January 5, 2000

By E-Mail and Hand Delivery

Mr. Donald S. Clark
Federal Trade Commission
Room H-159
Washington, DC 20580

Dear Mr. Clark:

I would appreciate your considering me as a candidate for participation on the Commission's Advisory Committee on Online Access and Security. If accepted, I will represent the interests of Time Warner Inc.

Time Warner, the leading media and entertainment company in the United States, is one of the world's largest providers of content in some of the most popular sites online, with more than 13 million unique visitors every month. We are also an online service provider, including Internet access, through our Road Runner cable modem service, with subscribers in communities around the country. In addition, Time Warner is one of the largest direct marketers in the United States through mail and telephone solicitations and television advertising.

Time Warner has been for years been a proponent of reasonableness and proportionality in the area of online access and security. We believe that online access and security policies must take into account the retrievability of the data, its sensitivity, and analogous practices in the offline world. For example, measures to verify the identity of a requester should be able to differentiate between situations when a requester asks for access to information that includes credit account data and when he asks for basic magazine subscription data that is routinely displayed on the labels of shipped magazines.

As Vice President for Law and Public Policy of Time Warner, I help coordinate the practices and polices of a large, diversified, and decentralized company that collects individually identifiable information for a range of legitimate business purposes at many of its hundreds of Web sites. I also have represented Time Warner in a variety of Internet-related policy fora, including in Federal Trade Commission workshops and congressional hearings. In addition, I have examined the issues of access and security in both the online and offline contexts.

Should you need additional information about Time Warner or me, please do not hesitate to contact me at (202) 457-9226. I look forward to hearing from you.


Arthur B. Sackler