The Department of Commerce's Internet Policy Task Force is conducting a comprehensive review of the nexus between privacy policy and innovation in the Internet economy. On April 23, 2010, the Department published a Notice of Inquiry seeking comment from all Internet stakeholders on the impact of current privacy laws in the United States and around the world on the pace of innovation in the information economy. The Department now seeks further comment on its report entitled, "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework," available
at http://www.ntia.doc.gov/internetpolicytaskforce/. Through this
Notice requesting comments on the report, the Department hopes to spur further discussion with Internet stakeholders that will lead to the
development of a series of Administration positions that will help develop an action plan in this important area.
4As, AAF, ANA, DMA, & IAB
Michael A. Signorelli, Esq. | Venable LLP
Catalog Choice | Chuck Teller, Executive Director
Thank you for accepting comment upon "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.†Attached, please find the comments of Catalog Choice, the nation's largest independent privacy portal.
Best,
Chuck
Executive Director
Catalog Choice
SIFMA -- Securities Industry and Financial Markets Association | Melissa MacGregor
Please see the attached comment letter re: Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.
We apologize for the brief delay.
Thank you.
Melissa MacGregor
Managing Director and Associate General Counsel
SIFMA
1101 New York Avenue, 8th Floor, NW, Washington, DC 20005
Office: 202-962-7385
Fax: 202-962-7305
Synaptic Laboratories Limited | Benjamin Gittins, Chief Technology Officer
U.S. Department of Commerce, 1401
Constitution Avenue, NW., Room 4725,
Washington, DC 20230.
privacynoi2010@ntia.doc.gov
Re: Cybersecurity, Innovation and the Internet Economy
Notice of Inquiry
This letter is written in response to the notice for inquiry made in the [Federal Register: Dec 21, 2010 (Volume 75, Number 244)], [Page 80042], [Docket No. 101214614-0614-01].
Thank you for making this important call for public comment.
There are seven sections in our reply. We begin with praise for the DoC IPTF and the IPTF Privacy Green Paper, which we consider to be a very valuable contribution and effort. Second, we point to specific sections of that text that we think are highly desirable. Third, we provide some constructive feedback on statements found in the body of the green paper. Four, we make some observations on the DHS fair information practice principles (FIPP). Five, we provide answers to selected questions out of your notice of inquiry. Six, we make a few very minor observations on a few sentences in the text. Seven, we finish with some suggestions regarding a) unique requirements to support small business needs and b) a proposition to survey the community to establish a baseline expectation for data privacy.
We appreciate this opportunity to provide feed back on the UPTF Privacy Green Paper. Should it be helpful, we are at your disposal to provide further clarification on any point we have raised.
Please find our full letter attached to this email, and also a redundant copy at the following URL:
http://media.synaptic-labs.com/downloads/pub/publications/NTIA/20110127-Synaptic-NTIA-Feedback-Released.pdf
Thank you and best regards,
Benjamin GITTINS, on behalf of the Synaptic Laboratories Team.
Chief Technology Officer
Synaptic Laboratories Limited
Intuit | Amanda Pedigo, Federal Technology Policy
We are happy to submit these comments. Please feel free to contact me if you have any questions.
Amanda Pedigo
Federal Technology Policy
Intuit
US Chamber of Commerce | Jason Goldman
Thanks,
Jason Goldman
===
Jason D. Goldman
Counsel, Telecommunications & E-Commerce
Environment, Technology & Regulatory Affairs Division
U.S. Chamber of Commerce
1615 H Street, NW
Washington, DC 20062
MAPPS | John Palatiello, Executive Director
John M. Palatiello, Executive Director
MAPPS
1856 Old Reston Avenue
Suite 205
Reston, VA 20190
IAB
Regards,
Michael Signorelli
Michael A. Signorelli, Esq. | Venable LLP
Comradity | Katherine Warman Kern
The Honorable Gary Locke
Secretary of Commerce
and The staff and members of the Internet Privacy Task Force,
I apologize for the delay in responding to the Internet Privacy Task Force, but I believe these decisions could add rather than remove hurdles to innovators seeking to IMPROVE consumer trust.
Please see our review of the greenpaper and response published here on our website: http://www.comradity.com/comradity/2011/02/review-and-response-commerce-iptf-green-paper.html
Do not hesitate to call me with any questions.
Best regards,
Katherine Warman Kern
TRUSTe | Elizabeth Frazee
Friday, January 28, 2011 - TRUSTe
To Whom It May Concern:
Please find attached the comments of TRUSTe regarding the Department of Commerce’s paper “Commercial Data Privacy and Innovation in the Internet Economy†(Docket # 101214614-0614-01). Please do not hesitate to contact me or TRUSTe's President, Fran Maier, if you have any further questions.
Sincerely,
Elizabeth Frazee
TRUSTe Consultant
Attachment
TWINLOGIC Strategies LLP
400 North Capitol Street Suite 585
Washington, DC 20001
Online Publishers Association | Patrick Byrnett
Attached, please find the comments of the Online Publishers Association (OPA) in response to the Commerce Department's notice regarding its report, "Commercial Data Privacy and Innovation in the Internet Economy." OPA appreciates the opportunity to comment on the report, and looks forward to participating in the Department's considerations on these issues going forward.
If you have any questions or concerns regarding the comments, please let me know. I would also appreciate an acknowledgement of receipt (if one is not automatically generated).
Many thanks,
Patrick J. Byrnett
Counsel to Online Publishers Association
Patrick J. Byrnett | Dow Lohnes PLLC | Dow Lohnes Government Strategies LLC
Attorney at Law | Director of Government Affairs
Net Choice | Steve DelBianco
--
Steve DelBianco
Executive Director
NetChoice
Semcasting, Inc. | Ray Kingman, CEO
I request that you replace the HTML doc with the attached PDF format.
Thank you for your assistance.
Ray Kingman
CEO
Semcasting, Inc.
University of Wyoming College of Business | Robert Sprague - academic
Thank you.
ROBERT SPRAGUE
Associate Professor
University of Wyoming College of Business
Department of Management & Marketing
1000 E. University Avenue, Dept. 3275 • Laramie, Wyoming 82071
International Pharmaceutical Privacy Consortium
On behalf of the International Pharmaceutical Privacy Consortium (IPPC), I am pleased to submit these comments on the Proposed Policy Framework for Commercial Data Privacy and Innovation.
Thank you for your consideration.
Sincerely,
Peter Blenkinsop
Peter Blenkinsop
International Pharmaceutical Privacy Consortium (IPPC)
USCIB | Jessica Berti
Should you have any questions, please don’t hesitate to contact Heather Shaw (hshaw@uscib.org) or me directly.
Best,
Jessica
Jessica Berti
Executive Assistant, Office of the President
United States Council for International Business (USCIB)
Consumer Data Industry Association | Eric Ellman
...........
Eric J. Ellman
Vice President, Public Policy and Legal Affairs
Consumer Data Industry Association
Self | Martin Nemzow
Facebook
Attached please find Facebook's comments in response to the Department of Commerce's proposed privacy framework set forth in its report, " Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework," Docket No. 101214614–0614–01.
Facebook appreciates the opportunity to comment on the Task Force's report and looks forward to working with you and other stakeholders to continue the vital discussion initiated by this report regarding an updated and dynamic approach to privacy.
Respectfully submitted,
Erin M. Egan
Covington & Burling LLP
on behalf of Facebook
Quicken Loans | Matt Emery
Please find attached Quicken Loans’s comment letter regarding the Department of Commerce’s Internet Policy Taskforce’s “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework†report.
Thank you,
Matt Emery
Government Affairs Associate
Quicken Loans
Online Trust Alliance | Craig Spiezle, Executive Director
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue NW.
Room 4725
Washington, D.C. 20230
RE: Commercial Data Privacy & Innovation in the Internet Economy: A Dynamic Policy Framework
Docket No. 101214614–0614–01
The Online Trust Alliance (OTA) hereby submits its comments to the Department of Commerce request for comments on Docket No. 101214614–0614–01.
Craig
Craig D. Spiezle
Executive Director
Online Trust Alliance
Intel Corporation
Brian Huseman
Intel Corporation
Self | Dr. John Nugent
Privacy Rights Clearinghouse | Beth Givens
Respectfully,
Beth Givens, Director
Privacy Rights Clearinghouse
3100 5th Ave., Suite B
San Diego, CA 92103
Experian
Regards,
Tara Sugiyama Potashnik, Esq. | Venable LLP
AT&T, Inc.
On behalf of AT&T Inc., we are pleased to submit the attached comments.
Please contact us if you have any questions, or need any further information.
Thank you for considering the views expressed in AT&T’s comments.
Sincerely,
Alan Charles Raul
SIDLEY AUSTIN LLP
Counsel for AT&T Inc.
Alan Charles Raul
SIDLEY AUSTIN LLP
Attachments
UC Berkeley, School of Information | Nick Doty, Lecturer / Researcher
Nick Doty
Lecturer / Researcher
UC Berkeley, School of Information
Consumer Federation of America | Susan Grant
Susan Grant
Director of Consumer Protection
Consumer Federation of America
Global Privacy Alliance
<
Sincerely,
Cynthia J. Rich
Morrison & Foerster, LLP.
2000 Pennsylvania Avenue, N.W.
Suite 6000
Washington, D.C. 20006
Consumer Watchdog
Attached as a PDF file please find Consumer Watchdog's comments on The Commerce Department¹s report ³Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.²
Thank you.
Sincerely,
John M. Simpson
Consumer advocate
Consumer Watchdog
Formerly The Foundation for Taxpayer and Consumer Rights 1750 Ocean Park Blvd., #200 Santa Monica, CA 90405-4920
Attachments
Kindsight
Attached please find a copy of Kindsight’s response to Information Privacy and Innovation in the Internet Economy (Docket No. 101214614-0614-01, RIN 0660-XA22) request for comments. Please let me know if you have any questions or problems opening the attachment.
Sincerely,
Bridget E. Anderson
Legal Secretary
Wilkinson Barker Knauer, LLP
Telcordia Technologies, Inc. | Stan Moyer, Executive Director, Strategic Research Program
Please find our comments in the attached file.
Sincerely,
___________________________________
Stan Moyer
Executive Director, Strategic Research Program
Telcordia Technologies, Inc.
1 Telcordia Drive/RRC 1A361
Piscataway, NJ 08854
Center for American Progress | Peter Swire
Attached please find the comments of Peter Swire on the privacy Green Paper.
Thank you,
Peter Swire
Google | Will DeVries, Policy Counsel
--
Will DeVries | Policy Counsel | Google Inc. |
Electronic Privacy Information Center (EPIC)
Thanks,
Sharon Goott Nissim
Consumer Protection Fellow
Electronic Privacy Information Center
202-483-1140 Ext. 107
UCLA School of Law | Jerry Kang - academic
Best,
Jerry Kang
______________________________________________
Jerry Kang, Professor of Law
Professor of Asian American Studies (by courtesy)
Korea Times--Hankook Ilbo Chair in Korean American Studies
eBay, Inc. | Lauren Sholley, Manager
Lauren Sholley
Manager of Federal Government Relations
eBay Inc.
Venable Law Firm | Stuart Ingis
Retail Industry Leaders Association (RILA) | Doug Thompson, Vice President
Doug Thompson
Vice President, Government Affairs
Retail Industry Leaders Association (RILA)
1700 North Moore Street
Suite 2250
Arlington, VA 22209
Business Software Alliance | Franck Journoud
Please find attached the submission of the Business Software Alliance re: Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework, RIN 0660-XA22.
Best regards,
Franck Journoud | Director, Cybersecurity Policy | Business Software Alliance
USACM | US Public Policy Council of the Association for Computing Machinery (USACM)
Attached please find the comments of the U.S. Public Policy Council of the Association for Computing Machinery in response to the Internet Policy Task Force report on commercial data privacy. We appreciate the opportunity to comment on an important report that should push forward the national discussion over online privacy.
Regards,
David Bruggeman
Public Policy Analyst
Association for Computing Machinery
1828 L Street, Suite 800
Washington, D.C. 20036
ePrio Inc. | Phillippe Coueignoux, Phd, President
please find here attached in pdf format
my feedback to your consultation on privacy
Respectfully yours
Philippe Coueignoux PhD
President ePrio Inc.
National Consumers League
On behalf of the National Consumers League ("NCL"), we submit the attached comment regarding the Department of Commerce's Internet Policy Task Force report, "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework." Please reply to confirm receipt. Thank you.
Mark Punzalan
Finkelstein Thompson LLP
100 Bush St., Suite 1450
San Francisco, CA 94104
Marketing Research Association | Howard Feinberg
Sincerely,
Howard Fienberg, PLC
Director of Government Affairs
Marketing Research Association (MRA)
Personal Data Ecosystem Collaborative Consortium | Kaliya Hamlin and Mary Hodder
Attached please find our letter and Q&A response to the Green Paper.
We are aware that it's late, but had consulted last week with Mr. Gallagher who told us you would accept it through today.
We hope to it isn't to late for you to consider our unique position coming form Silicon Valley innovators and technologists.
Thank you,
Mary Hodder
cc: Kaliya Hamlin
Attachments
CDD and US PIRG | Gary O. Larson
Walmart Stores Inc.
Please find attached the comments of Walmart Stores Inc. regarding the Department of Commerce’s paper “Commercial Data Privacy and Innovation in the Internet Economy†(Docket # 101214614-0614-01). Please do not hesitate to contact me if you have any further questions.
Sincerely,
Kirk Koehler Senior Manager Privacy Office
kirk.koehler@wal-mart.com
Coalition of Child, Health and Consumer Advocates | Guilherme Roschke, Staff Attorney, Georgetown University Law Center
Center for Digital Democracy, American Academy of Child and Adolescent Psychiatry, American Academy of Pediatrics, Children Now, Consumer Action, Consumer Federation of America, Consumer Watchdog, National Consumers League, Privacy Rights Clearinghouse, World Privacy Forum
Sincerely,
Guilherme Roschke
Guilherme Roschke
Staff Attorney / Fellow
Institute for Public Representation
First Amendment and Media Center
Georgetown University Law Center
Center for Democracy and Technology | Erica Newland, Policy Analyst
Erica Newland
Policy Analyst
Center for Democracy & Technology
1634 Eye Street NW, Suite 1100
Joel Ruiz
On behalf of commentator Joel Ruiz, we submit the attached comment regarding the Department of Commerce's Internet Policy Task Force's report, “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.†Mr. Ruiz is also copied on this email. Thank you.
Sincerely,
Mark Punzalan
Finkelstein Thompson LLP