The rationale for .pharmacy is a strong one particularly in lieu of the global increase in online purchasing and door-to-door delivery. Our new economy is one in which many consumers want the convenience of avoiding trips to a brick-and-mortar store. However, online fraud is rampant. So this level of vetting and security could go a long way in reassuring consumers that something as important as medication is at minimal risk of fraud. Similar security measures with .BANK is also a very good idea.

We at Public Citizen, a consumer advocacy organization based in Washington, filed comments with ICANN, expressing our view that ICANN should reject the National Association of Boards of Pharmacy’s application for the generic top level domain “.pharmacy,” for reasons of public interest.

NABP’s control of the .pharmacy domain confers legitimacy on pharmacies sanctioned by NABP, to the detriment of those that are not.

In its application to ICANN, NABP proposed an unfair standard that would bar online pharmacies that serve U.S. consumers but are located outside of the United States from using the domain (see NABP’s application at Section 18(a) IV*). This would exclude many licensed pharmacies which offer American consumers low-cost medicines of quality.

Whether a pharmacy is located in the United States does not determine whether a pharmacy is licensed and provides medicines of quality.

Consumer access to medicines depends in significant part on price and competition. It is inappropriate to allow NABP to control such an important gTLD while it maintains exclusionary plans for the domain, which work against the consumer interest in a robust market of quality affordable pharmaceuticals.

Peter Maybarduk
Public Citizen

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Public Citizen is a consumer advocacy group founded in 1971 and based in Washington, DC. We have more than 400,000 members and supporters. Our areas of organizational focus include, among others, pharmaceutical safety and efficacy as well as access to medicines.

* “NABP is currently evaluating a validation process whereby only online pharmacies and related entities that meet all regulatory standards in the jurisdictions in which they are based AND IN WHICH THEY DO BUSINESS, INCLUDING PHARMACY LICENSURE, drug authenticity, and valid prescription requirements, as applicable, would be permitted to register in .PHARMACY.” [Emphasis added.] Virtually no US states license non-US pharmacies.

Like the respected consumer advocacy group, Public Citizen, we filed a public comment with ICANN, the nonprofit that oversees global domain names and ensures the stability of the World Wide Web, opposing the National Association of Boards of Pharmacy (NABP) application for the generic top level domain “.pharmacy.” Lee Graczyk, our lead organizer, also delivered 24,349 petition signatures opposing NABP’s bid to control the .pharmacy domain to an ICANN Public Forum in Los Angeles.

When this article came out, we felt the need to reiterate our concerns. Despite good intentions of protecting consumer safety, we believe the domain will ultimately be anticompetitive and detrimental to consumers seeking affordable medicine online.

The NABP has an institutional history demonstrating its objective to prevent drug importation. The NABP’s Internet Drug Identification Outlet Program, launched in 2008 with the help of a Pfizer grant, publishes a “not recommended” list of “rogue” online pharmacies that unfairly groups legitimate international online pharmacies with criminal enterprises that sell fake medicine or real medicine without a prescription.

With this list, the NABP created a false dichotomy when it comes to prescription drug safety. The organization would have us believe that all U.S. prescription drugs are safe while all foreign drugs are not. The .pharmacy program headed by NABP appears to be subject to the same biases.

Certainly there are unscrupulous rogue sites that use deceptive and underhanded tactics to get American consumers to buy fake or adulterated medication. But there are also safe and legitimate Canadian and other international pharmacy sites, which require a doctor’s prescription and allow consumers to access needed medications at much lower prices. Due diligence is critical when choosing an online pharmacy to ensure safety. RxRights will support any NABP efforts to warn and educate consumers about actual rogue sites, those known to sell falsified and substandard medication or real medication without a prescription. But their intentional grouping of dangerous sites with safe online pharmacies is unreasonable. Misinformation of this nature threatens public health and limits American access to affordable medicine.

In addition, the .pharmacy initiative is funded by five big pharmaceutical firms: Eli Lilly, Gilead Sciences, Janssen Therapeutics, Merck and Pfizer. These multinational pharmaceutical companies are clearly vying for control of the Internet so it can be used for a commercial advantage.

Americans—and the global community for that matter—deserve Internet governance that maximizes information and protects the consumer’s right to safely access affordable medicine. Four million Americans import their needed medications from Canada and other countries each year (despite the fact that it’s not technically legal). Many have come to depend on this cheaper alternative—often saving 50 percent or more on U.S. prices.

As we know from the many testimonials we’ve received from Americans across the country, importing safe and affordable prescription drugs is not only possible, it’s vital. As Stephen Schondelmeyer, Ph.D., drug pricing expert and head of the University of Minnesota Department of Pharmaceutical Care and Health Systems says, “A drug that’s not affordable is neither safe nor effective.”

Lee Graczyk
Lead Organizer
RxRights.org
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RxRights is an American-based consumer advocacy group that’s dedicated to ensuring access to safe, affordable prescription drugs and is 80,000 members strong. We feature tips on our website for finding a safe international online pharmacy.

Mr. Catizone’s hope for .pharmacy is admirable.  Indeed, we concur that there is a huge need for measures that differentiate the good actors from the bad in the online pharmacy world.  We acknowledge his comment, “We recognized .pharmacy as a way to turn the tide against sophisticated criminals who build authentic looking sites and can easily duplicate verification logos to trick unsuspecting consumers into thinking they are visiting a legitimate online pharmacy.” However, a new top level domain operator that focuses on self-serving registration policies stands far from achieving that goal.

Proponents of .pharmacy would like everyone to believe that their model is the only way to keep patients safe, yet experience shows it could have quite the opposite result under the current .pharmacy registrant policies.  As an example, in the United States, patients who need medication and order them from a U.S.-based online pharmacy are likely to pay approximately the same price as they would pay at their neighborhood pharmacy.  The main reason people turn to the internet for their medications is because they can’t afford the high cost of meds in their home country so they look to safe, licensed pharmacies in other countries to meet their medical needs.  I particularly know this because almost every person who calls my office, as General Manager of the Canadian International Pharmacy Association (CIPA), starts by telling me a story about how much their local pharmacist just told them their medicine would cost. 

Apart from the NABP’s stated efforts to weed out bad actors that abuse consumers, it is equally important to acknowledge that there are many legitimate licensed online pharmacy websites, selling authentic medications according to doctors’ prescriptions, and under government regulatory oversight where they are located. However, under NABP’s current registrant policy requirements these licensed operators do not qualify for .pharmacy.  CIPA members have operated with .com websites for the past 15 years and have served millions of people who cannot afford their medications in the countries they live.  Unfortunately for those patients, if .pharmacy with its current eligibility criteria were to become successful in the way Mr. Catizone imagines, hundreds of thousands of patients will be faced with not filling prescriptions, cutting pills or skipping doses of medications; as reported by Kaiser Family Foundation.
 
Rather than trying to put the genie back in the bottle and relying on dated protocols, what is needed is a constructive approach to online pharmacy safety that recognizes how people need and use the internet, embracing practices that became global almost two decades ago.  People all around the world are purchasing products and services over the internet from wherever they can find a price they are prepared to pay for a legitimate product.  Pharmacy is no different.  In the internet age of the 21st century, what is required are ‘digital’ solutions that supersede ‘analog’ approaches of the last century.

What Mr. Catizone and NABP really need to do is speak with – and listen to – the millions of Americans who cannot afford expensive medications to understand that a broader model, which recognizes and reflects what consumers are doing is what is required. Registrant policies that welcome safe online pharmacies such as CIPA is what is needed to achieve Mr. Catizone’s safe pharmacy vision.  Excluding those of us who are legitimate, ready, willing and able to register .pharmacy domains does not serve internet consumers, while allowing the rogue pharmacies to continue to wreak havoc on people’s lives. 

Innovation and consumer choice are at the heart of the internet, and applying a broader approach to .pharmacy would lead to a safer model that takes us all into a safer future.

Tim Smith
General Manager
Canadian International Pharmacy Association