Telephone: (703) 207-9353                                 Facsimile: (703) 207-0343

January 5, 2000

Donald S. Clark, Secretary
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:

I would like to be considered for participation on the Advisory Committee for Online Access and Security, as described in Federal Register Notice of December 21, 1999.

In addition to being an attorney specializing in software and Internet law, I have litigated cases under the ECPA and have developed and operated an online legal drafting system for several years (

My most recent project is, a new privacy seal program. PrivacyBot uses web-based process automation to improve the efficiencies and reduce the cost of running a seal program to make widespread implementation of good privacy practices more feasible. As part of the PrivacyBot project, I studied and applied the detailed requirements of COPPA. I also filed two public comments on the FTC rules implementing the Children's Act.

I filed an application with the FTC for PrivacyBot to be approved as a "safe harbor" privacy seal program. In this application, I again addressed the detailed requirements of COPPA and the Final Rule.

The various roles I play as a lawyer, privacy advocate, privacy seal agency and commercial web site operator provide an assortment of perspectives that I would like to contribute to the effort to determine what is good policy, what is technically feasible and how to reconcile legitimate competing interests.

I live in Northern Virginia and do not see any problem meeting downtown on the scheduled dates.


John A. Newman, Esq./Founder