Secretary, Federal Trade Commission
600 Pennsylvania Ave., N.W.
Washington, DC 20580
I am writing on behalf of the Institute of Electrical and Electronics Engineers - United States of America to provide information to the Federal Trade Commission in response to your notice (P994413) concerning warranty protection for high-tech products and services. IEEE is the world's largest technical professional association with approximately 350,000 members worldwide. IEEE-USA promotes the careers and public policy interests of the nearly 230,000 electrical, electronics, and computer engineers who are U.S. members of the IEEE.
At the present time, we are not prepared to comment in detail on each of the questions outlined in the FTC's public notice. However, we are concerned about the implications of the proposed state model Uniform Computer Information Transactions Act (UCITA) and its implications for consumers, business users of technology, software contractors/programmers, and high-tech business in general. Our concerns are outlined in greater detail in our position statement entitled "Opposing Adoption of the Uniform Computer Information Transactions Act (UCITA) by the States," a copy of which is appended below and which can also be retrieved on-line at http://www.ieeeusa.org/forum/POSITIONS/ucita.html.Because of our concerns, IEEE-USA is currently engaged in an effort to educate and inform our members throughout the U.S. on UCITA and its implications. To that end, we have collected a wide variety of resources on-line at the IEEE-USA UCITA Grassroots webpage (http://www.ieeeusa.org/grassroots/ucita), including a downloadable grassroots information kit (http://www.ieeeusa.org/grassroots/ucita/ucitakit.pdf) that may be of use to FTC's deliberations. One of the resources collected therein is the article, Cem Kaner, J.D., Ph.D., Software Engineering and UCITA (328Kb PDF), originally published in the Journal of Computer and Information Law, Vol. 18, #2, Winter 1999/2000, reprinted here with the author's permission (http://www.ieeeusa.org/grassroots/ucita/kaner.pdf).
IEEE-USA encourages the FTC to carefully evaluate UCITA and its implications for Federal consumer protection and intellectual property laws. We would be pleased to assist the FTC in exploring the implications of UCITA for consumers and innovators in the technical community. Please contact me at 202-785-0017 or email@example.com if we can be of any service or assistance in this regard.
Chris J. Brantley
The Institute of Electrical and
Electronics Engineers - United States of America
Last Update: 20 Sept. 2000
Copyright © 2000, The
Institute of Electrical and Electronics Engineers, Inc.