Before the Federal Trade Commission
COMMENTS OF THE INTERNET ALLIANCE
INTERPRETATION OF RULES AND GUIDES
FOR ELECTRONIC MEDIA -- REQUEST FOR COMMENT,
FTC FILE NO P974102
Jeff Richards, Executive Director
Date: July 7, 1998
The Internet Alliance (IA) is pleased to respond to the Federal Trade Commission's Notice Requesting Public Comment on its proposal to issue a policy statement regarding the applicability of its rules and guides to newer forms of electronic media, such as e-mail, CD-ROMs, and the Internet, 63 Fed. Reg. 24996 (released May 6, 1998). The IA is the leading trade association of the Internet online consumer marketplace and its member companies provide paid Internet and online access to 85 percent of consumers in the United States today. Beyond providing consumer online access, IA members provide a diverse array of Internet and online products and services. Therefore, the IA appreciates the Federal Trade Commission's (Commission) request for public comments on this important issue.
The IA agrees with the Commission that consumer trust and confidence will fuel the commercial and cultural growth of the Internet. In fact, the IA's mission is to promote consumer trust and confidence in the Internet so that it can become the mass market medium of the 21st Century. The Commission's intent to enhance such consumer confidence through its proposed policy statement is most welcome. We look forward to helping the Commission in its efforts to clarify how its consumer protection rules apply to the electronic marketplace. The IA and its members seek to promote the safety and reliability of the Internet online marketplace. Therefor, the IA believes that those businesses or individuals engaging in unfair and deceptive practices in the electronic media should be prosecuted to the fullest extent of the Commission's authority. Through these comments we hope to offer insight into the delicate task of fostering consumer trust and confidence while preserving the operational flexibility needed for the medium to fulfill its limitless potential.
The IA also commends the Commission on its procedural approach to clarifying the consumer protection rules. We believe that a policy statement provides the flexibility needed when addressing the issues presented by such a fluid and ever-changing marketplace such as the Internet. In addition, the willingness on behalf of the Commission to engage the industry in a dialogue is likewise appreciated. We hope that the comments below will serve as a platform for more detailed and more interactive communications with the Commission.
The IA strongly supports the Commission's proposal to convene a public workshop to examine the issues raised in this Notice. The IA notes that its comments raise more questions than they answer. We believe that a workshop will provide an appropriate forum to work with the Commission to answer some of these questions and others and we believe that a workshop will allow the IA and the Commission to more fully examine the technical problems associated with applying existing consumer protection rules to this new medium.
The Commission is correct in its position that electronic media is unique. The Commission should carefully consider how it applies its current consumer protection rules to the online environment. The uniqueness of the Internet online medium makes an easy application of the Commission's rules impossible. As the medium is different, so too should be the rules and regulations designed to protect consumers.
The nascent medium is far from static. Every day, new applications, services and products are reshaping the landscape. The IA urges the Commission to apply its rules in way that will ensure the continued growth of the Internet and online marketplace.
There are many technical reasons why the electronic media defies easy application of the consumer protection rules originally designed for traditional media. The IA believes that a truncated version of a comprehensive paper written by Glee Harrah Cady, Chair, IA Public Policy Council and Senior Director, Technology and Public Policy, ICG Communications Inc. would be an appropriate prelude to this discussion. The paper by Ms. Cady serves to highlight the uniqueness of the medium (See Appendix I for full text of the paper).
The Internet provides a platform for many different tools to enable many different types of communication. Very often, those tools are interactive. Messages are not restricted to one particular form of communication at a time. Combinations of tools can be used to provide a communication experience that rivals that of in-person communications. At the moment, email and the World Wide Web are the tools most frequently used for electronic commerce but they are not the only ones.
Client and Server Program Architecture
Text -- Most, but not all, of the communication modes rely on text. In the cases where text is used, the choice of font size and background color, etc., usually may be controlled by the user. Newer versions of Web page design languages give the designer greater control of information placement and display, but much of that display remains in the control of the user.
View -- The user views information on the Internet differently depending upon the model and size of his screen or monitor. Differences in software (e.g. type font collections) will also alter the appearance of the text display. For instance, user browsing the Internet with an older model IBM Personal Computer with a black and white, non-graphical display will have a significantly difference experience than someone using a 1998 model computer with full color screen and graphical displays.
Client and Server -- The distinction between client programs and server programs is important for understanding Internet communications. A client program is usually responsible for:
The interaction of client and server programs allows for customization of the Internet experience from both sides of the Internet communications relationship. This flexibility is a very positive and unique feature of the Internet architecture and gives it the ability to meet many needs. Client programs have been developed for many different kinds of computers and thus many older models of computers are still useful. The information designer need not design for all the individual combinations of preferences and equipment that can be used. The designer's inability to completely control the presentation and display of the information to the end user makes the experience imprecise and somewhat unpredictable. Communications that seem clear in one environment may be less clear in another. However, this flexibility empowers end users to create a visual experience which meets their personal viewing preferences making it more enjoyable. More importantly, it allows providers and designers to constantly roll out new, cutting-edge features without having to wait for all of the end users to possess the software, hardware and/or bandwidth needed to view them as designed.
It is important to note that the medium is rapidly evolving technologically. While the fundamental client/server architecture of the Internet is not likely to change in the near future, the manner of client/server interactions are changing every day. This explosive technological growth provides as a moving target for the Commission's policy statement.
APPLICABILITY OF RULES AND GUIDES TO ELECTRONIC MEDIA
1. Does the Commission's proposal to clarify the applicability of its rules and guides to electronic media provide adequate guidance to industry and to the public?
The IA would like the Commission to clarify how its expects to address the applicability of its rules and guides in light of the discussion above about client/server architecture by Ms. Cady. We reiterate that in many cases the content provider or advertiser cannot control the manner in which the representation is displayed on the end user's screen. Again, font sizes and types, as well as screen size itself, are often under the control of the user. The IA notes that this is a positive characteristic of the medium and of the technology (e.g. many operating systems allow visually or hearing impaired individuals to enlarge screen and font sizes). The IA would like to work with the Commission to address this issue.
In addition, the IA notes that the fundamental design of the World Wide Web (i.e. a hierarchy of cascading Web pages) may be considered in satisfying the intent of the consumer protection rules. Web page designers structure their Web pages by inserting hyperlinks into each page. Often, an introductory paragraph, sentence or phrase will be followed by a hyperlink to more information about that topic. End user preferences, not Web page designers, have dictated this Web page format. The World Wide Web is a highly competitive market consisting of millions of Web pages with many more appearing every day. The competition for viewership requires that designers pay very close attention to consumers' viewing preferences. Screen real estate is a premium on the Web. Designers must maximize the variety of information they can initially present consumers to pique their interests. The current industry standard of hyperlinking to further information has been honed by the marketplace. If a designer fails to follow these consumer-dictated rules -- or if they are forced to substitute regulatory requirements for consumer preferences -- they will likely not survive in this marketplace.
The IA does not believe that the Commission should require content providers or advertisers to display all the pertinent text on one single page. Users on the Internet are accustomed to clicking on links to find more relevant information about a issue or product. The focus of this consumer protection inquiry must be whether there is consumer comprehension of the online representations and disclosures. Screen real estate is at a premium and content providers should be allowed to structure it according to online users' customs and habits -- especially in light of fact that users maintain a high degree of control over their own display.
2. What are the costs and benefits to consumers of the Commission's proposed policy regarding the applicability of its rules and guides to electronic media?
The Commission's proposed policy could result in significant costs being passed onto the consumer. In addition, such rules, if not carefully contemplated, could seriously hinder the growth of the medium itself.
First, online consumers pay Internet and online access providers for bandwidth. With the current state of the nation's telecommunications infrastructure, consumer bandwidth is a precious resource. Many factors contribute to bandwidth scarcity. Many times congestion at crucial access points along the network will slow down response time. Also, a particular server may delay its response to a particular client because of an overwhelming number of other requests for information pending. Many solutions to bandwidth scarcity are being deployed. However, Internet and online content providers must still carefully calculate the time consumers will be required to spend accessing their products or services.
In its Notice, the Commission indicates that online advertisements should be subject to the same rules as the print advertisements. Those rules, if applied strictly, may require that online advertisements be much larger (both in image size and in screen size) than they are at present. The IA notes that most content providers and Web page designers take special care to ensure that advertisement images are no larger than necessary. If the images are too large (either by square inch or by pixel per inch or resolution) the advertisement, as well as the Web page itself, will take a significant time to access. For consumers paying for access by the hour, this will translate into higher costs. For consumers paying for access at an unlimited, flat rate, the higher image size will make the online experience tedious and slow. At present, many Web-based services are funded by online advertising revenues. However, if those advertisements are too large to make the Web site easy to access, many Web sites will move to a fee-based service and consumers will be forced to pay. Worse yet, consumers may simply loose interest in this exciting new medium altogether.
INTERPRETATION OF TERMS
4. Do the Commission's proposed interpretations of the terms "written," "writing," "printed," and "direct mail" provide adequate guidance to the public?
The IA strongly believes that the terms "written," "writing," and "printed" cannot be easily applied to the Internet and online environment. In its comments, the Commission suggests that the rules and regulations which apply to those terms will apply to representations online if consumers can “read the information and preserve it for possible later review either by printing it on paper, saving it on disk, or by some other means.” The act of printing the online material on a piece of paper changes the medium in which the advertisement was intended to be seen. Once printed, the advertisement loses its interactive qualities, negating the possibility of user inquiry.
Similarly, once saved to disc, the Web page or advertisement often loses its interactive qualities. For example, an online banner advertisement image can easily be saved to disc (by "right clicking" on the image in Windows95 or by holding down the mouse click button in Macintosh OS). However, once on disc, that advertisement will no longer be hyper-linked to the Web location where the consumer would expect to find more information about the advertisement. Also, often, these banners ads are GIF animation images which consist of several rotating images -- each revealing more information than the image before it. Current browser technology makes the images rotate. However, once on disc, many consumers use other non-browser applications to view these images which may not allow the image to rotate or animate. Rather, the consumer will only see the first of several images intended to be seen online. (The same argument applies to Java and ActiveX applications.) Web pages also lose much of their interactive qualities once saved to disc. The links on a Web page often work only if the Web page file is viewed on the host's server. For instance, the Web page may reference another file in the same directory on that host Web server. However, once the source text of the Web page is saved to the user's computer, the link to the file on the host server is lost, thus erasing the Web page's interactive quality.
In most cases, the act of saving to disc or printing these images on paper eviscerates the interactive properties of the representations which consumers expect when online. Other technologies such as Java or ActiveX applets and PointCast transmissions are intended to be viewed online. The interactive properties of the Internet make the medium unique and the Commission's policy statement should seek to preserve them. Therefore, the IA recommends that the Commission consider the medium in which the representation was intended to be seen when formulating its policy positions. The saved or printed representation should not be the baseline upon which those representations are judged.
8. Does the Commission's discussion of "direct mail" adequately address the various new means of electronic communication, e.g., e-mail, facsimiles or list servers, and adequately account for the differences inherent in these various formats? What are the costs and benefits of advising against their use?
Internet email and traditional postal mail are similar in that they can be addressed to individuals privately. However, the properties of Internet email prevent the Commission from applying all the rules and regulations governing “direct mail” to Internet email. Internet email differs from postal mail in that email allows recipients to easily and quickly make further inquiries about a solicitation. Such inquiries to the email sender can be easily and instantaneously initiated by hitting the “reply” button. This interactivity allows consumers to obtain more information about the product or service referenced in the email. The technology allows Internet email to disclose more information to the recipient as well as more opportunities for the recipient to seek out more information than postal mail provides. Many email clients automatically hyperlink URLs contained in the body of the email message -- making the email truly interactive. Some email clients not only hyperlink URLs but also display images and more complex HTML formatting within the body of the message. Further, the U.S. Congress has distinguished Internet email and postal mail through the Electronic Communications Privacy Act of 1986 (ECPA). For the above reasons, direct mail via the postal routes and email via the Internet should not be viewed as synonymous for regulatory purposes.
10. Should Web page or banner advertisements that are targeted to certain consumers on consumer preference information be characterized as "direct mail"? If so, are such advertisements adequately addressed by the Commission's proposed interpretation?
While targeted Web-based banner ads are similar to direct mail advertisements in many respects, the interactivity of the medium negates easy application of the direct mail consumer protection rules to banner ads. The Web affords users to easily and instantaneously seek more information about the product in a manner which is customary on the Web -- by clicking the ad.
In addition, banner ads should not be compared to direct mail. Banner ads are more closely compared to ads running on a cable station: one that is targeted to people in specific geographical locations. Often, these cable ads are targeted to specific types of programming (e.g. sports, comedy, sci-fi). Another analogy is the targeted ads in printed magazines. TIME and Newsweek, for instance, sell different versions of their weekly magazine to individuals located in different geographical locations and depending upon whether the subscription is commercial, residential or off the rack. Not only are the ads in these magazines different based upon the above factors, but the stories themselves are tailored to different demographics. However, just like banner ads, these different magazine versions are not necessarily “individually addressed.” They are not targeted at the individual. Rather, they are targeted at an anonymous set of criteria (search term, zip code). Therefore, the Commission should not consider banners ads to be synonymous with direct mail.
Revenues from Web-based banner ads subsidize consumers' access to many products and services on the Internet. The IA believes that the Commission should take care to apply the consumer protection rules in a manner which does not threaten this important source of revenue.
11. What issues, if any, need to be addressed by the Commission regarding the use of electronic media to deliver information required to be provided in writing by a rule or guide? a. How should the Commission address those issues? b. Under what circumstances, if any, should the Commission advise that information be provided on paper and not electronically?
To the extent that the Commission requires Internet and online providers of services and products to provide subsequent information to consumers, it should ensure that those communications are consistent with the nature and use of the online environment. The Commission notes that there may be cases where the use of electronic media may satisfy affirmative requirements under the rules and guides (e.g. using email to send an octane fuel rating). The IA believes that this interpretation would make compliance with those obligations mush more efficient. Inversely, if the Commission were to require online businesses to comply with affirmative requirements (whether existing or future requirements) by sending paper, such efficiencies would be lost.
There are many instances where value added information may be provided on paper but those determinations should be made by the provider. Consumers, while online, expect to interact with companies electronically. Further, many online businesses have carefully made business projections based on their ability to reduce costs by communicating with customers electronically. Forcing these companies to provide information to their customers on paper will increase costs (administrative and raw paper/postal costs) thus eviscerating the benefits to consumers.
The Reasonable Consumer -- The IA would like to first respond to the Commission's comments regarding the "The Perspective of the Reasonable Consumer" (63 Fed. Reg. 24996, II(C)(6)). The Commission states that its consumer protection rules will be evaluated in relation to the "reasonable consumer" standard. We believe that it is important for the Commission to acknowledge that consumers have different expectations of disclosure online than offline (e.g. print, television, radio).
The difference in expectations is a direct result of the nature of the medium itself. When consumers read print advertisements in paper publications (e.g. magazines, newspapers, direct mail pieces, billboards, product labels etc), they have absolutely no expectation that they will be able to extract any more information from that particular source. Like the printed page, the television screen and radio speaker are passive devices unable to respond to further consumer inquiry for more information.
The online environment, the World Wide Web in particular, is anything but passive. In fact, the power of the medium is that consumers can seek out the information they want and request information that is of interest to them. The U.S. Supreme Court cited the interactive nature of the medium as a basis for overturning the Communications Decency Act. The Court astutely noted that rules and regulations, appropriate when applied to other media, fail to meet their designed objectives when applied to the Internet: “Unlike communications received by radio or television, "the receipt of information on the Internet requires a series of affirmative steps more deliberate and directed than merely turning a dial.'"(Reno v. ACLU 117 S. Ct. 2329 1997).
For the above reasons, the IA believes that Commission must approach any policy statement in this area from perspective of the “reasonable online consumer.” Any application of current consumer protection rules and regulations must contemplate the inherent nature of the user's online expectations and experience, as well as the fundamental differences between the traditional passive forms of media (e.g. print, television, radio) and the Internet online environment.
17. Are the Commission's underlying assumptions about consumers' perceptions with respect to Internet and other electronic media advertisements accurate?
As mentioned in the above discussion about the “reasonable consumer,” the IA believes that users expect a different level of immediate disclosure while online. The inherent nature of the online environment requires users to take affirmative steps to find out more information about a given topic. While the medium requires that users seek out information, the technology provides a virtual bread crumb trail to find their way back to their point of origin. Tim Berners-Lee, the “father” of the World Wide Web, created the Web because, admittedly, his brain was not up to the task of remembering trails of random associations and he wanted a network which would remember his movements and travels through it (See http://www.w3.org/People/Berners-Lee/FAQ.html). Online consumers understand this and, therefore, their expectations are very different than their expectations in the “offline” world.
13. Do the proposed factors for evaluating disclosures provide adequate guidance to industry regarding making disclosures in electronic media?
The IA feels that the factor delineated by the Commission deserves individual attention:
A. Unavoidability -- The IA believes that the Commission's proposed definition of “unavoidable” does not adequately take into account consumers' online expectations. As stated before, online consumers expect to take affirmative steps to get the information they wish. In Reno v. ACLU, the U.S. Supreme Court rightly concluded that this affirmative step-taking process is fundamental to the medium and sets it apart from other mediums. The act of scrolling or clicking does not present the same problems which the “unavoidable” consumer protection rules were designed to address in the offline world.
The IA notes that the industry has struggled with making certain disclosures “unavoidable” (e.g. terms of service). However, such unavoidability is very difficult because there seems to be no way to prevent a user from bypassing a Web page with a certain disclosure. For instance, if the IA placed a certain disclosure on its main page <www.internetalliance.org> and a user went directly to <www.internetalliance.org/policy/> the user would not see the disclosure. This type direct access allows users to quickly access the information they want and only that information. The Commission should consider this as it develops its policy.
The technology itself makes the Commission's proposed “unavoidable” definition difficult as well. There are several types of Web browsers and each one may display HTML code differently. In addition, users can configure their browsers to actually display Web pages differently. For example, users can adjust the size and the type of the proportional fonts and the fixed fonts. Larger fonts (e.g. Courier is a much larger font than Times New Roman) and larger font sizes will often make a Web page larger than the designer had intended -- thus necessitating scrolling. While HTML standards allow programmers to specify the font size and font type the given page should be viewed in (e.g. <FONT SIZE="1" FACE="Arial">), such code instructions only work if the user's computer possesses the required font. Also, differences in screen sizes make the scrolling determination suspect. The customizable nature of Web browsers ensures that not all users will view a given page as intended by the programmer. Further, a rule by the Commission requiring that disclosures appear a certain way will be difficult to execute on the Web. This personal user configuration is not only routine, it is central to interactive services.
B. Access to Disclosures -- Again, online consumers do not expect that disclosures should be visible at all times during the communication. User expect to “click” for information. In addition, the technology allows users to easily and quickly return to such disclosures (i.e. the user can return by clicking the back button or by using the “History” or “Go” command).
22. Are there other issues the that the Commission should address in clarifying the applicability of its rules and guides to electronic media?
The IA is concerned about the applicability of the Commission's rules and guides in non-domestic venues. A common jurisdictional problem when dealing with the Internet is that it is a medium which is by definition international. The Internet respects no borders. A user in Sydney, Australia can just as easily access the Web site of L.L. Bean in Maine as someone in Freeport, Maine.
The IA would like to work with the Commission to develop an appropriate policy for how it asserts its jurisdiction under this proposed policy statement in international venues. The IA notes that consumer protection rules vary from country to country. For example, in some countries competitive advertising is forbidden while in the U.S. it is perceived as desirable.
Most of the online e-commerce is being conducted by businesses in the U.S. If foreign countries were to apply their consumer protection rules to these U.S.-based businesses, it would seriously hurt the growth of e-commerce in this country. The IA would like to avoid any perceived provocation by the application of the Commission's consumer protection rules to the international Internet environment. The resultant complications of the European Union's Data Protection Directive illustrates our desire to avoid assertions of foreign jurisdiction over U.S.-based businesses.
The IA suggests that the Commission clarify that the consumer protection rules, as applied to the electronic media, are primarily intended for domestic cases. The Commission could note that this statement in no way abdicates its authority extend its jurisdiction to non-domestic businesses engaging in unfair and deceptive practices but such an extension will be made with international cooperation.
Again, the IA welcomes the opportunity to submit these comments to the Commission on this important issue. I realize that this document raises more questions than it answers but this is ultimately due to the fluid nature of the medium and the electronic marketplace. We look forward to working with the Commission in the future. If you have any questions regarding these comments please do not hesitate to contact me via email at <email@example.com> or by phone at (301) 495-4955.
Internet Communication and Electronic Commerce
Written for the Internet Alliance's reply comments to the FTC "Interpretation of Rules and Guides for Electronic Media Request for Comment".
Glee Harrah Cady
The principle advantages presented by the Internet are that the many tools available enable many different types of communication and that many of those tools are interactive. Messages are not restricted to one particular form of communication at a time. Combinations of tools can be used to provide a communication experience that rivals that of in-person communications and the experience can conquer distance. Email and the World Wide Web are the tools most frequently used for electronic commerce but they are not the only ones. Essentially, if there is a communication method, people will use it to try to sell something to one another.
Client and Server Program Architecture
Most, but not all, of the communication modes rely on text. In the cases where text is used, the choice of font size and background color, etc., usually may be controlled by the user through options set through the client program interface. Newer versions of webpage design languages give the designer greater control of information placement and display, but much remains at the preference of the user.
The view of information depends upon the kind and size of display screen and variations in installed software like type font collections. A person using an early IBM Personal Computer without color or graphical display capability may use the Internet. However, that person will have a significantly different experience than someone using the latest computer from The Apple Computer Corporation or the newest of IBM's ThinkPad ™ lightweight laptop computers. That early IBM computer may work really well, though, for the user who depends on a text-reading software program because he or she is blind.
The distinction between client programs and server programs is important for understanding Internet communications. A client program is usually responsible for
Server programs interact with the commands given to them by approved clients without knowledge of anything other than the commands issued. Clients and servers are connected by the network infrastructure which is built and maintained by the Online/Internet service providers. As providers, these services try to make the maximum amount of information and information about how to find information available to their users.
The interaction of client and server programs is both a strength and a weakness in Internet communications. The strength comes from the architecture's ability to meet many needs. Client programs have been developed for many different kinds of computers and thus many older models of computers are still useful. The information designer need not design for all the individual combinations of preferences and equipment that can be used. The weakness comes from the designer's inability to completely control the presentation and display of the information to the user. Communications that seem clear in one environment may be less clear in another.
Building on earlier work by Rob Raisch and Daniel Dern, Pat McGregor and Glee
Cady developed a taxonomy of Internet communication modes. Their taxonomy attempts to
account for the many ways people can send and receive communications using the Internet,
as well as the important additional concepts of temporality, public versus private
communication, and the authoritativeness (trustworthiness) of the information received.
The matrix is displayed in Table 1.
Table 1: Internet Communication Modes
Note: One omission from the tools placed in the box above is Telnet. Telnet is a program running on a local computer connected to the Internet that connects the user to another (called remote) computer (also on the Internet) and allows the user to issue commands directly on the remote computer. Telnet is really more like the cable connecting your computer's keyboard to the remainder of the computer than it is a type of communication. Telnet is frequently used to connect a user to a MUD, for example.
TYPE I INTERNET COMMUNICATIONS.
Type I Internet communications include Email, email auto-responses, FTP, files displayed by Finger, private World-Wide Web pages, and Talk.
Email. The most common of the communication methods used by people on the Internet is the private email, written by one individual to another, and sent between any two connected Internet sites or through an Internet email gateway to or from a service which provides an Internet gateway. Receiving email is similar to having a box at your local U.S. Post Office. You must go to the post office (by connecting your email client program to your mail server) and collect your email before you can read it. Email is sent to addresses that represent particular mailboxes. Specific knowledge about a recipient is not available to the sender, unless both the sender and the recipient are known to one another by virtue of their having met. Email is considered private and is protected in the US by the Electronic Communications Privacy Act.
In electronic commerce, email can be used to
Email is frequently used in conjunction with other Internet communications to complete commercial transactions. A solicitation may be made using any of the four types of communication. Completion of the transaction may be moved to private one to one email when subsequent communications between vendor and purchasers are needed. An email client program usually has options with which the user may control size and color of font. The client may allow the sending and receipt of digital “attachments” which may contain sound and video. Some clients may allow direct use of hyperlinks to display a webpage whose address is imbedded in the text. Some clients and servers do not allow for other than the sending and receipt of Roman alphabet text. Some clients require users to be connected to the Internet while they are being used; others may be used “offline”.
One critical difference in email clients is that some clients do not permit easily the display of email header information. Header information can be used to determine through which server the message was sent. Such information can be helpful in tracing fraudulent messages to their senders.
A special case of private email is that of encrypted messages. These are messages that have been mathematically changed to disguise their contents. This makes the transmission more secure. Only the sender and the receiver can see the message in an intelligible form.
The email equivalent of the direct response postal card is the prepared email auto-response. The message is a composed one, especially prepared as an automatic answer to any email that gets sent to that address. As an example, if you were to send a message to an address such as firstname.lastname@example.org, a message might be automatically returned acknowledging the receipt of your email.
FTP. FTP is an Internet tool that copies a file from one Internet site to another. FTP stands for both file transfer protocol and file transfer program, the specific program that implements the transfer. With the Internet address or domain name of a site, you can use FTP to connect to a specific location on that site (specific directory path and file name) and copy a file containing information to or from your computer for your own use. This activity is individual and private, although many FTP sites log (or register) file copy transactions either for market research or as security precautions.
A more secure version of FTP is available which makes sure that no one could access this information without permission. This kind of FTP requires an account and password before allowing access to the server or specific file or directory. Many Online/internet service providers specifically require (in their terms and conditions of use) that accounts and passwords not be shared with others.
In commercial transactions, the files that are transferred using FTP might be product descriptions or the product itself: a sound recording or a digital image or a computer program. The user would be required to use an appropriate application program to open and display or operate on the digital information contained in the file. Transfers of data in this way would most likely be started by either an email solicitation or by a user responding to a webpage.
Finger. By using a command called Finger, a user can view the contents of a file associated with a particular user ID at a particular Internet site. The Finger command will usually return information about whether that user ID is being used at that moment, and whether the user has mail waiting to be read. Lastly, it will display the contents of a file containing any textual information that the file owner wishes. Some people use this file to convey personal information about themselves. Finger would be an unlikely tool for commercial transactions.
Talk. Email, FTP, and Finger are asynchronous. That is, the two communicating parties need not be connected to the Internet at the same time in order to exchange information. The synchronous or interactive text equivalent to email is called Talk in the Unix environment and “Instant Messaging” or “Buddy lists” in other environments. The Talk program enables private communication between two individuals. The individuals can be connected through any two Internet sites with talk servers. Talk is simultaneous: it does require that both parties be connected at the same time. “Conversations”, or Talk sessions, may be initiated by any party with a request. The recipient of the request may accept the invitation and begin a conversation or reject the invitation simply by not responding to it. “Instant messages” usually are implemented by the two users being connected to the same server. Otherwise, the characteristics of the two communications are the same. They are ephemeral. No effective monitoring of these tools is possible. One potential commercial use for this communication method would be to provide customer services – using this method to respond to more immediate queries than could be handled by email.
Internet Voice and Video "phone" Services.
Today, voice and video communications can be transmitted via the Internet with varying degrees of satisfaction. Some voice services are indistinguishable from regular voice telephone services. These products usually require dialing from a telephone to an access number, entering a PIN number, and then entering the telephone number of the recipient of the call. The users will be unaware that the call is made using the Internet as a transmission medium except for the difference in access procedures. These calls do not require the callers to use their own computers to place and receive calls.
Other voice and video products require callers to be connected to the Internet. Certain of the services will work on relatively low-speed Internet connections and provide a relatively simple method for someone with inexpensive camera and sound equipment to send and receive voice and image. Some “video” phone services require a “reflector” server. These are not really private as anyone connected to the reflector can receive the transmission. Many of the simpler voice and video services require only a program running on each end of the connection to provide private, synchronous conversation. These communications are ephemeral and no effective monitoring is possible. It seems likely that these services are being used to deliver privately-produced video and voice products, particularly “adult” materials.
TYPE II INTERNET COMMUNICATIONS.
Type II Internet Communications include the very public communications that take place on unmoderated mailing lists or within unmoderated newsgroups. These communications come from many contributors and are distributed to many recipients.
Mailing lists. Mailing lists are simply a formal application using email -- easily copying a single mail message to many potentially interested persons, using email as the transmission medium. As such, this type of communication is non-simultaneous. A mailing list is a list of email addresses utilizing a single email address maintained by a mailing list agent program (sometimes called a list server). The sender enters the email address of the list as the recipient's address when composing a message. A message sent to a mailing list is re-sent to each email address on the list. Many of the mailing lists (groups of people who wish to receive the same information) are unmoderated and open. This means that you are welcome to join (or subscribe to) a list and to post your contributions to the list. You may also unsubscribe at will. Therefore, the people who read the list will vary widely from time to time. Mailing lists would be suitable technically for communicating a commercial message to a large group of people interested in a single topic. In fact, mailing lists are a great way to communicate with customers. However, many specific topic based mailing lists have prohibitions against commercial messages. People who ignore this prohibition are asked or forced to leave the group. Sending a single commercial message to a large list of email addresses in the same transaction is not a mailing list. That is called “SPAM” and is forbidden by the Terms and Conditions of most Internet/Online service providers.
Newsgroups. After email, Net News is the single largest information-sharing mechanism on the Internet. Net News or Usenet News or News are all names for the same concept: the broadcast of posted messages to a newsgroup. Net News is asynchronous, one-to-many communication -- in other words, someone makes an article or message available, and anyone who is interested can read it whenever they like. News covers every conceivable category, and any user can start a new group. It's rather like a global cocktail party where anyone can attend and say almost anything. There is no effective way of developing or enforcing rules other than by group decision.
Some newsgroups get hundreds of messages per day; some, only a few. Specific articles generally persist on news-servers for a specified, programmed amount of time. This is called expiration. Each Online/internet service provider will set its own parameters for article expiration. The goal is to balance the ability of the user community to access the material with the amount of disk space and computing resources needed to store, locate, and retrieve the requested article. A common algorithm is to keep text-based articles for 10 to 12 days and to store highly graphic material (which requires much larger amounts of storage) for two to three days. In general, messages in the newsgroups are text and the user chooses a particular type font in which to display them.
A News item looks much like an email message; it has headers and a body of text. But News items are stored and handled by a different set of programs, and there are specialized newsreaders -- programs to let the user more easily handle the volume of news available. Newsreaders let you select what you want to read, discard what you don't want (or filter it out altogether before you even see it), and keep items in a single discussion or thread together.
There are over 22,000 newsgroups worldwide as of early 1998. New ones are added each day. The groups are arranged in hierarchies and subhierarchies roughly according to subject. The range of subjects in the groups reflects the diversity of the Internet community. A newsgroup is similar to a BBS or bulletin board system but one that has been copied to thousands of computers throughout the world. People read a newsgroup on some local site and post their contributions to that local site. The contributions are then copied automatically according to a prearranged software pattern to the other sites which carry that particular newsgroup. Like unmoderated mailing lists, unmoderated newsgroups may be read and contributed to by anyone who can receive the newsgroup. There are thousands of servers involved in the Usenet chain.
Newsgroups are transmitted automatically. The messages are copied to each computer that runs a news server and that accepts and transmits postings for particular groups. Net News is cooperative and no site is required to accept the news feed for each and every newsgroup. Because each message is copied as part of a batch of messages, the communication is not simultaneous. Postings may reach some of the other computers carrying the newsgroup in seconds. The same postings may take several days to reach all the sites that carry a particular group.
Newsgroups are generally not suited to commercial transactions other than “For Sale by Owner” kinds of transactions. Newsgroups that are read by a large body of people usually have prohibitions against commercial messages. However, newsgroups that are devoted to the products of particular manufacturers or to classes of products designed to fit specific needs may well welcome new product and service announcements. The charter of the newsgroup will generally state if (and under what conditions) commercial messages are accepted. Posting a single commercial message to a large number of newsgroups is called “SPAM” and is usually prohibited by the Terms and Conditions of Internet/Online service providers.
Chat. Chat is a text-based, simultaneous communication method. Two or more people connect their chat client software to a single server, choosing a “room” in which they will communicate. Each “chatter's” words are seen by all the people connected to the chat room at that time. Generally these communications are ephemeral, but chats with celebrities, for example, may be archived and sent to the participants or to other interested parties at a later time. The client software may be proprietary – that is to connect to a specific server you need specific client software – or you may use any client to connect to other chat servers. Some chat servers are used to build and support online communities. These servers may carry advertising on them. The shape, content, and form of the advertising would be controlled by the chat server. Again client programs may give more or less control to the user of the client program. Generally, the font and background colors would be among the options that may be set with the client. Some chat servers/clients are able to support private conversations. The transcripts of these conversations are not seen by other connections to the chat server.
Internet Relay Chat. IRC, which stands for Internet Relay Chat, can best be compared to a text-based CB (Citizen's Band) Radio. Once you are connected to an IRC server, you elect to join a channel--the name given to each "conversation”. A channel is like a chat room. Like in chat in IRC, each participant's contributions are displayed on the screens of all the others taking part in a conversation.
In IRC, you can join an existing conversation or try to start one of your own. The topics being discussed will be as varied as the people participating. When you join, your name (or more likely your nickname) will be announced to others on that channel. Therefore, while you can be anonymous (by using a nickname that will hide your real identity) you cannot read without being seen (called "lurking") as you can in mailing lists and newsgroups. Others will know that another person is there watching and listening.
IRC is definitely individual and simultaneous. There can be few or many participants at any given time.
Internet Relay Chat works as a client/server application, and the IRC servers are interconnected to form, from the user's perspective, one large service. Each IRC user instructs a client to connect to at least one IRC server, preferably a server nearby to minimize network delays and inefficiencies. Any user, in any location, can join all other users in any of these discussion "channels".
MUDs and MUSEs. MUDs (Multi-User Dungeons) and MUSEs (Multi-User Simulation Environments) are shared worlds in which the user can communicate with others who are simultaneously taking part. The difference between MUDs and MUSEs and chats is not in the number and type of participants, nor in the general technology used. It's that MUDs and MUSEs postulate rules and environments that are shared. The environments may be imaginary or not. You may participate as yourself or as a character you construct (by your own rules or by the rules of the world you wish to share). In these shared worlds, the characters you construct walk around and converse with other characters created by other participants. Most of the shared worlds are intended for recreational use, but some are educational. Some corporations and think tanks use this technology to have multi-level discussions not bounded by physical location or time zones. And some of the shared environments have been running for years (although not with exactly the same participants, of course). In some cases, the user interacts with a shared environment using a client; in others, the user connects to the shared environment using Telnet to a specific host computer. It is possible to log interactions in some shared environments on either the client or the server end (once again depending upon the architecture of the programs).
TYPE III INTERNET COMMUNICATIONS.
Type III Internet Communications are public and allow many users to communicate with many other users. They include mailing lists and newsgroups that are moderated. Moderation is not intended to make the postings more or less authoritative, but to make sure the postings stick to the topic. The moderator may be the person who started the mailing list or newsgroup, or it may be someone selected later. The duties of the moderator vary according to the available software and the nature of the group. Since only mailing lists and newsgroups are moderated, this type of communication, like all unmoderated mailing lists and newsgroups, is non-simultaneous.
A key feature of this type of communication is that some person decides what is appropriate to transmit to the group of readers. A moderated newsgroup means that the newsgroup postings are controlled, not that the readership is controlled. Reading news articles is controlled at the individual newsreader client level and subscribers are not known to the moderator. Some moderated newsgroups and mailing lists may be supported by advertising. As has been said before, the newsreader and email client software can be configured by the user.
TYPE IV INTERNET COMMUNICATIONS.
Type IV Internet Communications are the public, published contributions of individuals and companies that can be received by many recipients, and that may be thought of as authoritative. Some authority has exercised editorial control over the content. The content represents an official statement, information about a product or a service, editorial or procedural matters, art work, catalogs, calendars for schools, colleges or universities. In short, these are published works intended for general or specific consumption, using all the tools of the Internet for the communication medium.
There is only one type of communication in this category that is truly simultaneous: the broadcast message that is used by a system or network operator to communicate about the state of the network or system itself with everyone currently using it. Broadcast messages are sent from an operator to every person using a system at that time. Broadcast messages are usually warnings about unusual activities such as system instabilities or outages. They are transmitted this way to reach the maximum number of affected people as quickly as possible. In general, these messages would not be commercial.
The World Wide Web. The World Wide Web is a distributed, hypertext collection of clients and servers that link a page to other pages throughout the global Internet. A page is a title, a collection of information, and pointers (hyperlinks) to other information. A page may be of any length. You view it using a client program which connects you to a server. Depending on the client you have, you can see color representations of lighthouses and other art work, hear audio clips from recorded music, see movie clips, or fill out survey forms. Page designers publish their pages, leaving the viewer to decide whether or not to view them at some subsequent time.
Viewing in this context means to display with text and graphic images, possibly including sound and video, limited only by the capabilities of the client software and the computer upon which the client is running. Increasing levels of sophistication in technological development within client/server software allow for animated processes to be automatically executed. Thus, once the has selected a particular page in a Web site, information on that page can cause additional pages to display. Interactions between client and server programs may make changes and store information on either the computer being used by the client program or on the server computer. One term for information stored on the client computer is “cookies”. “Cookies” are used to maintain state between transmissions because each Web interaction is complete in itself and the server doesn't know it has interacted with a particular client previously. “Forms” and email are both used to collect information from a webpage user. The term forms is used to describe the process of displaying spaces on a page into which the viewer enters data. The data is then sent to a program which processes and acts upon the data (an order, for example) and perhaps stores the data or it may be sent via email to another computer program which processes the data.
In making information available for access via the Web, an information server is created. It will "serve" (or send) information over the Internet to anyone who has a client program that can request it (and who also has appropriate security permissions, of course). In theory, this means that to implement a successful webpage, all the commands, programs, computers, and connections the user will rely on to seek and display the information doesn't need to be known by the designer. That is taken care of by the client software.
As is true of many useful ideas, not knowing the exact combination of computer, browser program, screen display, and type of connection that all users may have will both simplify and complicate the webpage designer's task. The designer always must consider that complete control of the display of the message on the user's computer is not possible.
Not all clients are created equally. A presentation may work really well in Lynx, but not in the AOL browser designed for the Macintosh (two very different WWW clients). Then the presentation needs to be modified until it is acceptable using both clients. The Web site BrowserCapsTM (http://www.browsercaps.com) is a service for webdesigners who want their information to be available to the widest audience. The webpage http://www.browsercaps.com/config/Cv/Generated/resultsbyname.html lists the capabilities of the various tested browsers. Some older clients do not support forms. Others don't support framing. Some Internet Web surfers move quickly to newer versions of browser software. Others remain with very old versions because they prefer them, because they are unaware of newer versions, or because they fear the download and installation process required to obtain the newer versions.
Besides the variations in the software itself, the user may choose options that will make the display of the same webpage appear differently from the display of that same page by another user. The user may choose font, sometimes background color, as well as the colors of links already visited or not yet taken. Newer versions of browser clients give the designer more control over the background color and fonts.
Gopher. Gopher is a menu-driven client/server program that allows the user to connect to a file, transfer a copy of a file and display it. Gopher links to and displays menus and files from other Gopher servers throughout "gopherspace”, making it unnecessary to gather all the information needed and place it on a single server. Despite its ease of use, gopher has become less popular than the Web because it did not allow for simultaneous display of graphics, sound, and text on the same screen. Since the primary operators of gopher servers were academic institutions and because the information flow was essentially one-way, gopher was not generally used for commercial transactions. Gopher could be used for making commercial offers. Accepting such offers would need to transfer the communication to email or some other two-way communication method.
Anonymous FTP. Another type of non-simultaneous, published communication information files placed for anonymous FTP. These files, like those in Web pages and in gopherspace, are prepared specifically for the convenience of others. The requester explicitly asks for it, so there is no question that it was wanted. In this type of interaction, the request is most likely logged at the server, but there is only the address of the file transfer's recipient. The Web is a much easier to use tool for commerce than Anonymous FTP, but it would be possible to use files as if they were billboards, again transferring the completion of any transaction to a more interactive medium such as email.
Databases. A more specific kind of published information can be provided with databases and search engines. Many databases on the Internet, including library catalogs, archives of articles, and books on line, have their own specific interface. Database interfaces, or search programs, are called search engines.
Using one of the other Internet tools (such as a Web browser) or using a specific client tailored for that database, specifically requested information can be published. Database publishing allows the user to access indexes to materials, making sure that the user gets what he or she wants more quickly, with fewer false starts.