Dear Sirs/Mesdames:

I would like to nominate myself (if possible) for appointment to the FTC Advisory Committee on Online Access and Security.

I am founder and CEO of a three year old, permission-based customer profiling company, FollowUp.Net. Our company provides customer profiling infrastructure (technology and services in a single package) to both large and small commercial web sites. This gives me a solid and well-balanced perspective on the current issues and practices as well as the dynamics of the industry. In addition, I run a non-profit organization of Internet professionals that has explored this area and I can commit to attending all of the meetings.

As a permission-based profiling company, FollowUp.Net provides Web-hosted, third party services to vendors who want to know more about their customers. Our applications only work with the explicit consent of individual customers.

We provide this service for the largest "dot-com" retailers (such as,,, et al.) as well as in a bundled feature set of the newer e-commerce hosting solutions that IBM, Intel and others sell to small e-commerce merchants. We have attained this broad market acceptance because we are one of the very few solutions that requires customer permission for profiling. Companies use our services exclusively or add our services and technology to their clickstream and transactional customer profiling techniques.

In our situation, we work with the profiling issues important to the largest companies as well as the smallest. For example, uses our applications to profile over a hundred thousand customers per month and we provide customized technology integration directly into their very large customer databases. On the other end of the spectrum, through partnerships with IBM and Intel and others, we sell the same service to a 5-employee hair salon, enabling them to collect profile information on their 65 customers for only $29 per month.

Many big companies like IBM and Intel believe that small business e-commerce will be an enormous business in the coming year and we are very interested to be leading the analysis of customer profiling for the "little guy" e-commerce vendor and to see how he deals with this sensitive information. Our broad perspective as third-party technology and service supplier would be valuable to the committee because we are at the very forefront of a variety of customer profiling and profile management issues. However, as an application service provider, and not a vendor, we also interact directly with the customers regarding their questions about our profiling systems and their specific profiles. We are the first to see profiling response rates change when different techniques are used. We process the "unsubscribe" messages that vendors receive when the annoy or do not provide value to their customers. And as a business trying to build the right solutions for a dynamic market, we respond to consumer sentiment on the use of their profiles as we plan our future products.

FollowUp also provides the core profiling infrastructure to several "infomediary" web sites that profile individuals - in this case we act as "fourth-party" service provider.

While we are a venture-backed commercial enterprise endeavoring to develop a profitable business (which we have been the last two months, demonstrating the viability of our business model), we have a definite approach to customer profiling and information usage:

We believe that the most effective customer profile is one that comes from a permission-based, explicit process of customer participation. To know your customer, you must ask them and they must be willing to tell you. We do not believe that clickstream analysis (interpretive analysis of a customer's web visits) - either with or without the customer's knowledge - is the best business practice for either the vendor or the customer. FollowUp.Net differentiates itself in this regard. Our viewpoint is that clickstream analysis doesn't give the vendor enough information to adequately address the consumer's needs and that it is also resented by the consumer as an invasion of privacy. In the last months we have seen both the reduction of vendors relying on clickstream analysis because of its limitations, as well as a rise in complaints to our vendor clients from customers who resent the surreptitious tracking of their activity.

We have several very interesting and "market-inspired" products in use and in development that allow customers to manage their own profiles as used by vendors.

In the coming weeks FollowUp will be publishing a white paper titled "Letting the Customer Control Their Identity: Methods, Practices and Effectiveness of Customer-Managed Profiles on Vendor Web Sites." This paper will explore the issues and analyze our experiences in building this technology during this evolving business environment.

Other particulars which may be of value to the Advisory Committee are:

I am the founder (1993) and current managing director of the Connecticut New Media Association, a professional networking group for internet professionals that meets monthly to discuss Internet issues. Our September meeting explored direct marketing over the Internet and consumer privacy issues.
I have spoken at many events including several Internet World trade shows.
I previously submitted comments to the FTC regarding the Online Profiling Project.
I was a legislative aid at the Governor of CT's Washington, D.C. office (reporting on environmental legislation) for a Summer during college.


Chris Woods, CEO
1017 Post Road East
Westport, CT 06880-5370
tel (203) 226-5853 x 43
fax (203) 226-7331