I-Behavior Inc.
75 South Broadway ( 4th Floor
White Plains, NY 10601
Phone 914-302-4040 - Fax 914-302-4041

                                    January 3, 2000

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

Advisory Committee on Online Access and Security - Nomination, P004807

The purpose of this letter is to nominate Lynn Wunderman for appointment to the Advisory Committee on Online Access and Security. Ms. Wunderman is uniquely qualified for the position, as outlined against the following selection criteria:
  • Would promote a balance of points of view represented and functions to be performed by the panel.
  • Has highly relevant expertise in the issues and technologies relevant to the implementation of fair information practices by commercial Web sites.
  • Is well positioned to represent of a broad range of interests affected by commercial Web sites' collection of personal information on consumers.

Overview of Ms. Wunderman's Background

Ms. Wunderman's primary professional expertise is in the field of database marketing. She has over 20 years of experience in the areas of strategic planning, database management, market analysis, target audience and media segmentation as used in the offline Direct Marketing Industry.

She is currently President, CEO of I-Behavior, a firm dedicated to serving the data and information services needs of e-commerce marketers. I-behavior's services include a co-operative database of opt-in on-line buyers, supported by an integrated suite of services, including Database Consulting and Management, Analytical Services and the-I-Behavior Data Lab (a provider of strategic consulting, behavioral research and product development services).

Prior to founding I-Behavior, Ms. Wunderman was a founding partner of Wunderman, Sadh & Associates, a consulting firm specializing in information-based marketing services for both consumer and business-to-business marketers in the financial services, high-tech, graphic arts, non-profit, and Internet industries -- with a particular focus on the needs of multi-channel companies.

From 1992 to 1998, Ms. Wunderman was President and C.O.O. of Marketing Information Technologies, a company providing database services for major Internet and Fortune 100 companies. Ms. Wunderman was formerly Senior Vice President, Director of Strategic Planning and Information Management at Ogilvy & Mather Direct.

Ms. Wunderman is active in the Direct Marketing Association, having served as Vice-Chair of the Marketing Council and on the Operating Committee of the Computer Council. Currently, Ms. Wunderman serves on the Internet Committee of the DMA Board of Directors.

Criteria #1: Ms. Wunderman's ability to promote a balance of points of view represented and functions to be performed by the panel.

Ms. Wunderman's participation will promote a balance of points of view because she has a direct, personal stake in the outcome of online data and privacy issues. Her company will prosper and grow to the extent that it is able to effectively acquire and analyze online consumer data. On the other hand, that business would be adversely affected if abuses of consumer privacy by others, or misunderstanding of the issues by consumers, leads to widespread consumer distrust or overly restrictive legislation.

Specifically, Ms. Wunderman's professional background qualifies her to hold a balanced view of privacy issues. As a direct marketer, Ms. Wunderman has been professionally involved with the collection and use of data for marketing applications for over 20 years. She has held professional marketing positions within corporations, has served account services and consulting roles to major corporations, and has managed companies serving in a vendor capacity - all positions involving the strategic use of consumer data and information to support marketing functions.

Ms. Wunderman has served leading corporations in the use of data for:

  • Finding lists of high-potential prospects
  • Development of segmentation tools to better predict and understand consumer behavior
  • Compilation of their customer purchase and response data for building and maintaining mutually-rewarding relationships with their buyers

Companies served include:

The Advertising Council America Online, American Express, Bristol-Myers, Carnation, Citicorp, Club Med, Duracell, Kimberly-Clark, Kraft, HBO Video, IBM, Lever, Mattel, Merrill Lynch, Nationsbank, NutraSweet, Olan Mills, Owens-Corning Fiberglas, Pantone, Perrier, SmithKline Beecham, Time Warner, Paramount Pictures, Unilever, and Van Kampen/American Capital.

Ms. Wunderman's current company is building the industry's first opt-in compiled co-operative database of online purchase information on consumers. In this role, she is actively involved in consumer privacy issues both for her firm and her firm's clients contributing data into the co-operative list. I-Behavior's activities include:

  • Researching industry standards and practices regarding published privacy statements
  • Constructing privacy statements for member sites in compliance with I-Behavior's use of their customer data
  • Development of a turnkey rewards program to encourage buyer opt-in to the list of online names and addresses
  • Monitoring legal/press news items

No legal or ethical issue impacts Ms. Wunderman's professional activities more than the issue of online consumer privacy. She is actively constructing a business designed to respect consumer privacy while making state-of-the-art use of consumer data for the mutual benefit of e-commerce marketers and their online customers.

Criteria #2: Expertise in the issues and technologies relevant to the implementation of fair information practices by commercial Web sites.

Ms. Wunderman is a recognized expert on the strategic issues and applications of technology involved in the collection and use of data for marketing purposes:

  • She currently heads a company that is developing proprietary technologies for use in managing the transactional data collected by e-commerce organizations (I-Behavior).
  • She has been actively involved in the areas of offline consumer list rental and processing, customer data capture, database design and maintenance, and the strategic use of consumer data compilations and customer data analysis for over 20 years.
  • She has managed companies responsible for the data capture, management and analysis of purchase data gathered on the Web for such noted companies as America Online, IBM and

Ms. Wunderman has a history of innovation in the application of traditional direct marketing techniques to new media. She has pioneered such areas as the application of direct marketing modeling techniques to the package goods industry, and the use of direct mail modeling techniques to support selective insertion of advertising in print media. She is now applying this experience to the use of new technologies for improved targeting efficiencies on the Internet.

An active industry speaker on the uses of consumer data in building profitable customer relationships, Ms. Wunderman was recently asked to sit on the annual conference program committee of the National Council of Database Marketing.

Ms. Wunderman offers a combination of traditional direct marketing expertise along with up-to-date experience in applying these tools to the area of e-commerce marketing.

Criteria #3: Representation of a broad range of interests affected by commercial Web sites' collection of personal information on consumers.

Ms. Wunderman's professional activities routinely address the needs of different business constituencies:

  • E-commerce marketers
  • E-marketing service companies/experts in interactive technology
  • Trade associations (Her active role in the Direct Marketing Association/Association for Interactive Media)

Recently, Ms. Wunderman was selected by the Direct Marketing Association's Board of Directors to represent the industry on its Internet Committee. Her nomination to the committee was based on her ability to fairly represent the data and privacy issues relevant to the Internet community in fulfilling the committee's mission.

In addition, Ms. Wunderman is personally an active online consumer buying from Web marketers and catalog companies with an online presence. She experiences first-hand what happens to her personal data and is personally concerned for the rights of the buying public.


Ms. Wunderman has exceptional professional qualifications that would be an asset to this committee, and she will be an active and committed contributor to the committee's work seeking an equitable, workable outcome.


                                Lynn Wunderman
                                President, CEO