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Information Privacy and Innovation in the Internet Economy Notice

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.

Comments

Enclosed are a Letter and Attachment as comments of a Coalition of Child, Health and Consumer Advocates:

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

To Whom It May Concern:

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

Attached is a PDF document comprising the comments for Docket No. 101214614-0614-01 from the Center for Digital Democracy and U.S. PIRG.

(Late Submission)
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

The Marketing Research Association (MRA) hereby submits these comments in response to the Notice and requests for comment from the National Telecommunications and Information Administration, the International Trade Administration, and the National Institute of Standards and Technology, titled “Information Privacy and Innovation in the Internet Economy”.

Sincerely,
Howard Fienberg, PLC
Director of Government Affairs
Marketing Research Association (MRA)

To Whom It May Concern:

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

Dear Sir or Madam,

please find here attached in pdf format
my feedback to your consultation on privacy

Respectfully yours

Philippe Coueignoux PhD
President ePrio Inc.

Hello,

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

Dear Madam/Sir,

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

Please accept the attached privacy comment letter from the Retail Industry Leaders Association (RILA).

Doug Thompson
Vice President, Government Affairs
Retail Industry Leaders Association (RILA)
1700 North Moore Street
Suite 2250
Arlington, VA 22209

Please find attached a request by industry trade associations for an extension of time to comment.

Please find attached the submitted comments of eBay, Inc regarding the Department of Commerce’s green paper Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework. Thank you for the opportunity to participate in this discussion. If you have any questions please do not hesitate to contact me.



Lauren Sholley
Manager of Federal Government Relations
eBay Inc.

Please see the attached comments to the Privacy NOI.

Best,
Jerry Kang

______________________________________________
Jerry Kang, Professor of Law
Professor of Asian American Studies (by courtesy)
Korea Times--Hankook Ilbo Chair in Korean American Studies

Comments are attached.

Thanks,
Sharon Goott Nissim
Consumer Protection Fellow
Electronic Privacy Information Center
202-483-1140 Ext. 107

Attached see the comments of Google Inc in Docket No. 101214614–0614–01

--


Will DeVries | Policy Counsel | Google Inc. |

Hello:

Attached please find the comments of Peter Swire on the privacy Green Paper.

Thank you,

Peter Swire

Telcordia Technologies (Telcordia) hereby submits comments to the National Telecommunications and Information Administration (NTIA) on its Public Notice requesting comments on the Department of Commerce’s Internet Policy Task Force (IPTF or “Task Force”) report, “Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework”.

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

Good evening,

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

Dear Sir or Madam,


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

Morrison & Foerster LLP on behalf of the Global Privacy Alliance (GPA) is pleased to offer the attached submission in response to the Department of Commerce's request for comments on the green paper, "Commercial Data Privacy And Innovation In The Internet Economy: A Dynamic Policy Framework," issued by its Internet Policy Task Force.
> >
Sincerely,
Cynthia J. Rich
Morrison & Foerster, LLP.
2000 Pennsylvania Avenue, N.W.
Suite 6000
Washington, D.C. 20006

The attached comments in PDF form are submitted by Consumer Federation of America.
Susan Grant
Director of Consumer Protection
Consumer Federation of America

Comments are attached.

Nick Doty
Lecturer / Researcher
UC Berkeley, School of Information

Dear Sir or Madam,

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

On behalf of Experian, we provide the attached comments on the Commerce Department's "Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework" report.
Regards,

Tara Sugiyama Potashnik, Esq. | Venable LLP

Thank you for the opportunity to submit these comments to the Department of Commerce in response to questions posed in the privacy green paper.

Respectfully,
Beth Givens, Director
Privacy Rights Clearinghouse
3100 5th Ave., Suite B
San Diego, CA 92103

Comments of Dr. John H. Nugent are attached in PDF.

Attached please find the comments of Intel Corporation.

Brian Huseman
Intel Corporation

via email

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

Dear Sir or Madam,

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

Dear Internet Policy Task Force,

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

Privacy Policy Comments attached via PDF

Attached, please find the comment of the Consumer Data Industry Association (CDIA).

...........
Eric J. Ellman
Vice President, Public Policy and Legal Affairs
Consumer Data Industry Association

Please find attached USCIB’s Comments on the Department of Commerce Internet Policy Task Force Report on Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.

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)

Dear Sir/Madam,

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)

Attached are my personal comments to the Dec. 2010 IPTF Report, Docket No. 101214614–0614–01.

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

On the 18th of January I submitted a Word Doc with comments in response to the DOC Privacy Green Paper. You were kind enough to post it however the conversion to HTML makes it difficult to access.

I request that you replace the HTML doc with the attached PDF format.

Thank you for your assistance.


Ray Kingman
CEO
Semcasting, Inc.

Please find our reply comments attached.

--
Steve DelBianco
Executive Director
NetChoice

To Whom it May Concern:

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

Information Privacy and Innovation in the Internet Docket # 101214614-0614-01

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

(Late Submission)
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

Attached are the comments of the Interactive Advertising Bureau.

Regards,
Michael Signorelli

Michael A. Signorelli, Esq. | Venable LLP

MAPPS (www.mapps.org), the only national association exclusively comprised of private sector firms in the remote sensing, spatial data and geographic information systems field, is pleased to submit the attached comment on the Commerce Department “green paper”, Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework for the official comment docket.


John M. Palatiello, Executive Director
MAPPS
1856 Old Reston Avenue
Suite 205
Reston, VA 20190

The U.S. Chamber of Commerce is pleased to submit the attached comments in response to the Department of Commerce’s Internet Policy Task Force’s green paper on Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.

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

(Late Submission)
We are happy to submit these comments. Please feel free to contact me if you have any questions.


Amanda Pedigo
Federal Technology Policy
Intuit

To: The National Telecommunications and Information Administration at
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

(Late Submission)
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

Dear Internet Policy Task Force:

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

Attached are joint comments of the American Association of Advertising Agencies, American Advertising Federation, Association of National Advertisers, Direct Marketing Association, and Interactive Advertising Bureau on the Internet Policy Task Force report on commercial data privacy and innovation in the Internet economy.

Michael A. Signorelli, Esq. | Venable LLP

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