Home » Publications » Federal Register Notices » 2010

Information Privacy and Innovation in the Internet Economy Notice

Topics: 
Date: 
December 21, 2010
Docket Number: 
101214614-0614-01
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.
application/pdf iconIPTF Information Privacy and Innovation in the Internet Economy Notice

Self - academic | Avi Goldfarb and Catherine Tucker

Submitted on January 24, 2011.
Please find our comments attached.
Best Wishes
Catherine and Avi

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NTIA_comments_2011_01_24.pdf 116.74 KB

Keller and Heckman LLP | Sheila Millar, Partner

Submitted on January 28, 2011.
Attached please find comments in response to the above-referenced request on the Green Paper report on privacy, Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework. Please contact the undersigned if you have questions.

Sheila A. Millar, Partner

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Response to DOC_KH.pdf 132.39 KB

State Privacy & Security Coalition

Submitted on January 28, 2011.
On behalf of the State Privacy & Security Coalition, the attached comments are being submitted in response to the U.S. Department of Commerce Internet Policy Task Force’s “Green Paper” on privacy: “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.”

Thank you,

Callie J. Carr
DLA Piper LLP (US)

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State Coalition Green Paper Comments(01-28-2011)(final).pdf 23.25 KB

Executive Director, GS1 Global Public Policy | Elizabeth Board

Submitted on January 28, 2011.
On behalf of GS1 US and GS1 EPCglobal, please find attached our comments on The Department of Commerce Internet Policy Task Force Report Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework, Docket No. 101214614–0614–01.
.
Thank you,
Elizabeth Board
Executive Director, GS1 Global Public Policy
1101 30th St., NW Suite 500
Washington, DC 20007

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GS1 Comments - DOC Docket No. 101214614-0614-01.pdf 450.09 KB

TechAmerica | Chris Wilson

Submitted on January 28, 2011.
Please find attached TechAmerica’s comments in response to the Department’s Internet Policy Task Force’s privacy “green paper.” Thank you.

Christopher E. Wilson
Director and Counsel, E-Commerce & Telecommunications
TechAmerica

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TechAmericaResponsetoDOCPrivacyGreenPaper.pdf 112.37 KB

Mortgage Bankers Association

Submitted on January 27, 2011.
Please find attached the Mortgage Bankers Association’s comments concerning the Department of Commerce green paper, “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.”

Thank you.

Sandra Troutman
Director of Public Policy
Mortgage Bankers Association

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MBA Privacy Comment Letter.pdf 85.04 KB

New York University | Helen Nissenbaum, Kenneth Farrall and Finn Brunton

Submitted on January 30, 2011.
(Late Submission)
To the Internet Policy Task Force:

I would be obliged if you accepted these (belated) comments on the Data Privacy Green paper, hereby attached in both Word and pdf formats.

Thank you,
Helen Nissenbaum

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NissenbaumIPTFComments.pdf 109.79 KB

CCIA | Ross Schulman

Submitted on January 28, 2011.
Attached please find the comments of the Computer and Communications Industry Association in response to the Information Privacy and Innovation in the Internet Economy notice of inquiry.
Any questions can be directed to me using the below contact information.

Sincerely,
Ross Schulman
Public Policy and Regulatory Counsel
Computer and Communications Industry Association

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CCIA Commerce Comments.pdf 192.88 KB

CMP.LY | Tom Chernaik, CEO

Submitted on January 28, 2011.
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, N.W.
Room 4725
Washington, D.C. 20230

email: privacynoi2010@ntia.doc.gov

CMPLY, Inc. commends the Department of Commerce on the work and thought that has gone into the “green paper” on innovation and privacy and we are honored to be able to comment and offer our perspectives on these important issues in the continuing effort to build a policy structure that protects consumer privacy and stimulates technology innovation.

We look forward to contributing to the dialogue in a meaningful and constructive manner.

Sincerely,

Tom Chernaik
--

Tom Chernaik
CEO

CMP.LY
104 West 29th Street, 11th Floor
New York, NY 10001

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CMPLY NTIA Comment.pdf 352.16 KB

Financial Services Forum | John Dearie, Executive VP

Submitted on January 28, 2011.
Ladies and Gentlemen:
The attached comment letter is submitted by the Financial Services Forum in response to the Department of Commerce Internet Policy Task Force’s report “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework,” issued on December 16, 2010.

The Forum appreciates the opportunity to comment on this important matter. If you have any questions concerning these comments or if we can otherwise be of assistance in connection with this matter, please do not hesitate to contact me.

Best regards,

John R. Dearie
Executive Vice President
The Financial Services Forum

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FinancialServicesForum.pdf 110.99 KB

General Electric

Submitted on January 28, 2011.
Attached please find comments from General Electric on the Department of Commerce report entitled "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework."

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GE comment letter.pdf 60.43 KB

Information and Privacy Commissioner of Ontario (Canada) | Dr. Ann Cavoukian, Information and Privacy Commissioner of Ontario

Submitted on January 27, 2011.
Please see the attached letter and commentary submission on the Department of Commerce Internet Policy Task Force’s green paper Commercial Data Privacy and Innovation in the Internet Economy from Dr. Ann Cavoukian, Information and Privacy Commissioner of Ontario.

Thank you.

Shelly Thrasher
Executive Assistant to
Dr. Ann Cavoukian, Information & Privacy Commissioner of Ontario
2 Bloor Street East
Suite 1400,
Toronto, Ontario, M4W 1A8

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Letter to U.S. Department of Commerce January 27, 2011.pdf 36.24 KB
2011-01-27-dept-of-commerce-submission.pdf 185.64 KB

America’s Health Insurance Plans | Marilyn Zigmund Luke

Submitted on January 28, 2011.
Re: Request for Comments on the Green Paper Addressing Commercial Data Privacy and the Internet.

Please find attached comments from America’s Health Insurance Plans. We appreciate the opportunity to offer comments on the report and the important issues it raised.”

Thanks!


Marilyn Zigmund Luke
Senior Regulatory Counsel
America’s Health Insurance Plans
601 Pennsylvania Ave., NW
South Building, Suite 500
Washington, D.C. 20004

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privacynoi2010 FINAL.pdf 133.42 KB

UnitedHealth Group

Submitted on January 28, 2011.
VIA E-Mail

January 28, 2011

National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Ave., N.W., Room 4725
Washington, D.C. 20230

Dear Internet Policy Task Force:

On behalf of UnitedHealth Group, attached please find our comment letter on the U.S. Department of Commerce’s report entitled “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework” (the “Green Paper”).

Should you have any questions regarding our suggestions, please do not hesitate to contact me.

Thank you,

Ann Tobin

Ann Tobin | Sr. Privacy Counsel
UnitedHealth Group
9900 Bren Road East MN008-T700 | Minnetonka, MN 55343

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UnitedHealth Group Commerce Green Paper Comment Letter 01.28.2011.pdf 67.08 KB

WPF

Submitted on January 28, 2011.
Attached please find the comments of the World Privacy Forum regarding Information Privacy and Innovation in the Internet Economy, RIN 0660-XA22. If there are any difficulties with opening the attached PDF file, please contact Pam Dixon

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WPFComments_Commerce_fs_01282011.pdf 304.36 KB

American Business Media | Mark Sableman

Submitted on January 28, 2011.
Comments of American Business Media.

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ABM comments to 12-2010 Commerce Privacy Report.pdf 463.26 KB

Reputation.com, Inc. | Michael Fertik

Submitted on January 28, 2011.
Please review the attached comments from Reputation.com, Inc. Thank you.

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Comments of Reputation.com Inc to the Department of Commerce-20110128.pdf 195.56 KB

LifeLock | Clarissa Cerda, Senior Vice President, General Counsel and Secretary

Submitted on January 27, 2011.
On behalf of Clarissa Cerda, LifeLock’s Senior Vice President, General Counsel & Secretary the attached comments are being submitted. LifeLock appreciates the opportunity to respond to the U.S. Department of Commerce Internet Policy Task Force’s “Green Paper” on privacy.

Please contact Clarissa at 480-457-5376, if should you have questions.

Thank you,


Donella R. Martin
Executive Legal Assistant to Clarissa Cerda, SVP, General Counsel & Secretary |
LifeLock® - Relentlessly Protecting Your Identity™

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LifeLock Green Paper Comments (01-27-2011)(final) (3).pdf 26.13 KB

The Future of Privacy Forum

Submitted on January 28, 2011.
Please see the attached comments on the Green Paper on behalf of The Future of Privacy Forum.

Regards,

Christopher Zaetta

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DOC029.PDF 3.63 MB

Microsoft | Mike Hintze, Associate General Counsel

Submitted on January 28, 2011.
Please find attached the comments from Microsoft Corporation on the Department of Commerce’s green paper “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.”

Thank you very much for the opportunity to participate in this important dialogue.

Mike Hintze
Associate General Counsel
Legal & Corporate Affairs
Microsoft Corporation
One Microsoft Way
Redmond, WA 98052

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Microsoft Comments on Commerce Privacy Green Paper - final.pdf 616.54 KB

Capital University Law School and New York University School of Law | Professors Dennis Hirsch and Ira Rubinstein

Submitted on January 28, 2011.
Dear Internet Policy Task Force:

Attached, please find comments on Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.

These comments are submitted by Professor Ira Rubinstein of New York University School of Law, and Professor Dennis Hirsch of Capital University Law School.

If possible, please confirm receipt of these comments.

Sincerely,

Dennis Hirsch

Dennis D. Hirsch
Geraldine W. Howell Professor of Law
Capital University Law School

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Rubinstein_Hirsch_Comments_on_Privacy_Green_Paper.pdf 101.17 KB

Coalition of Trade Associations

Submitted on January 28, 2011.
Attached are comments by a coalition of trade associations on the Internet Policy Task Force's Report on Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.


Michael A. Signorelli, Esq. | Venable LLP

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Industry Comment to DoC.pdf 75.64 KB

BlueKai

Submitted on January 28, 2011.
On behalf of BlueKai, we are submitting the attached in response to the Commerce Department's request for comments on the "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework" green paper.
Regards,
Tara Sugiyama Potashnik

Tara Sugiyama Potashnik, Esq. | Venable LLP

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Bluekai.PDF 39.34 KB

Berkeley Center for Law and Technology | Chris Jay Hoofnagle

Submitted on January 28, 2011.
Please see attached Comments of Chris Jay Hoofnagle on Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework, Docket No. 101214614-0614-01, RIN 0660-XA22

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hoofnagle_doc_comments.pdf 1.78 MB

Network Advertising Initiative | Charles Curran, Executive Director

Submitted on January 28, 2011.
Attached please find the Network Advertising Initiative’s response to the request for comments on the Green Paper issued by the Internet Policy Task Force.

Charles D. Curran
Network Advertising Initiative | Executive Director

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NAICommerceGreenPaperComments0128.pdf 334.04 KB

Software & Information Industry Association | David LeDuc, Senior Director Public Policy

Submitted on January 28, 2011.
Thank you for the opportunity to respond to the green paper entitled "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework." On behalf of the Software & Information Industry Association (SIIA), please find the enclosed comments.

David LeDuc
Senior Director, Public Policy
Software & Information Industry Association (SIIA)

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SIIA_DOC-Privacy&Innovation_28Jan2011.pdf 236.66 KB

Internet Commerce Coalition

Submitted on January 28, 2011.
On behalf of the Internet Commerce Coalition, the attached comments are being submitted in response to the U.S. Department of Commerce Internet Policy Task Force’s “Green Paper” on privacy: “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.”

Thank you,

Callie J. Carr
DLA Piper LLP (US)
500 Eighth Street, NW
Washington, DC 20004

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ICC - Green Paper Comments (01-28-2011)(final).pdf 32.22 KB

Consumers Union

Submitted on January 28, 2011.
To Whom It May Concern:

Please find attached Consumers Union’s comments on the Department of Commerce privacy report entitled: “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.” This is the final version of our comments. Please disregard any previous versions of this document you may have received.

Should you have any questions or concerns, please do not hesitate to contact me.

Sincerely,

Ioana Rusu
Consumers Union - Washington Office
Regulatory Counsel
1101 17th Street, NW Suite 500
Washington, DC 20036

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DoC Privacy Report - CU Comments - 1.28.11.pdf 64.93 KB

TruEffect

Submitted on January 28, 2011.
Please accept the attached comments to the Commerce Department paper “Commercial Data Privacy and Innovation in the Internet Economy.”

Thank you,
-S
________________________________________
Scott D. Nelson

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TruEffect - DOC comments 1-28-11 final.pdf 161.91 KB

IBM Corporation | Christina Peters, Senior Counsel, Security and Privacy

Submitted on January 28, 2011.
Dear Madams and Sirs:

Please find attached IBM's comments on the above-referenced matter.

Regards,

Christina Peters
Senior Counsel, Security and Privacy
IBM Corporation

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image2011-01-28-165552.pdf 3.25 MB

W3C

Submitted on January 28, 2011.
Dear Sirs,

please find attached comment from W3C Team to the Report "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework"

Yours sincerely

Rigo Wenning
W3C Privacy Activity Lead

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ResponseW3C.pdf 91.05 KB

Markle Connecting for Health | Rebekah Cohen Rockwood

Submitted on February 18, 2011.
(Late Submission)
Please see the attached letter for collaborative comments in response to the Notice And Request for Public Comments on the Commercial Data Privacy and Innovation in the Internet Economy Green Paper. These comments represent a collective view that was deeply informed by the many and diverse collaborators of Markle Connecting for Health.

Thank You.

Rebekah Cohen Rockwood
Research Associate, Health
Markle Foundation

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20110218-Dept-of-Commerce-Collab-Cmts.pdf 211.44 KB

ITIF | Daniel Castro, Senior Analyst

Submitted on January 28, 2011.
Attached please find comments from the Information Technology and Innovation Foundation (ITIF).



Best regards,

Daniel Castro
Senior Analyst | Information Technology & Innovation Foundation

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2011-Privacy-and-Innovation-Comments-Final.pdf 127.96 KB

DMA

Submitted on January 28, 2011.
On behalf of the Direct Marketing Association, Inc., we provide the attached comments in response to the Commerce Department's request for comments on the "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework" green paper.

Regards,

Kelly A. DeMarchis, Esq. | Venable LLP

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DMA Comments.pdf 84.24 KB

Reed Elsevier Inc

Submitted on January 28, 2011.
On behalf of Reed Elsevier Inc., we provide the attached comments in response to the Commerce Department's request for comments on the "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework" green paper.

Regards,

Kelly A. DeMarchis, Esq. | Venable LLP

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Reed Elsevier Comments to Department of Commerce.pdf 103.71 KB

American Catalog Mailers Association | Hamilton Davison, President and Executive Director

Submitted on January 28, 2011.
Please find attached comments of ACMA on the Commercial Data Privacy and Innovation in the Internet Economy" A Dynamic Policy Framework "green paper."

Thank you.

Sincerely,
Hamilton Davison

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ACMA Comments to DOC Report.pdf 303.74 KB

Yahoo! | Leslie Dunlap and Anne Toth

Submitted on January 28, 2011.
To whom it may concern,

I am submitting Yahoo!’s comments on behalf of Anne Toth, Yahoo! Chief Trust Officer. Thank you.


leslie
dunlap
sr. director, federal government relations

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DOC comments 01282011_yahoo.pdf 184.6 KB

Visa, Inc.

Submitted on January 28, 2011.
Morrison & Foerster LLP is pleased to submit the attached letter on behalf of Visa Inc., in response to the Internet Policy Task Force's request for comments on its green paper entitled, "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework."

Very truly yours,

Julie O'Neill
Morrison & Foerster LLP
Attachments

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Visa.pdf 18.56 KB

EFF | Kevin Bankston

Submitted on January 28, 2011.
Please see the attached comments of the Electronic Frontier Foundation, with one exhibit also attached.

Thank you,
Kevin Bankston
________________________________________
Kevin Bankston, Senior Staff Attorney
Electronic Frontier Foundation

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EFF_Comments_to_Commerce.pdf 282.01 KB
EFF_Comments_to_Commerce_Exhibit_1_of_1.pdf 314.61 KB

CTIA - The Wireless Association

Submitted on January 28, 2011.
Dear Mr. Secretary,

I respectfully submit these comments on behalf of CTIA – The Wireless Association® in response to the Department of Commerce Internet Policy Task Force’s Commercial Data Privacy & Innovation in the Internet Economy: A Dynamic Policy Framework Docket No. 101214614–0614–01.

Sincerely,
Susan L. Lyon
Of Counsel

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Filed 2011-1-28 CTIA Letter to Dept of Commerce.pdf 54.65 KB

ACLU

Submitted on January 28, 2011.
Comments attached.

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Final Commerce Comments January 2011 on DNT.pdf 134.15 KB

Verizon | Christopher Oatway, Associate General Counsel

Submitted on January 28, 2011.
Dear Internet Policy Task Force:

Attached please find Verizon's comments in response to the Department's Notice of Inquiry in the above-captioned docket. Please don't hesitate to contact me with any questions.

Sincerely,

Christopher Oatway
Assistant General Counsel
Verizon
1320 N. Courthouse Rd., 9th Floor
Arlington, VA 22201

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01 28 11 Verizon, Verizon Wireless Comments NTIA Privacy NOI.pdf 81.24 KB

Centre for Information Policy Leadership

Submitted on January 28, 2011.
Information No. 101214614-0614-01
RIN 0660-XA22
Information Privacy and Innovation in the Internet Economy

To Whom It May Concern,

Attached please find the submission of the Centre for Information Policy Leadership's comments in response to the Department of Commerce's report entitled, "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework."

Please direct questions related to these comments to Martin Abrams (mabrams@hunton.com) or Paula Bruening (pbruening@hunton.com).

Sincerely,

Kiisha N. Jennings
Administrator

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Centre's Response to the DOC (Docket No. 101214614-0614-01).PDF 598.48 KB

TRA

Submitted on January 28, 2011.
On behalf of TRA, attached are the Comments of TRA in response to the Department of Commerce’s Request for Comment dated December 16, 2010 in Docket No. 101214614-0614-01, concerning Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.

Paul Glist | Davis Wright Tremaine LLP
1919 Pennsylvania Avenue NW, Suite 800 | Washington, DC 20006-3401

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TRA Comments.pdf 67.48 KB

National Business Coalition on E-Commerce and Privacy

Submitted on January 28, 2011.
Please find, attached, the comments on the Department of Commerce's proposed privacy framework by the National Business Coalition on E-Commerce and Privacy. Please confirm receipt.

Thomas M. Boyd
DLA Piper US LLP

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Comments of the NBC.pdf 491.28 KB

Tech Policy Institute

Submitted on January 28, 2011.
Comments in response to the NTIA's December 21, 2010 Notice and request for public comments, "Information Privacy and Innovation in the Internet Economy."

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Lenard_DOCPrivacyComments.pdf 209.25 KB

Entertainment Software Association

Submitted on January 28, 2011.
Please find attached the Entertainment Software Association's comments on the Department of Commerce's green paper, "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework."

Best,
Lindsey

Lindsey L. Tonsager | COVINGTON & BURLING LLP
1201 Pennsylvania Avenue, NW
Washington, D.C. 20004-2401

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Comments of the Entertainment Software Association.pdf 202.28 KB

NCTA

Submitted on January 28, 2011.
Attached for submission are the comments of the National Cable & Telecommunications Association in Docket No. 101214614-0614-01 [Information Privacy and Innovation in the Internet Economy].

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012811 Commerce Privacy Comments.pdf 112.71 KB