Comment submitted by Matthew Schruers, Computer & Communications Industry Association

Before the Federal Trade Commission Washington, D.C. In re Digital Rights Management Project No. P094502 (DRM) Town Hall (Comment) COMMENTS OFCOMPUTER AND COMMUNICATIONS INDUSTRY ASSOCIATIONIn response to the Federal Trade Commission’s (FTC or “the Commission”) announcement of a town hall meeting regarding digital rights management technology, the Computer and Communications Industry Association (CCIA) submits the following comments. CCIA is a trade association dedicated to open markets, open systems, and open networks. CCIA members participate in the Internet, information, and communications technology industries, ranging from small entrepreneurial firms to the largest in the business – companies which collectively generate more than $200 billion in annual revenues. These comments focus on three issues: the notification and disclosure issues related to DRM, the risks to competition posed by DRM-related impediments to interoperability, and the fact that the use of DRM exacerbates the costs of current misconceptions about the balance between rights-holders’ rights and consumer rights. To address the first issue, it is proposed that the Commission offer guidance to market actors about when disclosure is appropriate. To address the second issue, these comments urge the Commission to take a more active role before the courts, and, where appropriate, in the exercise of its jurisdiction as a competition authority. In response to the third issue, CCIA ...