In the Matter of

Online Profiling Project Comment P994809 /

Docket No. 990811219-9219-01

Cyberknowhow, Inc, through its undersigned counsel, respectfully submits these comments in response to the Commission's request for comments on the Online Profiling Project.

Cyberknowhow operates multiple web sites that are configured to provide consumers with resources and information so that consumers can obtain desirable products and services. Web sites operated by Cyberknowhow, Inc. include Bookpricer.com, Medicalsearchengine.com, Nationalvoicedatabase.com, Greatscripts.com, Globaljobnet.com, Dvdsearchengine.com, Cybercard.com, and Cybershowbiz.com. Through operation of these sites, Cyberknowhow Inc. has the capability to perform online profiling, provide online advertising, and facilitate online marketing of products and services.

Cyberknowhow, Inc. recognizes that consumer profiling can be very useful to both consumers and to entities marketing products and services. Accordingly, Cyberknowhow, Inc. seeks to ensure that consumer profiling can continue under circumstances in which consumer security and satisfaction will be promoted.

1. Types of Companies and Relevant Business Models (Question 1)

Three main types of profiling activity are prevalent. These types can briefly be summarized below.

A first type of profiling activity involves gathering of consumer information or data in order to supply it to online marketing companies. This is the most common usage of consumer data as evidenced by multitudes of email lists available for every conceivable demographic. A recent innovation in this field has been the growth of "Permission Marketing" where the consumers willingly allow their names to be given to marketing companies which may contact them. This could be due to a real interest in certain services or goods or to inducements such as giveaways or sweepstakes.

A second type of profiling activity includes using consumer activity online to locate and provide relevant addition information. This procedure is a useful service provided to consumers by monitoring their online activities and simultaneously mining the entire web to bring similar available goods and services to the attention of the consumer. The profile database thus collected can of course be used either to provide ongoing relevant information to the consumer, or to create a list to sell or rent which pinpoints the interests of the consumer with accuracy.

A third and final type of consumer profiling activity involves using "Buffer" services providing online anonymity, limited financial liability, verification of age limits, and credit. Along with local delivery outlets for the goods purchased over the web, "buffer services" are necessary for the consumer to get the full benefit of the Internet revolution. Cyberknowhow is currently engaged in a project to provide every consumer with a web persona which masks the consumer's actual identity. The web persona displayed can include the consumer's age so that the merchants can be assured that sales are to a qualified consumer.

2. Do current Technologies enable creation of anonymous profiles? (Question 4)

"Buffer services" mentioned in reply to question 1 are the main source of anonymous profiles. These service companies can supply demographics of geographical areas, age groups and gender preferences, without the need to provide the name of consumers. Additionally, certain Internet service providers have decided to stop providing names of their consumer clients and will make anonymous profiles available instead.

The technologies required for the above are fairly simple and are not as important as the resolve to protect the consumer's privacy while at the same time allowing the consumer to receive all possible benefits of Internet use.

3. How is the information collected by online profiling companies used? (Question 7)

The data collected may be used in several ways. Often the profiler uses the data to create a database of consumer preferences. The profiler may use such databases for its own use to offer similar goods and services or may sell the data to third parties for the purpose of market research.

If the data is collected in real time, while the consumer is online, it can be used to provide the consumer with useful up-to-the-second information, related to his/her online quest. If a buffer service is used by the consumer (providing an anonymous code instead of a name), consumers are entirely protected and will be dissatisfied only if they do not wish to receive the relevant web information.

4. What are the costs and benefits, both to industry and consumers, of online profiling? (Question 9)

It is vital for the industry that the consumer has confidence in the Internet and is comfortable with family use of the Internet. It is vital therefore that profiling is used under the most stringent of rules and all of the possible safeguards, including buffer services being provided to the consumer.

Obvious benefits to the industry result from consumer profiling. Proper use of online profiling of consumer preferences can be of great help in developing the Internet as the most important tool invented by mankind. In the year 2000, there will be more web pages than there are human beings on this planet. To be expected to search through these billions of bits of data and locate the exact bit of information will be increasingly difficult for us all. Profiling one's preferences allows one to receive up to date information on subjects of interest. Real time information about topics related to one's online activity, provided while browsing the Internet can be very useful and time saving.

Online profiling does have some costs for the consumer. The main cost can be a loss of privacy if one's personal details fall into the wrong hands. Additionally, consumers can be confused by the receipt of an overwhelming amount of information. Finally, cyber spoonfeeding is disliked by many who wish to explore independently without being directed to preselected destinations.

In conclusion, Cyberknowhow respectfully submits that online profiling is a very useful activity for consumers and for industry. As long as mechanisms are available for ensuring consumer security, consumers will use these mechanisms and benefit from online profiling. We look forward to participating in further discussion pertaining to online profiling and further development to ensure that proper security measures are available.

Respectfully submitted,

Kunwar Chandrajeet Singh
Web Developer
Cyberknowhow, Inc
9399 Wilshire Blvd.
Beverly Hills, CA 90210