March 5, 1999

Donald Clark
Office of the Secretary
Federal Trade Commission
6th Street & Pennsylvania Avenue NW
Washington, DC 20580

RE: Complaint filed by the Center for Democracy and Technology, Consumer Action, Privacy Rights Clearinghouse, and Private Citizen, Inc. in the matter of Intel Pentium III Processor Serial Number

Dear Secretary Clark:

As organizations that represent a broad spectrum of consumer and privacy concerns, we are writing in support of the complaint filed in the matter cited above and urge the Federal Trade Commission to act immediately to prevent harm to consumer privacy. This action is necessary because public pressure and informal attempts to resolve the issue have not been successful in persuading Intel Corporation to stop deployment of its Pentium III Processor Serial Number (PSN) and to change the design to provide adequate control for consumers.

The complaint describes the substantial harm that the PSN may cause, not only to individual consumers but to the Internet itself. It is vital to the growth of the Internet as a means of communication for people to be able to browse the 'Net with anonymity. The countervailing argument that the PSN is needed for security purposes is not convincing.

In fact, as the Commission knows from its examination of telephone-billed fraud and the use of Automatic Number Identification for billing purposes, the fact that the communication comes through a particular piece of equipment does not verify who is using that equipment to communicate. There are other methods for authenticating identity that are more effective and in which consumers affirmatively choose to participate.

Instead of providing significant benefits for consumers, the PSN would significantly contribute to the erosion of consumers' control of their personal information. The complaint provides detailed and compelling arguments for why the deployment of this product should be considered unfair and deceptive in violation of Section 5 of the FTC Act. We appreciate your considering our views in determining the appropriate action in this matter.

Sincerely,

Barry Steinhardt Associate Director American Civil Liberties Union	Susan Grant Vice President Public Policy National Consumers League
Katharina Kopp, Ph. D. Senior Policy Analyst Center for Media Education	Jean Ann Fox Director of Consumer Protection Consumer Federation of America	Evan Hendricks Editor/Publisher Privacy Times