Notice of Inquiry on Information Privacy and Innovation in the Internet Economy

(Late Submission)
Good afternoon:

Attached are NCTA’s Comments in the Information Privacy and Innovation in the Internet Economy proceeding.

Gretchen M. Lohmann
Legal Assistant
National Cable & Telecommunications Association

(Late Submission)
Attached please find comments from Facebook, Inc. in response to the Department's Notice of Inquiry on Information Privacy and Innovation in the Internet Economy.
Please do not hesitate to contact me if you have any questions.

John Bash
GIBSON DUNN

Ladies and Gentlemen

Please accept the attached comments from Zix Corporation in response to the Internet Privacy Task Force's Notice of Inquiry.

Respectfully submitted,


James F. Brashear
General Counsel and Corporate Secretary
Zix Corporation

(Late Submission)
Please accept the attached submission.

Thank you for your kind attention.

Alan Raul


Alan Charles Raul
SIDLEY AUSTIN LLP

(Late Submission)
On behalf of the Direct Marketing Association (DMA), we are submitting the attached comments in response to the Notice of Inquiry on "Information Privacy and Innovation in the Internet Economy."

Tara M. Sugiyama, Esq. | Venable LLP

(Late Submission)
To Whom it May Concern:

Attached please find the International Pharmaceutical Privacy Consortium's comments to the Department of Commerce's Notice of Inquiry regarding Information Privacy and Innovation in the Internet Economy, as published on April 23, 2010 in Federal Register Vol. 75, No. 78. Please feel free to contact me with any questions or follow-up regarding these comments.

Many Thanks,

Gaynne Zimmerman

Gaynne Zimmerman
International Pharmaceutical Privacy Consortium (IPPC)
Drinker Biddle & Reath LLP

(Late Submission)
On behalf of the American Association of Advertising Agencies, Association of National Advertisers, Direct Marketing Association, and Interactive Advertising Bureau, we are submitting the attached comments on the Notice of Inquiry on "Information Privacy and Innovation in the Internet Economy."
Regards,
Tara

(Late Submission)
To Whom It May Concern:

Attached you will find our response to the Notice of Inquiry on Information Privacy and Innovation in the Internet Economy.

Sincerely,

Rodney Petersen

--------------------------------------------------
Rodney J. Petersen
Government Relations Officer &
Director of Cybersecurity Initiative
EDUCAUSE

1150 18th Street, N.W., Suite 1010
Washington, D.C. 20036
(202) 331-5368 / (202) 872-4200

EDUCAUSE Policy Analysis and Advocacy
www.educause.edu/policy
EDUCAUSE Cybersecurity Initiative
www.educause.edu/security
Identity and Access Management
www.educause.edu/iam

(Late Submission)
Docket No. 100402174-0238-02
RIN 0660-XA12
Information Privacy and Innovation in the Internet Economy

To Whom It May Concern,

Attached please find the submission of the Business Forum for Consumer Privacy's comments in response to the Department of Commerce Notice of Inquiry dated April 23, 2010.

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

Sincerely,

Kiisha N. Jennings
Administrator - The Business Forum for Consumer Privacy

(Late Submission)
Dear Sir or Madam:

Enclosed please find comments on behalf of the Computer and Communications Industry Association (CCIA) in response to the April 23, 2010 "Information Privacy and Innovation in the Internet Economy" Notice of Inquiry. Thank you.

Sincerely,

Ed Black
President & CEO

(Late Submission)
To Whom it May Concern:

Attached are RILA’s comments to the Notice of Inquiry issued by the Internet Policy Task Force. Please let us know if you have any additional questions.

Warm regards,
Sarah


Sarah Arbes
Vice President, Government Affairs
Retail Industry Leaders Association

(Late Submission)
On behalf of GS1 US and GS1 EPCglobal, please find attached our response to the Department of Commerce National Telecommunications and Information Administration Notice of Inquiry “Information Privacy and Innovation in the Internet Economy.” Docket Number 100402174-0238-02.
Thank you,
Elizabeth Board
Executive Director, GS1 Global Public Policy

(Late Submission)
Attached please find comments from the Information Technology and Innovation Foundation (ITIF) on Information Privacy and Innovation in the Internet Economy in response to Docket No. 100402174-0175-01.

The filing is also available on our website at http://www.itif.org/files/2010-privacy-and-innovation.pdf



Daniel Castro
Information Technology and Innovation Foundation

(Late Submission)
To Whom It May Concern:

Attached are comments of the Telecommunications Industry Association.
Sincerely,

Christopher Calvert

(Late Submission)
We are pleased to submit the attached comments to the NOI. Please contact Zoe Strickland if you have any questions or comments.
Thank you,
Stacy Killion, VP Assistant
to Zoe Strickland, VP and Chief Privacy Officer

(Late Submission)
Attached please find a PDF version of the Comments of AT&T Inc. submitted in response to the Information Privacy and Innovation NOI.

Thank you,

(Late Submission)
Attached please find our submission in response to the Department of Commerce’s Notice of Inquiry in the Matter of Information Privacy and Innovation in the Internet Economy.

This paper was first published in the Georgetown International Journal of Law in 2007. The disparate rules and burdens on organizations created by international cross border limitations discussed in the attached paper remain of crucial importance. More countries have passed laws restricting the free flow of information and the problems for business, governments and consumers have been exacerbated. As our economy continues to become more global and information continues to be central to the way business is done, these issues will only become more acute.
We urge the U.S. Government to lead the international discussion on these crucial issues and work to find methods to ensure that information can continue to flow freely so that innovation is not stifled, consumers can continue to have access to the products and services they desire, businesses can compete and governments can work together.
Thank you for your consideration of our comments.

Miriam H. Wugmeister
Morrison & Foerster LLP

(Late Submission)
June 14, 2010

To whom it may concern:

Please find the attached comments of the Network Advertising Initiative in Docket No. 100402174–0175–01, Information Privacy and Innovation in the Internet Economy.

Sincerely,
Meredith B. Halama
Assistant General Counsel
Network Advertising Initiative

(Late Submission)
The Council of Better Business Bureaus respectfully submits the attached comments to the Department of Commerce Notice of Inquiry on
Information Privacy and Innovation in the Internet Economy.

Caitlin Burke | Administrative Coordinator, Children's Food & Beverage Advertising Initiative

see attached

(Late Submission)
June 7, 2010

To whom it may concern,

Attached please find the written comments of the United States Federal Trade Commission regarding the Department of Commerce’s Notice of Inquiry in the Matter of Information Privacy and Innovation in the Internet Economy. The attached comments are in PDF format. They are submitted by direction of the Commission and signed by Donald S. Clark, Secretary.

Sincerely,
Christopher M. Grengs
Attorney Advisor
Office of Policy Planning
Federal Trade Commission
600 Pennsylvania Ave., N.W.
Washington, D.C. 20580
(202) 326-2612
cgrengs@ftc.gov

This letter is written in response to the call for public comment made in the [Federal Register: April 23, 2010 (Volume 75, Number 78)], [Page 21226-21231], [Docket No. 100402174-0175-01]
Thank you for making the call for input.

Please find the cover-letter to our submission attached to this email.

The cover-letter mentioned above lists the following 6 documents as additional input.

Benjamin Gittins
Chief Technology Officer
Synaptic Laboratories Limited

(Late Submission)
Attached please find the submission of Intel Corporation in response to Docket Number 100402174-0238-02 on Information Privacy and Innovation in the Internet Economy.

Thank you.

Brian Huseman
Intel Corporation

(Late Submission)
To Whom it May Concern,

On behalf of the International Association of Privacy Professionals (the “IAPP”), I am delighted to share a recent research report on the future of the privacy profession. The IAPP is the world’s largest association of people working in the emerging field of privacy, and now boasts over 7,000 members in 52 countries. The IAPP serves members through a robust combination of educational, networking and certification opportunities.

As an organization, the IAPP does not take positions on matters of public policy. However, to celebrate our 10th anniversary as an organization, the IAPP recently commissioned a study on the future of the privacy profession. This report provides a compelling picture of the evolution of the management of privacy within organizations. In many ways, this report points to the critical role that privacy professionals play in actually making privacy “happen” within the public and private sectors. We felt that the report may be valuable in the Department of Commerce’s current process.

Of particular note is the continued growth of the IAPP’s certification programs – the Certified Information Privacy Profession (CIPP). This designation remains the only broad-based privacy credential available and continues to grow in certified professionals every month. We now have over 3,000 CIPPs around the world.

I hope this report is helpful to your understanding of privacy and the privacy profession. Please do not hesitate to contact the IAPP if you have any further questions.

Sincerely,

J. Trevor Hughes, CIPP
Executive Director
IAPP

(Late Submission)
Attached please find the written comments of Visa Inc. regarding the Department of Commerce’s Notice of Inquiry in the Matter of Information Privacy and Innovation in the Internet Economy.

Nathan D. Taylor

(Late Submission)
ALSO: Verizon Wireless, 1300 I Street NW, Suite 400-West, Washington, DC 20005

Dear NTIA Department of Commerce Representative: Please find attached in pdf format my analysis and comments on the issue of privacy. As you can see neither law, regulation, or practice has afforded U.S. parties the right of privacy as intended by Supreme Court interpretations of the U.S. Constitution. Respectfully submitted, John Nugent

Dr. John H. Nugent, LLM, CPA, CFE, CFF, CISM, FCPA
Associate Professor
School of Management, CFO 503
Texas Woman’s University
Denton, TX 76204-5649
Cell Phone: 001-214-682-8025 (preferred number)
Email: jnugent@twu.edu
Email: jnugent@texoma.net
Email: drjnugent@yahoo.com

(Late Submission)
Dear Dept of Commerce, if feasible we would like to replace the WMT submission to the NOI with the attached. The only difference is that we have added a date to the document. We apologize for the inconvenience.
Please contact me with any questions about the new submission, and Zoe Strickland if you have any questions or comments regarding its contents.
Thank you,
Stacy Killion, VP Assistant

(Late Submission)
Please find attached IBM's submission to the Commerce Department's Notice of Inquiry on Information Privacy and Innovation in the Internet Economy.

Please contact me if you have any questions. Thank you.

(Late Submission)
Attached are CTIA - The Wireless Association's comments in response to the Department of Commerce's Information Privacy and Innovation in the Internet Economy Notice of Inquiry (Docket No. 100402174-0175-01).

Thank You


Shanée J. Meeks
Coordinator, Regulatory Affairs

(Late Submission)
Please accept comments from NetChoice in response to the Department’s NOI on Information Privacy and Innovation (attached).

Thank you very much for this opportunity to comment.

-Braden Cox

(Late Submission)
Please find attached eBay Inc’s comments to the Department of Commerce’s NOI on Information Privacy and Innovation in the Internet Economy, Docket No. 100402174-0175-01. If you have any questions please do not hesitate to contact me. Thank you for the opportunity to weigh in on this important issue.

Lauren Sholley
Manager of Federal Government Relations
eBay Inc.

(Late Submission)
Attached are the comments of the National Business Coalition on the NOI. We regret the delay but wanted to submit our thoughts nonetheless.

Thank you,

Tom Boyd

Thomas M. Boyd

(Late Submission)
Please find attached a submission from the Financial Services Forum to the Department of Commerce, National Telecommunications and Information Administration in response to its request for comments on its Information Privacy and Innovation in the Internet Economy.

Mark Schuermann
SVP, The Financial Services Forum

(Late Submission)
Dear Sir/Madam:

Attached is input to the Notice of Inquiry: Information Privacy and Innovation in the Internet Economy from the Procter & Gamble Company.

Please return confirm receipt.

Sandy Hughes

Dear Messrs. Locke, Strickling, Sanchez, and Gallagher,

Please file the attached letter of the Samuelson Law, Technology & Public Policy Clinic at UC Berkeley Law (ntia_letter_june_2010.pdf) and supporting documentation in Docket No. 100402174–0175–01, RIN 0660–XA12, Information Privacy and Innovation in the Internet Economy.

Thank you,
Chris Hoofnagle

(Late Submission)
The Marketing Research Association (MRA) is pleased to submit the attached comments in response to Docket No. 100402174-0175-01, Information Privacy and Innovation in the Internet Economy.

Best,
LaToya Lang

(Late Submission)
Dear Sirs and Madams:

Please find Microsoft Corporation’s submission for the Privacy NOI. Please do not hesitate to contact me should you have any further questions.

Kind regards,

Julie

Julie Inman Grant, CIPP
Director, Privacy and Internet Safety Outreach
Microsoft Trustworthy Computing (TwC)
Privacy, Accessibility, Geopol & Online Safety (PAGO)

See attached

(Late Submission)
To Whom It May Concern:

Attached please find the American Federation of Musicians of the United States and Canada’s submission in the NTIA’s Information Privacy and Innovation in the Internet Economy NOI.

Thank you.

(Late Submission)
Docket No. 100402174-0238-02
RIN 0660-XA12
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 Notice of Inquiry dated April 23, 2010.

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

Sincerely,

Kiisha N. Jennings
Administrator

(Late Submission)
Please file the attached letter and supporting documentation from the ACLU in Docket No. 100402174–0175–01, RIN 0660–XA12, Information Privacy and Innovation in the Internet Economy.

Thank you,


Sandra Fulton
ACLU Washington Legislative Office
915 15th St., NW
Washington, DC 20005

sfulton@dcaclu.org

(Late Submission)
Dear NTIA,

Please find attached HP's submission to the current Notice of Inquiry for Information Privacy and Innovation in the Internet Economy [Docket No. 100402174-0175-01].

We appreciate the opportunity to contribute our thoughts and ideas.

With best regards,

Larry Irving
Scott Taylor

Comment attached

(Late Submission)
Please find attached the Salesforce.com response to the Department of Commerce NOI.

Daniel Burton
Senior Vice President, Global Public Policy
salesforce.com

(Late Submission)
Attached are the comments of the Digital Due Process coalition to the NTIA NOI "Information Privacy and Innovation in the Internet Economy" (Docket No. 100402174-0238-02).

Please contact me with any questions or concerns.

Thank you.

-
Harley Geiger
Policy Counsel

(Late Submission)
June 25, 2010

Office of Policy Analysis and Development
National Telecommunications and Information Administration
U.S. Department of Commerce
1401 Constitution Avenue, NW
Washington, DC 2023

Dear Colleagues:

I’m writing in response to the Notice of Inquiry re Information Privacy and Innovation in the Internet Economy. In particular, I’m writing to recommend that the Department of Commerce consider advocating for stricter laws governing the use of personal information combined with the provision of a Safe Harbor program. This is a regulatory strategy under which a federal statute explicitly recognizes differences in industry performance by treating safe harbor participants more favorably than non-participants. This approach builds upon the safe harbor program outlined in COPPA. Although COPPA’s safe harbor program was well intended, it suffers from a low rate of adoption due to a lack of regulatory flexibility and failure to sufficiently differentiate statutory compliance from program participation.

Properly implemented, a robust safe harbor program could afford the ideal environment to foster innovations in privacy protection while allowing as much flexibility as possible for industry innovation. Critical to the success of a new Safe Harbor program would be differential treatment between firms that chose to participate and those that do not. The DOC should promote what is sometimes referred to as a “co-regulatory” approach, with the right balance of carrots and sticks to incentivize businesses to participate while providing them the space and means to influence the regulatory process. Safe harbor benefits would be limited to firms demonstrating superior performance and would not be available to other covered entities that merely meet the default statutory requirements. This co-regulatory approach is more fully described in my article, “Privacy and Regulatory Innovation: Moving Beyond Voluntary Codes” which is available online at http://ssrn.com/abstract=1510275.
Thank you.
Sincerely,
Ira Rubinstein
Senior Fellow, Information Law Institute, NYU School of Law

(Late Submission)
Please find attached our comments in response to the National Telecommunications Administration's Notice of Inquiry on "Information Privacy and Innovation in the Internet Economy."

Sincerely,

Katie Shilton & Deborah Estrin, UCLA CENS

(Late Submission)
Please see the attached Comments of the State Privacy & Security Coalition In the Matter of the Request for Comments on Information Privacy and Innovation in the Internet Economy.

Adrian B. Copiz

(Late Submission)
To whom it may concern,
Please find attached The United States Council for International Business submission in response to the Privacy NOI.

Regards,


Heather I. Shaw
Vice President, ICT Policy
U.S. Council for International Business