January 5, 2000

By Hand

Mr. Donald S. Clark
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 Mr. Clark:

I am pleased to nominate Daniel Jaye, the Chief Technology Officer of Engage Technologies, Inc. ("Engage"), to serve as a member of the Federal Trade Commission’s Advisory Committee on Online Access and Security. In November 1999, Mr. Jaye participated in the FTC/NTIA Online Profiling Workshop, and he has long been a leader in the development of privacy protection technologies and policy. As discussed more fully below, Mr. Jaye would bring to the Advisory Committee an important perspective and highly relevant expertise. Both as a representative of an "online business" and as an "expert in interactive technology" (in the words of the Commission notice), Mr. Jaye is exceptionally well-qualified to make important contributions to this Advisory Committee.

Engage is an industry leader in providing profile-driven Internet marketing solutions. Headquartered in Andover, MA with over 300 employees, Engage was founded in 1995 by Mr. Jaye and David Wetherell. Engage, which made its initial public offering earlier this year (Nasdaq: ENGA), is a majority-owned subsidiary of Internet firm CMGI, Inc. (Nasdaq: CMGI). Engage and CMGI have both recently announced plans to acquire other online profiling-related companies: Engage signed an agreement to acquire AdKnowledge (a provider of online marketing management services), and CMGI is acquiring Flycast (a provider of web-based direct response advertising solutions) and AdForce (a provider of centralized advertising services).

Engage Technologies

From the outset, Engage’s founders recognized flexible Internet advertising as a tool critical to the fulfillment of the Internet’s potential to revolutionize the transmission of content and the conduct of commerce. The prevailing model of a fundamentally ad-supported web would serve to underwrite the Internet phenomenon for years to come only if advertising were transformed – by harnessing the revolutionary power of the Internet itself – from an uninvited nuisance into a welcome, customized consumer service. From the outset, moreover, Engage has recognized that the Internet should be a medium that gives consumers comfort, not concern, over their privacy. Engage’s mission has thus been to reinvent direct advertising for the online world in a way that not only greatly enhances the value to advertisers, but also greatly enhances both the experience and the privacy afforded to consumers.

Engage accomplishes its goals of promoting the value of online advertising and consumers’ privacy alike through its two core products, Engage Knowledge and Accipiter AdManager. Engage Knowledge is a database of user profiles that are devoid of personally identifiable information. Accipiter AdManager is an online advertising management system that automates the scheduling, targeting and delivery of ads on Web sites and the reporting of ad campaign results. Together, these products permit Web publishers, advertisers and merchants to deliver, target, and measure the effectiveness of advertisements, content and e-commerce offerings while respecting consumers’ online privacy. Additionally, Engage offers Web traffic verification, measurement, analysis, and research through its wholly-owned subsidiary, I/PRO.

Engage has also developed technologies to protect the security of even the non-personally identifiable information it collects. These include: a "dual-blind" technique to prevent the ability to associate a profile with an individual; discarding specific factual information collected from clickstream data as soon as it is factored into an interest score; specifically restricting participating sites’ use of the profiles; maintaining the profiles in a secure central location behind firewalls; and submitting its processes for formal review and regular audits by TRUSTe, of which it is a founding member.

Expertise and Background

Since co-founding Engage Technologies, Mr. Jaye has served as its Chief Technology Officer, spearheading the development of interactive database marketing products and information services. In this role, he has pioneered relationship-marketing solutions using VLDB parallel database technologies. He also coordinates the review of technology and privacy developments for several of CMGI’s affiliated companies, which (as noted above) include a growing range of Internet advertising firms.

Mr. Jaye has long led the industry in several online privacy initiatives. For instance, he is a co-author of the Platform for Privacy Project (P3P) Protocol Specification and is a participant in the P3P at the World Wide Web Consortium (W3C). He also authored and submitted to the Internet Engineering Task Force (IETF) an Internet Draft that proposes creation of "TrustLabels" to rate the privacy practices of web sites with regard to HTTP cookies (so that Web servers could inform users of their privacy practices and allow users to control how they wish to treat cookies based on its ratings). Through this proposal, Engage is helping to define the process by which better privacy standards are created and implemented on the Web.

Prior to co-founding Engage, Mr. Jaye served as Program Director for high-performance computing at Fidelity Investments, where he managed Fidelity’s retail marketing data warehouse and applications and led projects responsible for enterprise-wide retail customer management and re-engineering of the sales process. Prior to Fidelity, he worked at Epsilon and Andersen Consulting. Mr. Jaye holds a B.A. in astronomy, astrophysics and physics from Harvard College.

The FTC Advisory Committee

Mr. Jaye and Engage Technologies share the FTC’s commitment to ensuring the protection of consumers’ privacy online, and to the Commission’s goal of employing effective industry self-regulation to that end. The new Advisory Committee will provide a welcome opportunity for diverse parties concerned about protecting consumer privacy to recommend mechanisms to guarantee reasonable access to, and reliable security of, Internet users’ personal information.

Mr. Jaye and Engage have enjoyed participating in the development of privacy protection technologies and policy, and they look forward to continuing their contributions to the national dialogue in this crucial area. In particular, Engage is an online profiling company which "enhances" data without using personally identifiable information, and which has developed substantial security measures to protect the integrity of the profiles. Mr. Jaye can contribute to the Advisory Committee both his perspective as a founder and senior executive of this leading online network advertising company, and his experience as a leader in developing technological solutions to privacy concerns.

Thank you for your consideration of this nomination. Please contact me at (202) 719-7307 if you have any questions about Mr. Jaye or Engage Technologies.


Clifford M. Sloan
Counsel for Engage Technologies
1776 K Street, N.W.
Washington, D.C. 20006
(202) 719-7307
(202) 719-7049 fax