Temple University School of Law
A Commonwealth University
1719 N. Broad Street
Philadelphia, PA 19122-6098

Amelia H. Boss
Charles Klein Professor of Law
(215) 204-8947
Fax: (215) 204-1185
E-mail: aboss@vm.temple.edu

January 5, 2000
The Honorable Donald S. Clark
Secretary
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue, N.W.
Washington, DC 20580
Re: Advisory Committee on On-line Access and Security -- Nomination, P004807
Nomination of Jeffrey B. Ritter

Dear Mr. Clark:

During the last ten years, I have been closely involved in advancing the emerging law of electronic commerce. As a member of the United States delegation to the United Nations Commission on International Trade Law regarding electronic commerce law reform, as an informal advisor to the Department of Commerce General Counsel Andrew Pinkus on electronic commerce policy, and as the Chair-Elect of the American Bar Association's Section of Business Law, I have had the opportunity to observe the escalation of privacy as an essential issue to be resolved in building the legal and policy framework for electronic commerce. In addition, I have worked with scores of individuals in the United States and around the world among the technology, business and legal communities. It is from this perspective of experience that it is my pleasure to nominate Mr. Jeffrey B. Ritter of Washington, DC to serve on the Advisory Committee on On-line Access and Security.

During the last twelve years, Mr. Ritter has emerged as one of our pioneers in shaping electronic commerce law and policy. Currently, he serves of counsel to the national law firm of Kirkpatrick & Lockhart LLP, where he is the co-chair of their electronic commerce practice. Mr. Ritter's legal practice involves virtually all aspects of electronic commerce, including serving many industry sectors in which the implementation of appropriate privacy protections has been a central focus of his recent work, including financial services, health care, international trade, and human resources.

In response to the criteria identified by the Commission in requesting nominations, allow me to briefly highlight why I believe Mr. Ritter would be a valued member of the Advisory Committee:

• Mr. Ritter has a comprehensive understanding of the business, technology and legal components of electronic commerce and, in particular, their integration in the management of personal information. As an entrepreneur, consultant, researcher and attorney (positions that Mr. Ritter has held during his career in electronic commerce), he has worked closely with the complex technologies of web-based databases, authentication technologies, data mining and EDI, to name just several. His understanding of the difficulties of implementing technologies and business practices on an integrated basis to produce the practical solutions demanded by suitable privacy policies will be a useful perspective.

• Mr. Ritter has extensive practical experience in developing policy formulations relating to privacy. During his tenure as a co-rapporteur on legal questions to the United Nations (1990-1996), he actively negotiated with EU officials as early as 1991 on the implementation of privacy protection in commercial transactions. In addition, he was a contributor to the initial OECD Committee on Consumer Policy meeting on electronic commerce in March 1997 in Paris, at which Mr. Ritter addressed the role of industry in the self-regulation of personal information and related business practices. His service in advancing electronic international trade and, in particular, understanding the impact of electronic commercial practices upon established multi-national corporations will provide an invaluable depth to the deliberations of the Advisory Committee.

• Mr. Ritter is an experienced veteran in exercising the delicate skills required to accommodate differing points of view in the formulation of effective electronic commerce strategies. As the Organizing Chair of the Internet Law & Policy Forum (www.ilpf.org) and as the founding Chair of the American Bar Association Committee on Cyberspace Law (www.abanet.org/buslaw/cyber), Mr. Ritter has achieved a remarkable record in organizing divergent views toward the formulation of uniform law and policy. His broad understanding of electronic commerce will enhance the difficult challenges facing the Advisory Committee, and his experience in contributing toward consensus-based solutions will be a potentially valuable asset to the Committee.

I have enclosed a more detailed CV on Mr. Ritter's professional record. However, with respect to privacy, his strongest value to the Advisory Committee may be his actual, direct experience in developing suitable privacy protections for real businesses. During the last year, Mr. Ritter has directed numerous privacy projects for clients that are both multinational corporations and new start-ups. He is closely familiar with the work of trustE and BBOn-line and fully appreciates the complexities of implementing compliant business practices around existing legal requirements. If asked to serve on the Advisory Committee, I am confident Mr. Ritter will be an effective voice for understanding the practical implications of implementing privacy within the existing business structures of America=s established institutional corporations.

Please do not hesitate to contact me if I can be of further assistance.

Sincerely,
Amelia H. Boss

AHB:me
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