|March 26, 1999
RE: U.S. Perspectives on Consumer Protection in the Global Electronic Marketplace -- Comment, P994312
The Coalition for Advertising Supported Information and Entertainment (CASIE) is pleased to submit its comments regarding Consumer Protection in the Global Electronic Marketplace. We applaud the Federal Trade Commission's commitment to examining this important issue and look forward to the opportunity to participate in the Commission's upcoming workshop on this topic.
CASIE is a joint effort of the Association of National Advertisers (ANA) and the American Association of Advertising Agencies (AAAA) and includes numerous leading advertisers and advertising agencies across the nation. The CASIE mission is to create an environment where advertising revenue will continue to be the key source of funding for information and entertainment in the evolving world of media.
As you know, CASIE was an early proponent of online privacy, publishing its first privacy goals in 1995. Moreover, CASIE is one of the pioneers of the industry organizations that later became the Online Privacy Alliance, which has since signed on over 85 companies and trade associations.
The developing online world presents unprecedented opportunities for a truly global marketplace. CASIE believes that effective consumer protection is vital to ensure consumer trust in this new environment. We realize that consumer trust is a critical element that will determine whether and how quickly the Internet reaches its full potential as an interactive medium. The level of protection consumers feel online will determine whether e-commerce becomes a viable and widely accepted way of doing business.
Protecting the free flow of information across international borders is also essential for this global online marketplace to succeed and thrive. Open channels of information allow more businesses to economically offer a wider range of products and services, thus giving consumers more choice. This in turn will allow the medium to continue to grow.
CASIE strongly supports industry's efforts to empower consumers to make informed decisions about their online activities. We believe that industry can and should continue to be the policy leader in the online world. To that end, we support the attached principles offered by the United States Council for International Business (USCIB) in response to the FTC's request for comments on Consumer Protection in the Global Electronic Marketplace.
These principles allow for policies that promote consumer empowerment while letting the marketplace and developing technology dictate the best methods for consumer protection. They promote reliance on industry self-regulation and allow for an internationally acceptable set of guides for online practices. The principles seek to avoid prematurely constraining the evolution of this dynamic medium. In CASIE's view, this is the right approach to protecting consumers while fostering the growth of electronic commerce.
Thank you for the opportunity to submit these comments. We look forward to the public hearings scheduled for June of this year. As in the past, we expect to offer our own testimony at the upcoming hearings and will be delighted to assist the FTC as it seeks to identify and obtain additional speakers.
Harold A. Shoup Daniel L. Jaffe