Re: ISSUE-10 First party definition, ISSUE-60, ACTION-?

Yes, I do not have any known criticism of the text that resulted from the
earlier action.

The "joint marketing exception" in Gramm-Leach-Bliley has been in
operation for over a dozen years. It is for a very similar concept.  For
instance, now that I am spending time in Atlanta (home to Delta Airlines),
it applies to a Delta American Express card.  A website for that card is
really about Delta and also really about Amex.

I am not saying that the joint marketing rules and experience should
necessarily apply to DNT.  I was suggesting that our work on DNT should be
informed by the experience with the same concept in GLB.

My request to Rob was to look at the proposed DNT text in light of the GLB



Professor Peter P. Swire
C. William O'Neill Professor of Law
    Ohio State University

-----Original Message-----
From: Justin  Brookman <>
Date: Friday, March 1, 2013 1:56 PM
To: "" <>
Subject: Re: ISSUE-10 First party definition, ISSUE-60, ACTION-?
Resent-From: <>
Resent-Date: Friday, March 1, 2013 1:57 PM

>It was my understanding that Peter had asked him to revise this
>language, suggesting GLB's joint marketing rules as potential guidance.
>Justin Brookman
>Director, Consumer Privacy
>Center for Democracy & Technology
>tel 202.407.8812
>On 3/1/2013 12:14 PM, Rigo Wenning wrote:
>> On Wednesday 27 February 2013 10:52:28 Justin Brookman wrote:
>>> Rob Sherman is separately working on text regarding multiple first
>>> parties.
>> AFAIK, Rob and I succeeded with the text that resulted from ACTION-273
>> Rigo

Received on Friday, 1 March 2013 22:14:37 UTC