“Since 1898, the AHA has worked to advance the health of individuals and communities, and to lead, represent and serve hospitals, health systems and other related organizations that are accountable to the public and committed to the improvement of our health care system. ”

“The AHA is an established and respected leader of the health care community, and the AHA’s members are clearly intended to be the users of the applied-for .health gTLD.”

“For the reasons below, the AHA believes that the delegation of the .health gTLD will be detrimental to public health and safety, and the general goals and interests of the health care community targeted by this gTLD.”

“First, the AHA believes that a private, for-profit commercial enterprise that is not affiliated with, endorsed by, or otherwise connected to the health care community should not be entrusted with the responsibility of operating the .health gTLD. It is imperative that the public view this gTLD, and the websites and email addresses hosted by domains in this gTLD, as trustworthy and legitimate sources of health related information, products and services. The AHA and its members are concerned that the applicant will operate the .health gTLD pursuant to private commercial interests, and not in the interests of public health and safety. The applicant’s management of the .health gTLD without the participation of the targeted health care community will erode the public’s confidence in the health care system.”

“Further, both the health care community and the public it serves need to be protected from a variety of fraudulent activities. The application for .health does not provide for adequate protections. Unlike the applications for other gTLDs that will serve highly sensitive industries (e.g., .bank), the application for .health does not include registrant eligibility requirements or validation procedures designed to ensure that .health domains are not secured by bad actors. In the absence of such protections, the AHA and its members are concerned that the applicant’s procedures will both encourage and allow third parties to secure and use .health domain names in the perpetration of fraudulent or other illegal activities (e.g., fake health provider websites, illicit online pharmacies, spamming, phishing attacks, identity theft, etc.), and will invite cybersquatting and other acts of trademark infringement that will cause consumer confusion, damage the AHA and its members’ reputations, and otherwise cause material economic harm to the AHA’s constituency.”

“In addition, the health care community is not in a position to accept the financial burden of purchasing and managing domains in the new .health gTLD, or the costs associated with enforcing its rights and protecting consumers from infringing and otherwise fraudulent activities in this gTLD. The majority of the AHA’s members are not-for-profit organizations, and many are already under tremendous fiscal pressure. Accordingly, the creation of the .health gTLD will further tax the resources of the AHA’s members, interfering with their efforts to help the sick and infirm, and to educate the public regarding health and wellness issues.”