October 18, 1999

By Hand

Mr. Donald S. Clark
Secretary
Federal Trade Commission
Room H-159
600 Pennsylvania Avenue NW
Washington, DC 20580

Dear Mr. Clark:

RE: Online Profiling Project--Request to Participate, P994809 / Docket No. 990811219-9219-01.

On behalf of Engage Technologies, Inc. ("Engage"), I write to request that Engage's Chief Technology Officer, Daniel Jaye, be included as a participant in the "Session I: Online Profiling Technology" segment of the FTC/NTIA Online Profiling Workshop scheduled for November 8, 1999. As described below, Mr. Jaye would provide this session with an important perspective and highly relevant expertise.

Engage is an industry leader in providing profile-driven Internet marketing solutions. Headquartered in Andover, MA with over 300 employees, Engage was founded in 1995 by Daniel Jaye and David Wetherell. Engage, which made its initial public offering earlier this year (Nasdaq: ENGA), is a majority-owned subsidiary of Internet firm CMGI, Inc. (Nasdaq: CMGI). Engage and CMGI have both recently announced plans to acquire other online profiling-related companies: Engage signed an agreement to acquire AdKnowledge (a provider of online marketing management services), and CMGI announced its intention to acquire Flycast (a provider of web-based direct response advertising solutions) and AdForce (a provider of centralized advertising services).

From the outset, Engage's founders recognized online profiling as a tool critical to the fulfillment of the Internet's potential to revolutionize the transmission of content and the conduct of commerce. The prevailing model of a fundamentally ad-supported web would serve to underwrite the Internet phenomenon for years to come only if advertising were transformed - by harnessing the revolutionary power of the Internet itself - from an uninviting nuisance into a welcome, customized consumer service. And one that gives consumers comfort, not concern over their privacy. Engage's mission has thus been to reinvent direct advertising for the online world in a way that not only greatly enhances the value to advertisers, but also greatly enhances both the experience and the privacy afforded to consumers.

Engage accomplishes its goals of promoting the value of online advertising and consumers' privacy alike through its two core products, Engage Knowledge and Accipiter AdManager. Engage Knowledge is a database of user profiles that are anonymous--devoid of personally identifiable information. Accipiter AdManager is an online advertising management system that automates the scheduling, targeting and delivery of ads on Web sites and the reporting of ad campaign results. Together, these products permit Web publishers, advertisers and merchants to deliver, target, and measure the effectiveness of advertisements, content and e-commerce offerings while respecting consumers' online privacy. Additionally, Engage offers Web traffic verification, measurement, analysis, and research through its wholly-owned subsidiary, I/PRO.

A leader in the online profiling industry, Daniel Jaye's substantial experience and understanding of the technical and policy issues surrounding online profiles would make him a valuable participant in the session on Online Profiling Technology. Since co-founding Engage Technologies, Mr. Jaye has served as its Chief Technology Officer, spearheading the development of interactive database marketing products and information services. In this role, he has pioneered relationship-marketing solutions using VLDB parallel database technologies. He also coordinates the review of technology and privacy developments for several of CMGI's affiliated companies, which (as noted above) include a growing range of Internet advertising firms.

Mr. Jaye has long led the industry in several online privacy initiatives. For instance, he is a co-author of the Platform for Privacy Project (P3P) Protocol Specification and is a participant in the P3P at the World Wide Web Consortium (W3C). He also authored and submitted to the Internet Engineering Task Force (IETF) an Internet Draft that proposes creation of "TrustLabels" to rate the privacy practices of web sites with regard to HTTP cookies (so that Web servers could inform users of their privacy practices and allow users to control how they wish to treat cookies based on its ratings). Through this proposal, Engage is helping to define the process by which better privacy standards are created and implemented on the Web.

Prior to co-founding Engage, Mr. Jaye served as Program Director for high-performance computing at Fidelity Investments, where he managed Fidelity's retail marketing data warehouse and applications and led projects responsible for enterprise-wide retail customer management and re-engineering of the sales process. Prior to Fidelity, he worked at Epsilon and Andersen Consulting. Mr. Jaye holds a B.A. in astronomy, astrophysics and physics from Harvard College.

We at Engage welcome the focus of the Federal Trade Commission and the Department of Commerce on the role of online profiling, as we share deeply in the vital goal of ensuring consumer confidence on the Internet. We look forward to the opportunity for Dan Jaye to share his valuable expertise and insights in the course of the workshop's discussions.

Thank you for your consideration of Engage's request. Kindly direct any questions regarding this matter to the undersigned.

Sincerely,

Michael K. Baker
Vice President of Business Affairs
and General Counsel

ENGAGE TECHNOLOGIES, INC.
100 Brickstone Square
Andover, MA 01810
(978) 684-3199
(978) 684-3877 fax
mbaker@engage.com