This is to offer my submission to the Request for Comments (RFC) organized by the FTC as part of its Spring Privacy Series on Mobile Device Tracking (Project No. P145401). I applaud the leadership as well as the thoughtful consideration I am certain the FTC will give to some of the key challenges to privacy and data protection posed by the growing use of Mobile Location Analytics (MLA). The RFC asks for input on how companies can implement the principles of Privacy by Design while designing and using MLA technologies. I attach "Building Privacy into Mobile Location Analytics (MLA) Through Privacy by Design" which examines the application of Privacy by Design to the design and architecture of MLA systems through the work of Toronto-based MLA company Aislelabs. I hope this paper will be useful as the FTC furthers its review of this growing technology.