From: "Barry Hurewitz"
To: Advisorycommittee advisorycommittee@FTC.GOV
Date: Thu, Jan 6, 2000 11:06 AM
Subject: Re: Advisory Committee on Online Access and Security

Thank you for notifying me of the transmission problem. Below is another copy of the e-mail which I sent yesterday, January 5, 2000.

There are no attachments, as the entire message is contained in the text of the e-mail. -Barry Hurewitz Advisorycommittee wrote:

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January 5, 2000

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

RE: Advisory Committee on Online Access and Security' Nomination, P004807

Dear Sir or Madam:

Please consider the following nominations for the FTC's Advisory Committee on Online Access and Security, submitted in response to the Notice and Request for Nominations published in the Federal Register on December 21, 1999.

Mr. Gary Ciavola is the Vice President and Business Development Officer of Predictive Networks, Inc.

Mr. Devin Hosea is the President and CEO of Predictive Networks, Inc.

For the reasons discussed below, either or both of these nominees would be knowledgeable, active, and valuable participants in any discussion about information practices by domestic commercial Internet web sites.

Predictive Networks, Inc. provides new advertising and e-commerce systems for preferred content delivery on the Internet. "Preferred content" technologies mean that Internet users are provided with information that reflects their unique sets of interests and preferences. The Company has built its system around the highly robust click-stream data coming from the ISP access point -- the primary location of connectivity to the Internet for each user. This click-stream data, coming from all Internet activity -- not simply from a network of selected web sites -- is analyzed by a powerful set of profiling tools, which results in highly accurate and -- if desired, entirely anonymous -- user profiles. We are then able to deliver content in exactly the right format, at exactly the right time, and tailored exactly to user preferences.

Predictive Networks is a company that is constantly confronted with the issues of on-line privacy, security, and data access issues. Reflecting these concerns, Predictive Networks develops technologies and follows a business model that can address consumer privacy while maximizing the potential of e-commerce.

As daily participants in the on-line world of data collection and analysis, both Mr. Ciavola and Mr. Hosea are personally familiar with on-line privacy issues.

Mr. Ciavola and Mr. Hosea would provide the Advisory Committee with essential insights from the point of view of a commercial organization which has developed workable e-commerce solutions while preserving and protecting personal privacy. This perspective would provide an important balance to those who seek to prevent commercial use of click-stream data as well as those who might overlook important privacy and security concerns.

As discussed below, both Mr. Ciavola and Mr. Hosea have personal expertise and knowledge relevant to the Advisory Committee's work in the area of online data access and security:

Gary Ciavola, a sixteen year high technology veteran, is the Vice President and Business Development Officer for Predictive Networks, Inc. Gary worked for Internet industry leader CMG Information Services, Inc. from 1996 to 1998. Most recently, he served as Vice President of Operations and then Vice President of Finance and Administration and Corporate Secretary for the CMG subsidiary InfoMation Publishing Corporation. Previously, he was the Director of Business Alliances for CMG Direct Interactive (now Engage Technologies), a developer and marketer of precision online marketing solutions. Mr. Ciavola served in senior legal positions at Computervision Corporation and Prime Computer, Inc. from 1987 to 1996 and worked at custom software developer Softech from 1983 to 1987. He received a B.A. from Boston College, a Ed.M. from Harvard University and, while working at Softech, a J.D. from Suffolk University Law School.

Devin Hosea is the President and Chief Executive Officer of Predictive Networks. Devin is the principal developer of the Company's core neural-inferential modeling technology. Prior to founding Predictive Networks, he was a Vice President in technology investing for the GE Capital Equity Group. During his tenure at GE Capital, he served as Chairman of the Board and President of Vanguard Automation, Inc., a supplier of automated assembly systems integration solutions for high technology manufacturers. Mr. Hosea directed a dramatic operational turnaround at the near-bankrupt company which was sold one year later for $46 million. Before working at GE, Mr. Hosea was a National Science Foundation Fellow in Artificial Intelligence. He also worked as a buy-side analyst at the New York money-management firm of Sanford Bernstein & Co., Inc. He received his A.B. degree from Princeton University in 1991.

Thus, Mr. Hosea and Mr. Ciavola would offer the Advisory Committee an exceptional level of expertise in interactive and data profiling technologies and a business which utilizes such technologies. No discussion of online data access and security would be complete without this essential knowledge base. Both nominees would be valuable assets to the Advisory Committee.

Thank you for your consideration.

Respectfully submitted,

Barry J. Hurewitz
Hale and Dorr LLP
1455 Pennsylvania Ave., N.W.
Washington, D.C. 20004
(202) 942-8413
fax (202) 942-8484

On behalf of

Gary Ciavola
Devin Hosea
Predictive Networks, Inc.
180 Canal Street
Boston, MA 02114
(617) 367-4700
fax (617) 249-0932