|From: Michael Sondow [email@example.com]
Sent: Sunday, February 27, 2000 6:05 PM
Subject: Comments for The Advisory Committee
Dear Advisory Committee,
These comments are submitted to the Advisory Committee in the spirit of constructive criticism.
First, the Committee's purpose is variously given on your website as "Online Access and Security" and "Online Privacy". As is well known, these are not the same thing, and are frequently even in contradiction with each other when their point of view is that of ecommerce vendors and consumers, respectively. Wouldn't it be a good idea to clarify from the outset what the subject matter of the Committee really is?
In this regard, one would suppose that the FTC's Bureau of Consumer Protection would be a more ardent proponent of the latter rather than the former, that is, of Online Privacy, which is a consumer protection issue. The need for security in financial transactions is more an ecommerce issue than a consumer protection issue, or is at least a minor issue in the panoply of invasions of privacy occurring on the Internet, which includes such abuses as the selling of customers' private data to third parties and covert surveillance.
Then, if the orientation of the Committee is towards consumer
protection and online privacy, why are only a minority of the
paticipants representatives of the consumer public, and a majority
representatives of either ecommerce or for-profit Internet
infrastructure companies? When I posed this question to someone at the
FTC, I was told that the consumer protection issues had already
Lastly, even the few representatives of non-commercial interests on the Committee are not, with the possible exception of Mr. Torres from Consumers Union, true consumers of Internet and ecommerce services. They are representatives of supposed public interest Internet non-profit corporations, which is not the same thing at all, since those non-profit corporations are made up almost exclusively of Internet technical people and their lawyers. Why are there not more consumers, or representatives of consumers like the Nader organization, on the Committee, to balance the influence on it of commercial power?