Viacom Inc.
Suite 1100, 1501 M Street, N.W.
Washington, D.C. 20005

January 4, 2000

Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Re: Advisory Committee on Online Access and Security ? Nomination, P004807

Dear Secretary Clark:

Viacom Inc. ("Viacom") is pleased to submit this nomination in response to the Commission’s request for nominations of individuals for appointment to the Advisory Committee on Online Access and Security ("Advisory Committee"). Viacom is one of the world’s largest entertainment companies and is a leading force in nearly every segment of the international media marketplace. The operations of Viacom include Blocbuster, MTV Networks (which includes MTV: Music Television, Nickelodeon, VH1 and other program services), Paramount Pictures, Paramount Television, Paramount Parks, Showtime Networks, Simon & Schuster, 19 television stations and movie screens in 12 countries. Viacom also owns half interests in Noggin (a 24-hour, commercial-free educational channel for kids), the broadcast network UPN and Comedy Central.

With its focus on creating, producing and packaging content, it is only natural that Viacom has turned to the Internet for the distribution of its products. Viacom’s divisions operate several websites, including,,,,,,, and As an active citizen of the Internet, Viacom takes its online responsibilities seriously, particularly in the online privacy arena. Viacom is a member of the BBB Online Steering Committee and the Online Privacy Alliance, and was the first children’s website to be awarded the BBBOnline privacy seal. Accordingly, Viacom has a keen interest in participating in the Advisory Committee so that it can aid in formulating advice and recommendations to the Commission regarding implementation of fair information practices for access to personal information and security of that information.

Viacom nominates Nicholas Butterworth to serve on the Advisory Committee. Butterworth is the president and CEO of MTVi, where he is responsible for overseeing the growth and direction of MTV Networks’ music-oriented websites. Prior to this position, Butterworth was the president of SonicNet, Inc., the leading online music entertainment network. Butterworth also led the interactive efforts of SonicNet’s then-parent company, TCI Music. He has been with SonicNet since its days as a start-up bulletin board service, when he served as its creative director and editor-in-chief. Before that, Butterworth was executive director of Rock the Vote, a music industry charity which promotes voter registration to young people. Butterworth also served on the board of M.O.U.S.E. (Making Opportunities for Ugrading Schools and Eduction), a non-profit organization providing volunteer labor and technical support to New York City schools.

While Butterworth’s portfolio is focused on music-oriented websites, he has a strong background in public policy areas and works closely with his colleagues who create and operate the online activities of other Viacom divisions. Butterworth will be able to bring to the Advisory Committee not only his own hands-on experience in running MTVi and SonicNet but the varied online experiences shared by Viacom’s children’s programming, motion picture, television and publishing divisions.

In sum, Viacom respectfully requests that the Commission consider the nomination of Nicholas Butterworth to the Advisory Committee.

Respectfully submitted,
Anne Lucey
Vice President, Regulatory Affairs
Viacom Inc.
Tel: 202/785-7300