Secretary
Federal Trade Commission
Room H-159
Sixth Street & Pennsylvania Avenue NW
Washington, DC, 20580

Consumer Privacy 1997 – Request to Participate, P954807

Enclosed please find my comments on the Consumer Privacy 1997 workshop. I would greatly appreciate the opportunity to participate in this workshop. I would like to describe the approach that PowerAgent Inc. is taking to address the protection of consumer information online. PowerAgent will represent consumers in front of marketers and advertisers, and maximize the value that consumers receive in exchange for their time and information - through various Internet based applications. PowerAgent will protect consumers’ information in numerous ways, including:

• Separating consumers’ identities from their profiles into separate databases, and never allowing marketers or advertisers access to the combination of such databases. To ensure this, the "keys" that correlate this information will be protected by a third party.

• Giving consumers control of how their information is used, as well as of the information that will be sent to them by advertisers and marketers.

• Protecting consumers’ information with advanced and sophisticated security mechanisms.

Additionally to discussing PowerAgent’s system, I would also like to share with the attendees the views and experiences of three companies of which I am a member of the board of directors. These are:

Internet Profiles Corporation (I/PRO): as the leading measurement and auditing company on the web, we have had significant experience helping web sites analyze their traffic and audiences. I/PRO registered over 750,000 consumers for its I/CODE program during 1996.

LinkExchange: as the largest advertiser banner network on the web (with over 120,000 member web sites), LinkExchange measures and delivers over five million banner impressions per day to over one million unique consumers.

Silicon Investor: as the highest traffic site dedicated to the discussion of technology stocks, Silicon Investor has obtained detailed registration information from over 150,000 consumers.

I look forward to participating in this important workshop.

Sincerely,

Ariel Poler

Consumer Privacy 1997 - Comment, P954807

2.1

While most commercial web sites collect activity information, very few collect "clickstream" information, i.e., the path of unique users. This is due to the stateless nature of the web which doesn’t tie together all the activity from one user. Although tools are becoming available today to perform such analysis, it is still only performed by a very small fraction of sites. Regarding personal information, most sites do not collect any, although asking for information is becoming increasingly common. The most frequent pieces of information requested include name, email, zip code, and telephone number.

Consumer Privacy 1997 - Comment, P954807

2.2.

While collecting information in an aggregate fashion satisfies most research needs, marketers thus far have insisted on personally identifying consumers. This is due to the need, in traditional direct marketing, to establish a relationship with each individual prospect. New systems, such as the one under development by PowerAgent, will provide marketers with all the benefits of collecting personalized and identified information - including developing a one-to-one relationship with each consumer - while keeping consumers’ identities anonymous.

Consumer Privacy 1997 - Comment, P954807

2.9.

During the last 12 months, a consensus has emerged in the online industry to the effect that:

• consumers should not received unsolicited commercial messages
• consumer information should not be resold without their permission
• consumers should be aware of how their information will be used, and, at least, be given the opportunity of opting out from such a relationship
• In order to improve consumers’ online experiences, it is important to collect a certain amount of consumer information. Consumers, however, should be able to opt out from such improvements and/or the complete relationship, if they would rather not share any personal information

Consumer Privacy 1997 - Comment, P954807

2.13

One concern that has not been addressed to date is the reinforcement of the gap between the "information haves" and the "information have-nots". While personalizing consumers’ experience based on their profiles and interests does appear to be a win-win proposition, it does present the potential of increasing the gap between the above groups, by presenting more information to the "haves" and less (or different) to the "have nots".

Consumer Privacy 1997 - Comment, P954807

2.14

The increasing availability of digital certificates (over 750,000 issued to date) provide a mechanism for increased protection of consumer information. The current proposal (to the IETF) for a more sophisticated use of "cookies" by browsers would also increase protection of consumers’ privacy - although it might adversely affect consumers’ experiences online and the viability of online advertising as a significant industry. PowerAgent will also propose technology to further empower consumers’ ability to receive the information of their choice, as well as share their information with the advertisers and marketers of their choice.

Consumer Privacy 1997 - Comment, P954807

2.16

While unsolicited consumer email receives a lot of attention because it is so intrusive, it does not appear to be widespread, as most marketers realize that such action would be a losing proposition for them. Usenet groups and bulletin boards’ addresses seem to be the main source for unsolicited emails. Internet White page directories and online service directories are increasingly being used as well.

Consumer Privacy 1997 - Comment, P954807

2.19

PowerAgent will launch a revolutionary service to allow consumers control over the information that they receive from marketers and advertisers. We cannot disclose additional information at present, but shall be able to do so at the June workshop.