January 3, 2000

Federal Trade Commission
Room H-159
600 Pennsylvania Avenue NW
Washington, DC 20580

Dear Sir or Madam:

I am writing to nominate myself for membership on the Federal Trade Commission Advisory Committee on Online Access and Security. Since I am submitting this nomination by e-mail two days before the deadline, I would appreciate it if you would confirm receipt and advise me if there is anything else I need to in order to complete this nomination.

I am a nonpracticing attorney and president of S.O.S., Inc.: Students for Other Students, an eleven year old nonprofit organization based in Toledo, Ohio. S.O.S. funds and develops student-to-student tutoring programs which are used in public schools in three states. Some of our initiatives include an online tutoring component.

I have several areas of interest and expertise in the questions to be examined by the Advisory Committee.

First, in my professional capacity as the president of a small educational foundation, I have concerns about students' online privacy. Increasingly, teachers at all levels are encouraging--and requiring--students to use the internet as a tool in completing their assignments. Unlike consumers, students may not have a meaningful choice about whether to visit sites that protect personal data or to view those that do not. Esther Dyson and others have argued in favor of a purely market-based response to online privacy issues, but that solution presupposes that everyone who might access a particular website has a completely free choice. Students frequently do not have such a free choice. This fact should be taken into account as the Committee frames its recommendations.

Second, as the operator of several small websites, I want to keep the exchange of information over the world wide web quick, easy and transparent. I believe that the web works well as an informational exchange medium because it imposes no onerous regulations, requirements or expenses on its users.

Third, as the father of two elementary school students, I have a parent's desire to safeguard my children's privacy, which I believe should be subject to more rigorous protections than my own.

Fourth, as a firm supporter of civil liberties--including the right to privacy--I have a number of concerns about the collection, archiving, use and sale of personal data collected over the internet. I use the web daily for shopping, research and entertainment and, like most people, am disquieted by the idea that my identity and surfing habits may be monitored and archived without my knowledge.

I have a good working knowledge of HTML and web design, the law, and the function of portal, news, educational and commercial websites. I also write fairly well. I would not come to the Committee with any particular agenda, except insofar as I have the concerns about privacy described above. I am not, however, wedded to any particular course of action in regard to those issues. I would come to the Committee with an open mind.

Thank you for evaluating my candidacy, and please feel free to contact me with any questions or comments.

Very truly yours,

James F. Trumm
S.O.S., Inc.: Students for Other Students
3171 N. Republic Boulevard
Toledo, Ohio 43615
Fax 419-843-7229
Phone 419-843-5798