December 21, 1999

Mr. Donald S. Clark, Secretary
Federal Trade Commission
Room H-159
Sixth Street and Pennsylvania Avenue, N.W.
Washington, DC 20580

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

Dear Mr. Clark:

As Chief Privacy Officer for, I respectfully nominate myself to serve on the Advisory Committee on Online Access and Security. is the first Internet infomediary to achieve popular success. As a true Infomediary, works as a personal agent on behalf of consumers to help them take control over the profiling process. We allow our members to monetize and obtain value for the use of their personal data profiles without compromising their privacy. Launched in March 1999, we signed up 250,000 members in our first 10 days of operation and currently have over 4.5 million active registered members around the world. Through our Viewbar™ technology, we currently serve over 150 million banner-ad impressions each day while paying our members $0.50 per hour (currently capped at 25 hours per month) for the time they spend online. was ranked as the 13th most visited web property for the month of November 1999 according to PC Data, Inc.

As an Infomediary, works as a personal agent on behalf of members to realize monetary value from the personal profiles that our members permit us to build about them. Utilizing our Viewbar™ technology, we are able to collect data regarding individuals’ online viewing and purchasing habits. By collecting these profiles and by aggregating it with those of other individuals, we are able to accurately target relevant information directly to individuals and to present that information in real-time directly to their Viewbars™. Using the information gathered from our members, we are able to negotiate with marketers and vendors to the benefit of our members. Our slogan, "The Rules Have Changed… Get Paid to Surf the Web!" encapsulates the results of our business model: consumers are placed in a position of increased power and control over the collection and use of their personal information. Moreover, they have an agent working on their behalf to control how their information is used and to realize a share of the value advertisers place on that information. builds highly detailed activity-based profiles of its members through a mutual agreement between the two parties. Unlike traditional Web sites that extract data from visitors by unauthorized cookies and other mechanisms, legitimately obtains information from its members in a relationship built around disclosure, consent, and member control. In return, shares with its members a substantial portion of the value it is able to obtain for that information. Our relationship with our members is built upon four pillars: explicit notice, concurrent consent, compensation, and member privacy.

As Chief Privacy Officer for AllAdvantage, I am the member of the management team charged with ensuring that member expectations regarding the company’s privacy protection practices are met and that the company’s overall commitment to member privacy is constantly reinforced throughout all aspects of our business. My position and role within the organization is an example of’s commitment to member privacy and a sign of the importance privacy plays in our business.

On behalf of, I welcome the opportunity to share with the Commission why our business model radically changes the debate over online privacy practices, and why the rise of the Infomediary is one of the most important indications that the marketplace is beginning to meet the challenges posed by the current self-regulatory environment. Attached is a brief biographical summary outlining my work in the privacy and e-commerce arena. I would be pleased to provide any additional information that the Commission might require.

Thank you for your consideration.


Ray Everett-Church, Esq.
Chief Privacy Officer

Attachment: Biography of Ray Everett-Church, Esq.

Ray Everett-Church

Ray Everett-Church is Chief Privacy Officer and VP for Public Policy at, a leader in the emerging infomediary industry. He has a national reputation as an expert in the law and policy of information technology, Internet commerce, and privacy in cyberspace. Before joining, he was an attorney with the Washington, DC-area technology law firm of Haley Bader & Potts. Prior to that, he worked for 6 years as an independent consultant to the online services industry, high-tech startups, and other Internet ventures.

Mr. Everett-Church has been active in technology, privacy, and online marketing issues for many years. In 1997, the New York Times' online edition profiled him as one of the most influential proponents of responsible Internet commerce. He was a co-founder and currently serves as counsel to the Coalition Against Unsolicited Commercial Email, the nation's largest grassroots Internet advocacy organization with over 20,000 individual and over 200 corporate members. Mr. Everett-Church has helped draft numerous legislative initiatives at the state and federal levels to address the practice of unsolicited commercial email.

As an online industry consultant, Everett-Church provided advice on administrative, technology, security, and marketing to companies such as America Online, CompuServe, and numerous content providers and trade associations, including the National Association of Home Builders. He is an ad hoc advisor to the Internet Service Provider Security Consortium of the International Computer Security Association, serves as a member of the Congressional Internet Caucus' Advisory Committee for the 106th U.S. Congress, and is a Fellow with the Internet Telecommunications Project.

A frequent speaker and media commentator on legal and technology issues surrounding the Internet, he has testified before the United States Senate, the Federal Trade Commission, and has appeared on NBC Nightly News, The Today Show, CNBC, National Public Radio, and the Fox News Channel. His comments regularly appear in reports on CNN Interactive, and MSNBC, and in USA Today, the Wall Street Journal, the New York Times, the Washington Post, Wired News, and Interactive Week.

Mr. Everett-Church is a graduate of George Mason University and received a law degree from the National Law Center at The George Washington University. In his spare time he is technical administrator for the widely respected technology policy email discussion lists Cyberia-L and Cybertelecom-L, and the ComputerGuys-L mailing list (online companion to the monthly ComputerGuys show on National Public Radio's syndicated program "Public Interest"). He is a member of the Maryland Bar, The Internet Society, the Association for Computing Machinery, the American Bar Association, and the Federal Communications Bar Association.