COHRED - Council on Health Research for Development :

    Dear Sir or Madam,
    I am writing on behalf of the Council on Health Research for Development –
    COHRED, an international not-for-profit organisation with the mission to
    improve health, equity and development by supporting countries to develop
    strong research and innovation systems. We work globally, but prioritise
    low and middle income countries.
    It has come to our attention that you are considering filing an Objection
    to the 5 proposed .health gTLD applications (including the .health
    application in Chinese).
    We share the concerns of the International Medical Informatics Association
    as noted in their letter of 25 January 2013:
    ü  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.
    ü  There is no guarantee that the new ".health" TLD will be operated in the
    interest of global public health and consumer protection.
    ü  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.
    ü  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 hereby lend the voice of COHRED and our country partners to this
    *David Abreu, MBA*
    Web for Development
    +41 22 591 89 11
    Skype: david_abreu
    COHRED - Council on Health Research for Development
       *Incorporating the Global Forum for Health Research*
    1-5 Route des Morillons
    1211 Geneva 2
    P.O. Box 2100
    Tel: +41 22 591 89 00
    New Resources: 20th Anniversary
    <>, COHRED
    Publications <>
  12. Email from Martine Berger, Health Innovation in Practice :

    Attachment :

    Please find attached a letter of support for filing an objection to the 5 proposed ".health" TLD applications. We thank you in advance for your consideration, On behalf of the Democratising Global Health Coalition Martine Berger, MD, PhD, MPH Director, Health Innovation in Practice Ecumenical Centre 1-5 route des Morillons 1211 Genève Suisse Tel: +41 22 7989852 Mob:+41 78 6280176 mberger at skype: berger.hip
  13. Email from Vanda Scartezini


    I am becoming a little worry about these objections to common names. I saw
    health for instance. The complaint states:
    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
    3.   All of the applicants are commercial in nature and none represent the
    health community.
    Well, who said it cannot be a commercial?  Who said was mandatory to
    represent any community?  Why they need to operate in the public interest
    and not in the private one? And besides, NET, for instance, that is also a
    word in English, now in all languages, has the same approach, and does not
    follow any of the statements above.  Where is the fairness of the process? 
    The number of objection like this one is becoming big and if ICANN  doesn’t
    make a move  to  clarify the rights of these applicants, I believe ICANN
    will be sued  from many fronts, and more relevant, we will NOT have any
    competition at all, since only common names have any attraction to the
    public to jump and buy a domain under that name, others are brands.
    That was the main intention of this new gTLD program, that may risk to be
    I am  really becoming worried about the way things are going.  We cannot
    dismiss applicants for issues they were not supposed to commit under their
    application to new gTLD program.
    In time, I did not applied for any gTLD, so my comment  is because I am not
    seeing any fair approach in these complains. 
    All the best, 
    Vanda Scartezini
    Polo Consultores Associados 
    IT Trend
    Avenida Paulista 1159 cj 1004
    01311-200 São Paulo,SP, Brasil
    Tel + 5511 3266.6253
    Mob + 5511 98181.1464
  14. Email from Dr Marie-Paule Kieny, Assistant Director-General, Health Systems and Innovation, World Health Organization

    Dear Sirs,
    Following the extensive exchange of comments between Eric Brunner-Williams and DotHealth LLC, 
    the World Health Organization (“WHO”) would like to clarify that WHO does not and will not endorse
    or support any particular applicant for .health. WHO has engaged in informative dialogue with
    all applicants with a view to ensuring that the names and acronyms of WHO and its Regional Offices
    will be appropriately protected at the second level within the .health TLD, should it be delegated,
    and with a view to understanding whether and how the applicants are proposing to operate
    the .health TLD in the interest of global public health. However, WHO has not entered into any consultative or advisory process with any of the applicants
    on the development of their policies, commitments or applications in general. Representations by any applicant in that regard would be incorrect and misleading. For the avoidance of doubt, WHO should also like to clarify that the WHO Executive Board
    has not adopted any resolution, 10.5 or otherwise, on the .health TLD and/or the possible engagement
    of WHO with any of the applicants. On another related note, WHO notes that the
    string "健康<>" has
    been translated as “healthy” instead of “health”, and that this difference is used to argue that the
    objection should not proceed. WHO should like to inform the ALAC that the official
    WHO translation of "健康<>"
    is “health” in English. In French it is “santé”, and in Spanish “salud”.
    WHO would therefore ask that the ALAC reconsiders the
    translation of "健康<>" and
    use instead the official WHO translation in determining whether the Objection should proceed or not. We thank you very much for your attention. Best regards, Dr Marie-Paule Kieny Assistant Director-General Health Systems and Innovation World Health Organization Avenue Appia 20 CH1211-Genève 27 Switzerland Tel: +41 22 791 35 91 Fax: +41 22 791 49 09 E-mail: kienym at<mailto:kienym at>
  15. Email from Prof. S. Yunkap Kwankam, PhD | Executive Director, International Scoiety for Telemedicine and eHealth ISfTeH) :

    Attachment :


    Dear Sir / Madame,
    We hereby lend our voice to the objection to the 5 proposed .health gTLD applications by At-Large New gTLD Review Group - see attached letter. Thank for you consideration.
    Prof. S. Yunkap Kwankam, PhD | Executive Director, International Scoiety for Telemedicine and eHealth ISfTeH)
    Chemin des Champs-Blancs 94 | 1279 Chavannes-de-Bogis, Switzerland
    Phone: +41 22 796 6238 | Cell: +41 79 369 0998 | Web: