260 West 52 Street apt. 27B · New York,
New York 10019
April 18, 2000
Mr. Donald S. Clark, Secretary
Dispute Resolution for Consumer Transactions in the
Dear Mr. Clark:
I am an entrepreneur developing an automated on-line alternative dispute resolution (ADR) system for e-commerce transactions. My system is an entirely automated negotiation mentor that operates according to an assisted negotiation model, and is particularly suited for small e-commerce transactions. Our business model is to charge businesses an annual subscription fee on a sliding scale, depending on whether they have their own web site or sell only through auction web sites.
I believe that government regulation would significantly encourage use of on-line dispute resolution systems by companies and individuals selling through the Internet (e-merchants). My suggestions for appropriate regulations are as follows:
To reduce the cost to credit card issuers of chargeback processing for e-commerce transactions, the Fair Credit Billing Act should be amended as follows:
Additionally, other laws and regulations relating to dispute resolution should be amended so that written notice requirements can be satisfied by electronically delivered notices (including e-mail and facsimile transmissions).
Because I believe my technology model offers a non-regulatory solution to some of the FTCs concerns, I would like to participate in the FTCs June 2000 workshop on ADR systems. I would be pleased to demonstrate a prototype of my system.
I am eager to work with the FTC, the consumer advocacy community, the dispute resolution community and the business community as a voice for on-line dispute resolution systems. I appreciate this opportunity to provide my views on alternate dispute resolution for online transactions, and look forward to the public workshop.