[NA-Discuss] FW: [New gTLD RG] PICs posted by applicants "dot Health Limited" and "DotHealth, LLC"

Eric Brunner-Williams ebw at abenaki.wabanaki.net
Wed Mar 6 18:20:02 UTC 2013

My careful reading shows no indication that the text of the PIC has
been communicated to any endorsing third party. This seems at odds
with the claim that the policy is the product of three and a half
years of extensive efforts and great care, but perhaps outreach to
third party agencies is not the ordinary business practice of Mr.
Weissberg's entity. I've no way of knowing, but I was looking for the
endorsements of the text by parties other than the beneficiary applicant.

The following, which appears as "Other Specific Public Interest
Committments (Spwcification 11, Paragraph 3), I find interesting.

> Commitment to the Protection of the World Health Organization Names and/or Acronyms
> DotHealth, LLC shall commit to consult with the World Health Organization on the protection of
> appropriate second level domain names within the .health TLD in order to withhold their use by
> any third party where such protection is deemed to be in the public interest. 

Mr. Weissberg does not inform the reader if the World Health
Organization is even cognizant of this commitment.

Nor is the reader informed specifically as to the modality of this
consultation with the World Health Organization.

Nor is the reader informed specifically how, and by whom, the public
interest evaluation of third party registrations is to be effected.

In my opinion this PIC does not rise to the level of prudence and care
likely to (a) permit effective community policy formation or (b)
prevent the most likely forms of abuse.

Eric Brunner-Williams

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