Visa U.S.A. Inc. - Comment on CardSystem Solutions, Inc.

VISAMarch 27, 2006 Russell W. Schrader Senior Vice President Assistant General Counsel By Electronic Delivery Federal Trade Commssion Offce of the SecretarRoom 135­600 Pennsylvana Avenue, NWWashington, DC 20580Re: CardSystems Solutions, Inc., File No. 0523148 Ladies and Gentlemen: Ths comment letter is submitted on behal or Visa U. A. Inc. in response to theproposed consent agreement issued by the Federal Trade Commission ("FTC") concerng theFTC' s allegation that CardSystems Solutions, Inc. ("CardSystems ) failed to employ reasonableand appropriate securty measures to protect credit and debit card information that CardSystemsstored on its computer network in connection with processing payments for merchants. Visa appreciates the opportnity to comment on ths important issue. I is a parThe Visa Payment System, of which Visa U. .A. , is the largest consumerpayment system, and the leading consumer e-commerce payment system, in the world, withmore volume than all other major payment cards combined. In calendar year 2005, Visa U.card purchases exceeded a trillon dollars, with over 510 millon Visa cards in circulation. Visaplays a pivota role in advancing new payment products and technologies, including technologyintiatives for protecting personal information and preventing identity theft and other fraud, forthe benefit of Visa s member financial institutions and their hundreds of milions of cardholders.Visa Supports the FTC' s Data ...