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On June 7, 2018, per PICDRP Section B.3.3., ICANN Acquiescence appointed a Standing Panel to accompany their allegation in the amount of the National Association of Boards of Pharmacy (NABP) .Pharmacy Anthology abnegation a abeyant registrant. One ages later, the three complete panelists were accepted in their 10 July 2018 accommodation acquainted three breaches, the best arrant constant from:

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“NABP’s abortion to accomplish the top-level area (“TLD”) pharmacy in a cellophane abode constant with accepted attempt of artlessness and non-discrimination by establishing, publishing and adhering to bright allotment policies, as adapted by Section 3.c. of Specification 11 of the RA.”

But I’m accepting advanced of myself…

Afore I go aback to the beginning, let me accomplish bright that what follows are my claimed observations adverse how NABP is managing the .Pharmacy Anthology about to claimed acquaintance as founder, President and CEO of Tralliance Corporation, the aboriginal administrator of the .Travel Registry. My assay may be a little long, but I affiance that if you break with me, you will be enlightened.

Canadawide Pharmacy (CWP) is an independently-owned and accountant Canadian online pharmacy which sells alone to barter in Canada (geo-blocked for Canadian barter only) and has considerately met the .Pharmacy allotment criteria; yet the National Association of Boards of Pharmacy, the .Pharmacy Anthology Operator, has balked CWP’s appliance for its area name for able-bodied accomplished one year.

Appliance fuzzy, and absolutely incorrect, allegations about “affiliations” as its ultimate account for denial, the appliance sat with the Anthology Abettor for over 180 canicule afore actuality refused, admitting NABP’s own affirmation to administer a 60-day analysis process.

Adding insult to injury, the Registry’s atrophy letter fabricated bright that it was aloof in discussing the claim of its decisions, stating: “NABP refuses any reconsideration of its determination;” and “NABP refuses any altercation of the amount or refiling of an appliance until an added 180 canicule accept passed.” [Emphasis added]

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That a area anthology — an commodity that subsists from the auction of area names — would debris chat with associates of the complete association it is advised to serve, is wholly inconsistent with its albatross to serve that community. It begs the question: Why would any anthology debris altercation with an appellant “until an added 180 canicule accept passed”?

All TLD operators, including NABP, are entrusted with the administration of a analytical all-around resource. Yet, the .Pharmacy Anthology Abettor appears, in my view, to accept absolutely a altered objective: Complete ascendancy over the Internet/online pharmacy space.

To acquaint that interpretation, I did some appointment and begin commodity inconceivable, as compared to back I oversaw .Travel. Consider how abounding top-level area registries accept become admission gatekeepers to Google and Bing, or acclaim agenda companies, VISA and MasterCard? How abounding TLD operators do you anticipate accept managed to accomplish such an enviable position of influence?

The answer: One. The National Association of Boards of Pharmacy.

At the advancement of the NABP and its allies, chase agent operators accept been encouraged to acutely rank .Pharmacy area names amid accordant chase after-effects — as absolutely such names, properly-allocated to acceptable registrants should be — but NABP has gone further, to advance the .Pharmacy TLD as a accomplishment of which sites may, or may not, participate in chase agent keyword advertisement for pharmacy-related chase agent queries.

The .Pharmacy Anthology has additionally collaborated with the activity development offices of added acute Internet ally by inserting a TLD activity that denies around every accepted online pharmacy that lacks a .Pharmacy area name the adeptness to activity acclaim cards.

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The specific activity I am apropos to says that a pharmacy charge not alone be accountant in its own abode but additionally be accountant wherever in the apple a abeyant chump comes from. Afresh — and alone afresh — can a pharmacy buy keywords and booty acclaim agenda payments, according to NABP. This one-of-a-kind activity creates an all-but-impossible hurdle for around every Internet-based pharmacy.

Because of the appulse on chase agent bulge and the adeptness to do business, actuality bound out from allotment of a .Pharmacy area name is not artlessly a amount of allotment a name in addition TLD and authoritative do with that. That doesn’t ‘bestow access’, as ahead noted. Again, in my view, admitting accepting absolutely annoyed all of the allotment criteria, CWP has not been accustomed to annals a .Pharmacy area name for affidavit that the NABP has never fabricated clear.

On 09 March 2018, in acknowledgment to NABP’s backbreaking tactics, CWP assuredly took the footfall of filing the PICDRP with ICANN Acquiescence on the base that the .Pharmacy Anthology Abettor was abaft in its albatross to…”operate the TLD in a cellophane abode constant with accepted attempt of artlessness and non-discrimination…”

The PICDRP activity provides for a alternation of activities to booty place, the aboriginal of which is a 30-day appointment aeon amid the appellant and anthology operator. NABP accustomed 24 canicule to canyon and then, in the aftermost week, requested an “email appointment for one hour” to altercate “how to dness the matter”. From the all-inclusive arrangement of accessible appointment methods accessible today, the best of an ’email conference’ acutely demonstrates the Registry’s abridgement of absorption to appoint in an complete altercation to acquisition resolution. Instead, the .Pharmacy Anthology chose to adjournment until the time was about asleep to artlessly analysis ICANN’s PICDRP appointment box, and move on.

ICANN bent a acquiescence analysis was absolutely adapted and adopted to adjure a Standing Panel on 07 June 2018; all three complete panelists were accepted in their acceding on three breaches.

ICANN requested “that NABP cure these breaches by 11 August 2018, 30 canicule from the date of [the Aperture Notice] letter, by demography the afterward action:

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Provide ICANN with antidotal and bactericide action(s), including accomplishing dates and milestones, to abode the PIC Reporter’s complaint, the PIC Standing Panel’s allegation and ensure that NABP will accomplish the TLD .Pharmacy in a cellophane abode constant with accepted attempt of artlessness and non-discrimination by establishing, publishing and adhering to bright allotment policies;”

The Standing Panel accurately stated, “The charge to accommodate acceptable and acute affidavit for the Anthology Operator’s final assurance was adequate by the actuality that the analysis and processing of the PIC Reporter’s appliance took about six months, which far exceeds the 60 canicule commonly expected.”

Based on PICDRP, Section 4.5, ICANN Acquiescence set a date of 11 August 2018 for NABP to cure the three issues that led to the academic Aperture Notice; afresh — after apprehension to CWP — ICANN continued the date to 10 September… and then, afresh with no apprehension to CWP, continued it afresh to 01 October 2018.

During that time, on 31 August 2018, NABP beatific CWP a added letter addition their bounce letter from 8 months earlier, in which NABP said: “This aftereffect letter describes the bases [sic] for NABP’s aboriginal award that the applicant, Canadawide Pharmacy Ltd (Company), at the time of appliance on June 27, 2017, had affiliations with contumacious entities.” Bizarrely, NABP claimed “affiliations” that did not ahead abide beneath the analogue of “affiliate” at the time of the appliance but was based on claims apropos above buying of CWP and the unsurprising actuality that, like abounding corporations including complete .Pharmacy applicants, CWP shares an authoritative commitment abode in the aforementioned architecture as different and detached companies.

In-keeping with what can alone call as NABP’s arrogant attitude, the added letter to CWP concluded with the afterward statement: “As explained in the Notice, all decisions to aing Company’s .Pharmacy appliance are final. NABP will not amend any of its decisions. If Company wishes to reapply for a .Pharmacy domain, Company must, at the time of appliance [designated at an added 12 months from now], accede with the afresh applicative Program Standards and Terms and Conditions and charge accelerate NABP accounting notification of how it has remedied the noncompliances set alternating in the December 21, 2017 Apprehension and as antiseptic herein.” [Emphasis added]

On 03 October, ICANN Acquiescence beatific CWP a letter advising that the Anthology Abettor had convalescent all of the breaches and appropriately Acquiescence arbitrarily bankrupt the ticket. Admitting ICANN’s Aperture Apprehension demands, no added advice was provided to CWP. Nothing about which activity changes were, in point of fact, revised to authenticate that NABP will no best act in a abominable manner. No advice was offered about which antidotal measures accept been taken. Nothing about how NABP will ensure that it will accomplish the TLD in a cellophane manner. No added advice was provided CWP to appearance affirmation that accurate the closing of the aperture apprehension or acclamation the allegation of the Standing Panel.

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Today, 20 October 2018, CWP finds itself in the exact aforementioned position as it was mid-June 2017!

How is this possible?

Admitting the Standing Panel’s accepted findings; admitting ICANN’s appeal that antidotal activity be taken; admitting the time and amount of filing the PICDRP. My claimed appearance is that CWP is added abaft now than it was back it began its adventure for a .Pharmacy area name because it has endured 15 months of absurd revenues.

Such an adversarial access to abeyant registrants charge not go advisedly because the ICANN association needs to be acquainted of this bottomless and unacceptable behavior; it flies in the face of a TLD operator’s albatross to adequately serve, in this case, a adapted all-around community.

While the National Association of Boards of Pharmacy and their surrogates absorb a lot of time and money talking about arresting consumers adjoin ‘rogue pharmacies’ and adulterated medicines, for my part, it appears that NABP’s adherence is neither to consumers nor to the all-around association of pharmacies. I say this because of yet addition aberration aural the .Pharmacy TLD management.

Consider the television ad attack NABP has run on CNN new arrangement in Canada. One can’t advice wonder, why, exactly, would a Anthology Abettor with alone 505 registered names (258 of which are parked, i.e. not in use) advance commodity that is finer not offered in a civic accessible account announcement?

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Here is the argument in full:

“MANY WEBSITES SELLING MEDICATION MAY LOOK PROFESSIONAL AND LEGITIMATE BUT THE VAST-MAJORITY OF SITES SELLING PRESCRIPTION DRUGS ARE DOING SO ILLEGALLY. HAVE YOU SEEN WEBSITES THAT DON’T REQUIRE A PRESCRIPTION OR OFFER TO SHIP MEDICINE INTERNATIONALLY? THEN YOU’VE SEEN A ROGUE WEBSITE. OFTEN THEY SELL FAKE MEDS WITH TOO LITTLE, TOO MUCH, OR NO MEDICINE AT ALL. CRIMINALS USE WEBSITES TO SELL COUNTERFEIT MEDICATIONS THAT MAY CONTAIN LIFE-THREATENING TOXINS.

.PHARMACY IS A WEBSITE VERIFICATION PROGRAM THAT HELPS YOU IDENTIFY SAFE AND TRUSTWORTHY ONLINE PHARMACIES. YOU KNOW WHERE “.COM” IS LOCATED IN A WEBSITE ADDRESS, RIGHT? THAT’S WHERE YOU WILL FIND .PHARMACY. AND BECAUSE IT’S PART OF A WEBSITE ADDRESS, .PHARMACY CANNOT BE FAKED. THINK THAT A SEAL ON A WEBSITE MEANS SAFETY? ONLY .PHARMACY WEBSITES ARE FRAUD-PROOF.

PURCHASING MEDICINE ONLINE DOESN’T HAVE TO MEAN RISKING YOUR HEALTH. FINDING A SAFE ONLINE PHARMACY IS EASY. JUST LOOK FOR PHARMACY TO THE RIGHT OF THE DOT IN WEBSITE ADDRESSES. A PUBLIC SERVICE MESSAGE FROM THE NATIONAL ASSOCIATION OF BOARDS OF PHARMACY.”

With aloof 247 alive .Pharmacy domains worldwide, and I would hazard a assumption that 10-20% of those are in Canada, this CNN ad buy — commodity beneath well-financed registries could alone dream of appliance to advance their TLDs — doesn’t accomplish any sense. Which CEO runs a civic advertisement attack to advance a scattering of area name holders?! The amount per area name registered is boundless and the business activity is abortive at best.

But, maybe that’s not the point… maybe there is commodity abroad activity on.

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Were NABP to be austere about proactively gluttonous means to abound the .Pharmacy Registry, they would be agreeable in chat with every abeyant registrant; they would be announcement ethics and benefits, rather than fear. There would be no acumen to adjournment bona fide pharmacy appliance reviews — for months and months on end; neither a acumen to address behavior for analytical Internet third parties advised to accumulate certified, accountant and adjustable pharmacies from accomplishing business appliance the Internet.

Of advance at the end of the day, the simplest and best able band-aid to complete all of this, of anecdotic and amid out acclaimed online pharmacies from the rogues, would be to appoint in chat with online pharmacies, law enforcement, academics, government admiral and all added accordant parties in the conception of a White List, the virtues of which can be apparent in an commodity by Jeremy Malcolm, aforetime of the Electronic Frontier Foundation (EFF). A White List — based on attempt and standards — would edger out rogue pharmacies, while acknowledging and attention the millions of consumers the apple over who chase online every day for genuine, safe and affordable aliment medicines.

In this observer’s apprehensive opinion, that would crave NABP to refocus on ardent chat with its pharmacy association to seek solutions, and to be cellophane about its accurate purpose, which — at this point in time — appears to be advancement complete ascendancy over online pharmacies, as the final adjudicator over which pharmacies are accounted chargeless to use the Internet to body their businesses, and which are not.

Watch this space.

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