Comment Number:	539814-00005
Received:	1/6/2009 5:22:15 PM
Organization:
Commenter:	Kevin Lowe
State:	IN
Agency:	Federal Trade Commission
Rule:	FTC Town Hall to Address Digital Rights Management Technologies - Event Takes Place Wednesday, March 25, 2009, in Seattle
Attachments:

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Comments:

Take a look at the recent outage of the TAGES DRM system for an example of how DRM can unintentionally harm consumers. DRM systems need to be built from the start to fail-open after a reasonable period of time, and should come with a minimum guaranteed service level such that consumers aren't left with software they can't use because the authentication servers are down, either temporarily or permanently. Placing unrestricted copies in escrow, while not ideal, would be an acceptable alternative.