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Comments filed with the Federal Trade Commission on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

Comments filed with the Federal Trade Commission on “Protecting Consumer Privacy in an Era of Rapid Change: A Proposed Framework for Businesses and Policymakers.”

The Federal Trade Commission should rigorously analyze the costs and benefits of its proposed privacy recommendations, including the “Do Not Track” mechanism, before moving forward with any policy proposals. Without such an analysis, the Commission cannot accurately predict if its recommendations will improve or reduce consumer welfare.

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