<HTML> <HEAD> <title>WebForm1</title> <meta name="GENERATOR" content="Microsoft Visual Studio .NET 7.1"> <meta name="CODE_LANGUAGE" content="Visual Basic .NET 7.1"> <meta name="vs_defaultClientScript" content="JavaScript"> <meta name="vs_targetSchema" content="http://schemas.microsoft.com/intellisense/ie5"> <META http-equiv=Content-Type content='text/html; charset=UTF-8'> </HEAD> <body > <TABLE id="Table1" cellSpacing="1" cellPadding="1" width="100%" border="0"> <TR> <TD><b>Comment Number:</b></TD> <TD>518795-00279</TD> </TR> <TR> <TD><b>Received Date:</b></TD> <TD>10/26/2005 7:09:51 PM</TD> </TR> <TR> <TD><b>Organization:</b></TD> <TD></TD> </TR> <TR> <TD><b>Commenter:</b></TD> <TD>Vatterott, Glenn</TD> </TR> <TR> <TD><b>State:</b></TD> <TD>MO</TD> </TR> <TR> <TD><b>Agency:</b></TD> <TD>Federal Trade Commission</TD> </TR> <TR> <TD><b>Rule:</b></TD> <TD>Competition Policy and the Real Estate Industry</TD> </TR> <TR> <TD><b>Docket ID:</b></TD> <TD>To Be Added</TD> </TR> <TR> <td colspan='2'>No Attachments</td> </TR> </TABLE> <hr/> <b>Comments:</b><br/><br/> I speak for no one but myself in the following remarks, but as someone long involved in various aspects of real estate, I m concerned that the DOJ is being lobbied to intercede on behalf of technology companies who would like to insert themselves into the home buying process. These  online real estate data scrapers have a dirty little secret: they don t want to interact with the consumer, or the agent, or be involved in any real way in the home sale process. They simply want to insert themselves between the buyer and the agent by grabbing the data that the traditional real estate agent has worked hard to create, and use that data to generate leads, and then SELL the lead back to the agent. These data scrapers have little or no interest in working with the consumer; they simply want to use readily available technology and existing content (MLS data) to generate revenue. They take the data that the real estate practitioner has assembled and they post that data on a website, in competition with the information the real estate practitioner has posted on sites readily accessible to the consumer, and if they generate interest, they will sell the lead back to her in the form of a hefty referral fee. I m concerned that the DOJ may be unwittingly endorsing the creation of a whole class of non-productive middlemen, who produce nothing, contribute nothing and are sucking money out of the home buying process& and that money comes from where? It comes from the consumer. They are not interested in real estate, the real estate process, the home buying experience, or the welfare of their clients and customers. Traditional real estate professionals build their reputation on the word-of-mouth of satisfied homebuyers and home sellers. They know that market values hinge on what the informed buyer is willing to pay and the seller is willing to accept in the current marketplace. They know that in a high-consumer-touch, competitive business environment, fairness to all parties is the stuff of long-term business survival. The scrapers have no such ethical considerations. Nor have they interest in the mundane details of construction, easements, architecture, valuation, regulatory issues, occupancy permits, zoning, lead-base paint disclosures, Seller property condition disclosures, Megan s Law, environmental issues, school districts, neighborhood amenities, building/mechanical/termite inspections, etc. They are interested solely in content that can be put online and that has the potential to generate revenue for them. As a sidebar, I have recently seen an individual named Bruce Hahn securing some media attention. He has draped himself in a veil of consumer advocacy, identifying himself as the main spokesperson for something called the  American Homeowners Grass Roots Alliance. They show their address as&nbsp;&nbsp;&nbsp;&nbsp;&nbsp; Arlington, VA 22213. I further found Bruce Hahn identified online as the Director of Public Policy for the Computing Technology Industry Association, aka CompTIA. (www.comptia.org) also located at&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;Arlington, VA 22213. Which is he? CompTIA describes itself as  & the leading association representing the international technology community. According to their website,  CompTIA s public policy group helps members participate in and shape policies that affect their bottom lines. If one connects the dots it may appears that this current effort is simply an extension of the initiative the tech sector has been pursuing for several years. They view the MLS as a conveniently well-organized database that they could easily throw online, at little expense, and use to generate income for themselves. There is a perception that the technology world is trying to encourage the DOJ to hand over MLS systems to them so they can generate customers for the data and then---in an amazing irony---sell those customers back to the very group who created that data. I hope that the will DOJ will not ignore the fact that these scapers have no interest in assisting the buyer with the complex process of home buying or home selling. They would rather leave that to the licensed practitioner. They simply want to use existing automated systems to insert themselves into the process and then charge a disproportionately high fee for little more than forwarding an e-mail to the real estate practitioner who not only created the data, but who will be left with all the heavy lifting on both sides of the transaction. <A name=RDACT1></A> </body> </HTML>