BEFORE THE Online Profiling Project PROMOTION MARKETING ASSOCIATION, INC. REQUEST TO PARTICIPATE
October 18, 1999 I. Introduction The Promotion Marketing Association, Inc. ("PMA"), through its attorneys, hereby submits this request to participate in the Public Workshop to be held by the Commission and the Department of Commerce on the topic of online profiling. See 64 Fed. Reg. 50813 (September 20, 1999). II. The PMA The PMA has been the leading non-profit association representing the promotion marketing industry since 1911. The PMA is an international trade association serving major companies who use promotions as a marketing technique as well as suppliers who implement those promotions around the world. The PMA's membership consists of major Fortune 500 companies offering consumer goods and services, such as package goods companies; entertainment companies; TV networks; fast food companies; financial services companies; retailing companies; over the counter pharmaceuticals companies; health and beauty aids companies; household products companies; food and beverage companies; Internet companies; computer hardware and software companies, and many others. PMA membership also includes various agencies and other suppliers providing vital services such as printing, production, fulfilment, and promotion administration to marketers engaged in the conduct of promotions. The PMA has been a leader among trade associations in addressing the issues of advertising and selling on the Internet. The PMA has focused upon both the business goal of using the Internet to achieve business success and the legal goal of determining what, if any, level of governmental regulation should be imposed on the Internet. The PMA's mission is to encourage the highest standards of excellence in promotion marketing. The objectives of the PMA are to educate its members on the laws that govern promotions and to act as a resource to state legislatures, state attorneys general, and federal regulatory agencies in drafting appropriate and focused legislation and rules to combat deceptive marketing and promotion practices. III. The Public Workshop The notice announcing the Public Workshop indicates that Session II of the Workshop will focus on the implications of online profiling technology for user privacy, and that Session II of the Workshop will focus on the role of self-regulation. The PMA's members include a cross-section of industries who use common marketing techniques as well as the advertising agencies and other companies who actually execute those techniques. The PMA, therefore, has a unique industry perspective regarding online profiling activities, the costs and/or benefits of various activities to online promotion marketers, and the role of self regulation in the process. The PMA has also participated in past Commission privacy and ecommerce workshops, including the recent Commission children's online privacy workshop. The PMA believes that it will be able to provide the Commission with useful, practical information during Session II and/or Session III of the proposed workshop sessions in this proceeding. IV. CONCLUSION For the foregoing reasons, the PMA respectfully requests that the Commission and the Department of Commerce honor this request to participate in the Public Workshop on the topic of online profiling. Respectfully submitted, PROMOTION MARKETING ASSOCIATION, INC.
October 18 , 1999 |