Submission Number: 00013
Received: 2/1/2012 1:32:24 PM
Commenter: Gilit Roshan
Organization: Classical Silk Inc.
Agency: Federal Trade Commission
Initiative: 16 CFR Part 303: Rules and Regulations Under the Textile Fiber Products Identification Act; Project No. P948404
Attachments: No Attachments
My company regularly uses the RN database in order to identify infringers that steal our copyrights for use on knock-off apparel. Often the only way to track down an infringer is through the RN number on the necktag. However, the FTC's online RN database is often inadequate because it seems that there is no penalty or deterrent when someone adopts, without authorization, another company's RN number. It would be beneficial to the public, and reduce fraud, if the RN system had an expiration date or required maintenance date such that a company has to renew its RN number every few years. This will also ensure that company addresses are regularly updated.
In addition, the FTC should include in its RN Lookup database all the fields that must be filled out when a company applies for an RN number. We request that the RN Lookup include the following information, all of which is already part of the application template, but (for no reason) not included in the Lookup database: (a) date of application; (b) name of person submitting and certifying the application; (c) title of that person; (d) that person's email address; and (e) the website URL address. The date of the application is important since it provides a clue into how long the infringer has been operating. The name and title of the person is important because it is often difficult to determine who is actually behind a textile infringement. The email and website are important because many of these infringers can be difficult to locate except via their online stores (the mailing address is often stale or merely a drop box).