December 2, 2019
Via Electronic Filing
Federal Trade Commission Office of the Secretary
600 Pennsylvania Avenue NW Washington, DC 20580
Re: 16 CFR Part 425 – Negative Option Rule, Project No. PO64202
Comments of the Entertainment Software Association and Internet Association
Dear Secretary Tabor,
The Entertainment Software Association (“ESA”) and Internet Association (“IA”) submit
these comments in response to the Federal Trade Commission’s (“FTC” or Commission”) advance notice of proposed rulemaking and request for public comment (“Notice”) regarding the Commission’s Rule Concerning the Use of Prenotification Negative Option Plans, 16 CFR Part 425 (“Negative Option Rule or “Rule”).
