We appreciate the Commission's undertaking this effort to solicit public comments and sponsor a public dialogue on this important topic and we are especially pleased that the Commission has embarked upon this effort in a careful and thoughtful manner. Addressing the questions raised by the Commission in its notice is critical to the maintenance of consumer confidence in electronic commerce, and thorough research is a prerequisite to any successful effort to address these questions.

Along with many other companies supporting, and engaged in, electronic commerce, IBM is currently involved a variety of responsible efforts to understand how consumers rights can best be addressed in the Internet.

Among these are detailed studies of this subject being conducted by the American Bar Association, the Internet Law & Policy Forum, the Global Business Dialogue on Electronic Commerce, the Better Business Bureau OnLine and the International Chamber of Commerce. We are confident that, through the efforts of these groups, and others, as well as the careful and thorough work we expect from the Commission, a viable framework that addresses the questions raised by the Commission in this notice will emerge.

We look forward to supporting the Commission's effort in this area as it moves forward.

 Roger J. Cochetti

Program Director-Internet Policy & Business Planning,
IBM
1301 K Street, NW
Washington, DC 20005
202-515-5062