Proposed Consent Agreement: In the Matter of Sears Holdings Management Corporation, FTC File No. 082 3099 #542583-00006

Submission Number:
542583-00006
Commenter:
Alan Raul
Organization:
Sidley Austin LLP
State:
DC
Initiative Name:
Proposed Consent Agreement: In the Matter of Sears Holdings Management Corporation, FTC File No. 082 3099

Dear Chairman, Commissioners and Staff: Please accept the attached article, "End of the Notice Paradigm?: FTC's Proposed Sears Settlement Casts Doubt On the Sufficiency of Disclosures in Privacy Policies and User Agreements," published today in BNA's Ecommerce Law Daily, as a comment on the Commission's proposed settlement in the Sears matter. Thank you for your kind attention. Respectfully, Alan Raul Alan Charles Raul Sidley Austin LLP 202-736-8477 (tel.) 202-736-8711 (fax) 202-403-7068 (portable) araul@sidley.com1501 K Street, NW Washington, D.C. 20005 http://www.sidley.com/infolaw