December 23, 1999

United States Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, NW
Washington, D.C. 20580

Re: Advisory Committee on Online Access and Security

Nomination – P004807

Dear Sir or Madam:

Pursuant to the Federal Register notice published on December 21, 1999, I submit this letter to nominate myself to serve on the Commission’s Advisory Committee on Online Access and Security. I have attached my professional biography.

From it you will see that I am the Managing Director of the Washington, D.C., office of Kroll Associates, Inc. ("Kroll"), a private investigative and security consulting company. Kroll is an active user of online information during investigations, and also consults with many hundreds of commercial institutions and corporations on information security issues. Kroll’s website describes our extensive services in this area. () My professional interest in the topics to be addressed by the Commission is therefore strong.

Please also note that I have served as Assistant General Counsel for one of the largest telecommunications carriers in the world (MCI), and have earned an LL.M. degree focused on Intellectual Property. My LL.M. thesis, on the importance of cryptography in the preservation of legal rights to privacy, is published online at . While at MCI, I worked on a number of issues concerning online privacy and other consumer privacy issues.

Having worked professionally in the above areas, I feel that I can provide useful comments and advice on many of the issues outlined in the Federal Register notice. These issues would include the feasibility of identifying individuals who seek access to information; the commercial reasonableness of security standards for websites; the likelihood of abuse of personal access rules; the risks of unauthorized use and disclosure; and the legitimate commercial or investigative uses of personal data about consumers.

I believe that I could offer a representative business perspective on the issues to be considered by the Advisory Commission. Please call me at 202-371-6777 if there is more information that I can provide.

Very truly yours,

John A. Fraser
Managing Director & Counsel

John A. Fraser

John Fraser is Managing Director and Counsel in Kroll Associates’ Washington, D.C. office. Since joining Kroll in 1996, Mr. Fraser has been responsible for managing significant information security consulting assignments; Internet investigations; internal corporate investigations; competitive intelligence matters; kickback cases; intellectual property; gray market; multi-national business intelligence matters; litigation-related investigations; and business control studies.

Prior to joining Kroll, Mr. Fraser worked for MCI Communications Corporation from 1986 to 1996, where he rose from Senior Attorney to Assistant General Counsel. Mr. Fraser built MCI’s in-house commercial litigation department and was in charge of business litigation in areas ranging from advertising to zoning. Mr. Fraser also supervised MCI’s legal compliance programs and wrote and enforced the company’s business ethics guidelines.

Before working with MCI, Mr. Fraser was an associate in the Labor Law section of Morgan, Lewis & Bockius in Washington, D.C. from 1981-1986.

Mr. Fraser graduated with honors from Fort Lewis College in Colorado (B.A., 1977) and Washington & Lee University (J.D., 1980) and served as a law clerk for Judge Roger Robb of the United States Court of Appeals for the District of Columbia Circuit. Mr. Fraser was awarded the LL.M. degree by the University of Virginia in 1997.

Mr. Fraser has been active in the American Corporate Counsel Association for years, including service as Vice Chairman of the Litigation Committee in 1995-96. He is a frequent speaker and writer on legal ethics, investigations, due diligence, intellectual property investigations, and cost-saving techniques for in-house counsel and corporate clients. His most recent legal journal publications are on the subjects of constitutional protection for encryption technology and privacy, the enforcement of international arbitration awards, and checklists for international due diligence.