VIA ELECTRONIC FILING
To: Mr. Donald S. Clark
Federal Trade Commission
Office of the Secretary
400 7th Street, SW
5th Floor, Suite 5610 (Annex A)
Washington, DC 20024
Re: Informational Injury Workshop and P175413
Dear Mr. Clark:
The U.S. Chamber of Commerce (“Chamber”), the world’s largest business federation representing the interests of more than three million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America’s free enterprise system, respectfully submits these comments to the Federal Trade Commission (“FCC” or “Commission”) in response to its request for comments for its December 12, 2017 Workshop on Informational Injury.
The Chamber applauds the Commission’s decision to hold the Workshop and take a serious look at the nature of informational harm in the context of privacy and data security. The Commission should use this Workshop as an opportunity to adopt a regulatory framework that focuses on protecting consumers against concrete consumer harms as opposed to merely conjectural or hypothetical injuries. Such an approach to protecting consumer privacy will provide much needed regulatory certainty, enhance competition in the marketplace, and enable businesses involved in e-commerce to continue providing consumers the benefits they desire...