Transcript of Louis Freeh’s Keynote Address at “Building Trust on the Web” Consumer Reports WebWatch’s First National Summit on Web Credibility

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Note: This is an edited transcript of the proceedings. 

Charles F.W. Bell: Thank you. Hi, I’m Charles Bell, I’m the Programs Director for Consumers Union and that means I manage a variety of projects and initiatives. I had the privilege to be involved with the start-up of Consumer Reports WebWatch. I got to work on the grant proposal that brought it into being. It’s tremendously gratifying to me to see you all here today as sort of the public face of a community of interest that cares about this issue.

There is a constituency that cares deeply about whether we have credible and trustworthy information on the Web. And you come from a variety of disciplines. You come from the private sector and the e-commerce world, from government, from the non-profit sector, from consumer organizations and from the media and the health community, among others. I think it’s tremendous that we could aggregate this community of interest to try to carry this idea forward.

Clearly, the idea that we should have more credible, trustworthy information has intuitive appeal and it has deep resonance for many of us. This morning in his remarks, Hodding Carter said this project has audacious goals in wanting to create guidelines for credible information on all types of websites. He said it’s akin to parting the Red Sea. And I want to say that Consumer Reports WebWatch, with its small staff and its very optimistic director, Beau Brendler, will do its level best to part the Red Sea. But we can’t do it alone. We’re not Moses; we’re going to need your help. And so we thank you all for coming today and, going forward, we greatly value your participation and your ideas to help with the project.

We’ve spent a lot of time coming up with the guidelines for credibility. We again invite you to review them and consider whether your organization can endorse them. We’d also welcome your help in helping to get the word out, through peer-to-peer communication, though listserves, in other venues or speaking opportunities within your various sectors.

I think that the force of the combined group in this room should not be underestimated. We can really do this; we can carry this idea forward together. We also think there’s tremendous potential for cross-learning between different sectors, that there are lessons from the media world, for example, with its devotion to serving readers first and foremost and observing rigid separation between advertising and commerce that are valuable for other sectors of the Internet. And we think, conversely, there could be much other learning that will be helpful, also.

We want to use the Consumer Reports WebWatch organization as a mechanism for sharing information and we will be following up with you. We invite you to give us your suggestions in person or on our evaluation form at the end of the day. But also, we will follow up with you and continue to ask you for your ideas and suggestions.

Now, it’s my pleasure to introduce our luncheon speaker. We’re very fortunate today to have Louis Freeh here with us. Mr. Freeh was appointed FBI director by President Clinton in 1993, where he served for eight years, through 2001.

In his eight years as director, Mr. Freeh dramatically changed the Bureau’s mission, at a time when crime, like so many other things were becoming globalized. He has more than doubled the number of FBI branches around the world and focused on counter-intelligence and cyber crime, as well as DNA technology and state-of-the-art electronic surveillance. He’s also recognized the importance of building relationships with the private sector to tap cutting edge scientific and technical expertise.

Louis Freeh began his career in law enforcement as an FBI special agent, serving in New York City and at the FBI headquarters in Washington. He’s also held various positions in the New York City U.S. Attorney’s Office, including Deputy U.S. Attorney. He was also a U.S. District Court judge for the Southern District of New York.

Throughout his career, Mr. Freeh has been recognized for his exemplary accomplishments, including landmark investigations and prosecutions, such as the Pizza Connection and the VANPAC cases. Freeh now serves in the private sector as the Senior Vice Chairman for Administration at MBNA Corporation, the largest independent credit card lender in the world. He oversees the company’s legal affairs and is also responsible for all personnel, facilities, security and transportation functions.

Mr. Freeh, we’re so pleased that you could join us here today and we look forward to your remarks.

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Louis Freeh:Thank you very much, Charles, and good afternoon, ladies and gentlemen, it’s a pleasure to be here. Let me just begin by saying I really do appreciate not just the conference, but the very credible standards that are being proposed and propagated here. One of the most difficult things, putting back on my government hat for a moment, is getting an industry — particularly one which is as broad and diverse and dynamic as the one that uses the Internet, which is in effect the world — to come up with voluntary standards of conduct, in this case emphasizing disclosure.

In my time in Washington, Consumers Union was also considered very credibly as a middle-of-the-road arbiter and presenter of facts, so I really do appreciate your efforts here.

I want to leave a little bit of time for some questions. I certainly encourage you to do that. I’ve been asked questions for many, many years. Happy to try to answer yours. The FBI director, actually, unlike most federal officials, answers to more congressional committees than anyone else. So I actually hold the record for testifying more than anyone else in Washington – not that I’m particularly proud of that. We testify before the two judiciary committees, two intelligence, two appropriations, two government reform, so I’m pleased to get any of your questions and, as when I testify, I always followed Mark Twain’s rule, which is just tell the truth. That way you don’t have to remember anything.

On disclosures, I think building a trust in the Web, as building trust in any institution or person, really comes down to disclosure and transparency. And certainly in corporate America today, in the post-Enron world, we see by the regulated industries, including many of the financial institutions, the impact and the focus has been exactly on that, disclosure. And the Internet, where commerce is probably going to continue to exponentially grow over the next couple of years and decades, it’s critical — if e-commerce is to succeed — that people have trust and confidence in the mechanisms, in the people offering products and services. Which, as you know, don’t localize themselves. Many, many companies are, in fact, outsourcing call centers and whatnot, literally around the world. India, Pakistan, Philippines where someone calls and maybe believes they’re speaking to a representative in a local branch; in fact, they’re speaking to a foreign national who is working by contract to a corporation. And the issue as to how much of that needs to be disclosed is really a critical decision.

In terms of disclosure, of course, I come from a world where disclosure sometimes was difficult or slow to make. I remember just riding up here from Brooklyn this morning, one of my first assignments in New York City, I — it was actually a great assignment, I was 25 years old — I got here and my supervisor said, “Would you like to work under cover?” I said, “I would be delighted.” And in those days, being undercover was a much less formal process than it is today. No psychological screening, etc., etc.

Anyway, my job was to go to a health club in Brooklyn and observe an individual who was called Big Mike. It seems Big Mike was a captain in the Genovese family who controlled most of the piers on the West Side of Manhattan.

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Big Mike would shake down companies, particularly maritime companies, as a cost of doing business on his piers if they wanted to have union peace, etc. And at 75 years old, having been arrested a few times, he was very careful about where he took his payments from the various captains of the industry and decided that the safest place was in the sauna in a locker room in a health club in Brooklyn. Hence my assignment. I was supposed to go there and watch him and make notes. Of course, it was hard to make notes standing around a locker room without any clothes on. So I would go back to my locker and make notes.

But, anyway, in terms of disclosure, this went on for quite a period of time. And my job was just to identify people who were giving him cash envelopes. The reason he did it in the sauna is he realized they couldn’t record his conversations there, so that’s why he did it.

Anyway, he began to engage me in conversations, a very friendly man. And at one point, asked me what I was doing, who I was. My job now was not to engage him. I told him, because I didn’t want to completely misrepresent myself, I said I was a lawyer, but I really didn’t have a job. Then he offered to introduce me to various judges that he knew around the city.

Anyway, the end of the story was, he gets arrested. Guys on my squad arrest him and he’s presented in the U.S. Courthouse in Foley Square — ironically, the courthouse where, years later, I was assigned as a judge. So I was sitting in the front of the courtroom at the counsel table with the prosecutor. And Big Mike was in handcuffs in the back of the courtroom. And he’s trying to get my attention. You know, when someone’s trying to get your attention, you’re trying to ignore them. And I wouldn’t turn around to talk to him. Finally, his lawyer comes up to me, very prominent lawyer. And he says to me, “Are you an FBI agent?” And I said, “Yes, I am.” And he shook his head, he said, “You know, I’ve been telling Mike all morning that you’re an FBI agent. And he insisted that I come up and tell the judge to let the kid go, because he had nothing to do with it.” That’s a case where disclosure could not have been made at least prior to the arraignment.

Another quick story and then I’ll talk about some things that are serious. But disclosure, again, being the basis of your discussion. I was on a plane once in my last job, flying back from Hawaii, commercial plane. Five hour trip to LAX. And 10 minutes into the flight, the chief attendant comes up to me and says, “Director, the pilot needs to speak to you immediately.” And I assumed there was some drunk in the first-class cabin or whatnot. I had one other agent with me, so we went up into the cockpit. And the pilot says to me, he says, “Director,” he said, “my instruments indicate that the landing gear will not engage when we get to LAX.” And I looked at him, I said, “Why are you telling me that?” He said, “Well, I thought I had to disclose that to you.”

One of the things that I did quite seriously appreciate, particularly as the Internet as the crimes and bad people who populate it increased very dramatically over the eight years that I was director, trust in this technology is critical I think if e-commerce is to be everything we expect and hope it to be.

And, very much like any institution, whether it be a government institution or a private institution, people’s willingness to use this marketplace, both of ideas and products and services, will directly depend upon their trust in the institution.

Now, it’s interesting that in our court system, particularly our federal court system, if you take surveys, most people in this country have a very, very high trust in the court system. Not so much the police, separately, maybe not even the prosecutors and, when we get to the defense bar, it’s a whole different story. But with respect to the court, the institution of the United States court, there is a huge amount of trust in that process. And you have to ask yourself why.

Unlike many, many countries, not only in our constitution, but our whole society, our whole economy and all of our liberties directly relate to the protection and respect that we have for our courts. In fact, we’re one of the few countries that actually has courthouses. In many, many countries, there’s no such thing as a courthouse. The judge and the judicial part is in another government building. Where here we take particular time and devotion to the institutionalization, the separateness, the independence of the trust in our courts. So juries and people who go through the system as litigants, even as defendants, for the most part believe that this is a system that can be trusted. Because it’s trusted, people bring their disputes there. Whether it be contracts or disputes that in many, many other occasions and circumstances, could lead to violence and chaos and all the things that a system of law, a rule of law is designed to prevent.

What is it about our court system that makes it trust it — particularly trust the judges and the jury system? I think probably it’s because of the provision in our Constitution against public trials. Now, when the framers wrote that, they were talking about criminal proceedings, that they did not want to have under our Constitution what was not only common in many, many other countries, star chambers. Proceedings that occurred in secret. Where rulings were made by judges or officials without any understanding of the underlying facts and circumstances. So the right to a speedy and public trial has transcended beyond the criminal realm into the civil realm. And you can walk into just about any courtroom or any courthouse in the country – state, federal or local – and hear proceedings and understand proceedings. So that when the jury reaches a result, particularly in a controversial matter or a sensational case, there is a sense of confidence that people have because of the transparency of the proceedings. Because every part of the system, with a few exceptions, is designed to educate, disclose and illuminate the underlying facts and circumstances that support a decision.

Now, there are some exceptions to that rule. One would be, for instance, in the disputes and litigation that have to do with the protection of trade secrets. A trade secret is something protected which gives a person or company an economic advantage over someone who did not spend the genius or the research and development dollars to come up with a particular product or service.

And, up until 1996, there was no federal protection for trade secrets. There was copyright protection that went to intellectual property, but not protection for trade secrets. And we found, the Congress did, that trade secrets, particularly in the economy that is the leading edge not just for technology, but really economics in general was being pilfered and purloined by many, many people, indeed, by many foreign countries. In fact, there was testimony that probably about 29 foreign countries, most of whom are our friends, were actively and clandestinely using their external security services to steal not blueprints for the F-18, but secrets, trade secrets. Enzymes for the fermentation in pharmaceutical productions, etc., etc. The value of those ideas and property is not just the genius behind them, but the economic investment the companies make.

So the Congress passed, in 1996, a Trade Secrets Protection Act. And the statute requires companies to provide to the government in the course of a criminal investigation information about their particular trade secret. Congress had a dilemma there, which I think faces anyone today, but maybe more precisely issues and matters which have to do with disclosure on the Internet.

Congress decided that very few companies would voluntarily come forward and give the government the information about its trade secret which it wanted to protect in order to facilitate the prosecution. Because, in giving that information, obviously, it compromises the secrecy that is intended to be protected.

So Congress created a special provision in the statute which allows a closed and protected and sealed proceeding, where the information directly relating to the definition of that trade secret is protected. And the purpose was to encourage companies to come forward and voluntarily provide the information the government needed to prosecute and protect trade secrets.

On the one hand, the industry was wildly in favor of this statute, because for the first time in 200 years, it gave a federal protection to a trade secret. On the other hand, they were extremely reluctant to assist it, because in assisting it, they were fearful of the disclosures that they were about to make and how that would harm their ability to do business and the protection of the secrecy.

The guidelines which have been suggested here with respect to disclosure have in many cases the same dynamic at work. Companies would all agree, and I think most people would agree generally, that information about the ownership of sites and conflicts of interest, etc., etc., ought to be disclosed. This is a good thing, it’s like being in favor of free speech. Everybody’s in favor of free speech until they hear something that they don’t like.

The countervailing dynamic there is a company, particularly a new company, that has a very, very narrow profit margin and a very strong disincentive to tell the potential consumer all the reasons why it shouldn’t buy their product and service. This creates the inevitable tension between disclosure and private interests.

So what has to be fashioned, in my view, is a voluntary system, first of all. I don’t think it’s going to be possible for the government to impose a regulatory scheme which will govern how and when and in what manner business is conducted on the Internet, with a few exceptions. Financial institutions, for instance, and companies that are otherwise regulated by the OCC or the FTC will have to abide by those regulations whether they’re working on a telephone or in the international marketplace on the Web.

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But to the vast majority of companies and businesses and services, and because of the global nature of this marketplace and technology, no government — certainly not the United Nations — is going to be able to impose a scheme and infrastructure that will deal with the correct balancing of necessary disclosures and productive and economic competition.

So I think what needs to happen are companies, particularly the leading companies, not only agreeing to, but actually putting into practice guidelines which are not short-term in interest. I think the problem here is, if you look at a company’s short-term interest, why would you want to make a disclosure that you’re not required by law or regulation to make? And yet, if you ask yourself the question introspectively, you would agree that, in terms of a long-range policy, this is a good thing for this technology and this marketplace. It’s the next term, next quarter profits and what will this do to my sales type of inquiry which will make it much more difficult to do.

We found in a related experience that trying to control encryption — which was something that the government was very, very concerned about not only 10 years ago, but particularly now in the world of terrorism and Internet activities and potential dangers. How does the government control a technology that can be downloaded and keystroked across the globe and yet balance the public safety that’s required to access encrypted information to a law enforcement officer acting under a valid court order, for instance, as opposed to not interfering with free speech or free stream of information or data that the technology so robustly provides for?

Now, if you remember in the early 1990s, there was a very strong effort to encourage the industry, the manufacturers of the technology, encryption-based, to come up with some type of arrangement where the government, using a valid court order, with a judge making a fourth amendment type analysis, finds probable cause that information which is in encrypted form is related and relevant to a criminal investigation and orders that to be produced. The law enforcement officer with that order in hand can’t execute it because the encryption manufacturer is not providing or the technology does not have readily available to it the ability to plain text the encrypted technology.

The debate went on, it still goes on for quite some time. Should the government require manufacturers and/or users of encrypted products to provide for access pursuant to a court order when a judge, a judge in the system that most people trust, determines that information there is related to the commission of a crime and should be turned over.

Ramsey Youssef, just by way of example, who was convicted not just for blowing up the Trade Tower in 1993, but another more elaborate plot which was never achieved to blow up 11 U.S. airliners in the Western Pacific by putting timed explosive devices on them so they would all destruct within a few hours and kill, literally, hundreds and hundreds of people. They actually tested the explosive on an airline that killed a person, but without bringing the airliner down.

When he was subsequently returned to the United States from Pakistan, and tried downtown in federal court, one of the issues related to that investigation had to do with his computer. When a fire broke out in their apartment in Manila, he and the other co-conspirators, one who was Sheikh Khalid Mohammed, recently arrested, left the apartment and left behind a laptop computer. In that computer was an encrypted file and that file was inaccessible to the government for many, many weeks. In fact, it only became accessible not through a brute force breaking, but by a happenstance that was really unexpected. But in that encrypted file were all kinds of other plans. They were going to assassinate the Pope when he visited Manila, etc., etc., etc.

So what happens with an encrypted piece of data, either in transmission or stored, when the government makes a case that requires a judicial officer to issue a warrant, but the warrant is a nullity, because nobody can retrieve the plain text because the manufacturer never provided for that or built it into the system when the product was made?

The discussion, anyway, went from voluntary disclosures and provision of this technology to law enforcement officers to a discussion about whether it should be required. In the U.K., for instance, Parliament passed a statute which requires manufacturers, and even users to some extent, of this technology, to provide access to law enforcement officers when given the appropriate warrant. We don’t have such a system in the United States. And we’ve really relegated the effort to a voluntary effort by companies to make available to law enforcement and security services, when appropriate, but perhaps without a court order, which some people would prefer, information when it relates directly to the ongoing conspiracy to commit a terrorist act or some other similar crime. Or some matter within the jurisdiction of those agencies.

You saw recently a very long initiative by the White House, actually by the Security Council, to come up with requirements for cyber security which would be imposed on corporate America. It was very expected by many people that the administration would propose a very elaborate set of requirements, which would then be implemented at least where they would affect interstate commerce.

The end of that initiative — well, it’s probably not ended, but the end of that phase — surprised many people. Because after all the discussion, it really came down to a voluntary suggestion that corporations and businesses and entities that are directly related to cyber security and cyber safety, voluntarily adopt guidelines and provide for that type of cooperation. And I think that’s the future of this discussion. Unlike many other areas of public safety and law enforcement, this is an area which is going to be very difficult, if not impossible, for the government acting unilaterally to implement infrastructures of control [and required] activities. It’s really going to require the cooperation and partnership of industry. Industry is going to have to come forward with suggestions, with guidelines, with best practices.

And those are going to have to be universally recognized and used and there has to be the belief — and I think there is the belief — that if that is done and done well and done smartly, there will be trust in terms of e-commerce and Internet sites and that people will have a little bit more than whatever the percentage was in the Princeton study, I don’t know what it is currently, reflecting people’s willingness and trust in the Web sites that they regularly use and how extensively they will use them. Will they use them with their credit cards? Will they use them with their personal information? Will this economy, which is now a multi-billion dollar economy become a multi-trillion economy and is that the future of where we’re going? I think the regulation is going to have to come from the industry, though.

I have a lot more things I was going to say, but I wanted to leave some time for some questions and I’ve been told this is a very robust group and you will ask me questions, so I don’t want to run into the next session, but I’d be delighted to try to answer any of your questions. Yes, Ma’am?

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Q: [unintelligible] within each state, you have the attorney general, [unintelligible] looking out for the individual. And several years ago, the attorneys general in a group were looking at e-commerce and what it is doing to try to protect the consumer.

And you’ve got the State Department, or the Department of State within each state, which is [unintelligible] monitoring corporations. You’re suggesting something on a federal level that shouldn’t, perhaps, maybe started on a state-by-state level in the attorney general’s office and the departments of state?

LF: Yeah, I think the danger there is, as with any regulation, particularly as it becomes less voluntary and more requisite, the one thing that will harm not just the economy, but the corporate actors who are going to be required to make this thing work, are conflicting sets of regulations. In other words, if you’re a company just doing business in New York State, you’re very pleased to follow and maybe happy to follow guidelines that the attorney general and the department of state for New York have set forth. If you’re a multi-state corporation, the prospect of dealing — because that’s inevitably will be the case — with 10 sets of requirements or 10 sets of guidelines, voluntary though they may be, becomes not only extremely expensive, but almost inefficient in terms of realizing the goal, which is consistency.

I think what you really want is consistency and I don’t think with this particular technology — a technology that goes beyond our borders, I mean, literally around the world — you could really depend on a state-by-state regulation or even voluntary scheme. I think it has to be much broader than that.

Q: But if that corporation also has a public Web site, it’s still governed by the state of New York, but because of the public Web site, it’s now on a different federal [unintelligible] or international. So it’s a dichotomy for the company.

LF: Well, yeah, you could say it’s a dichotomy within the company, but what the company would say is we’re happy to follow a regulatory scheme or even a voluntary scheme, but we can’t follow 51 separate requirements and then meet the requirements of the European Union, who’s going to impose separate conditions.

I think the notion of federal preemption, which is very common in our law, whether it be antitrust matters or telecommunication matters or copyright matters, is something that we accept and understand and this case may be uniquely suited for federal preemption because of the difficulty and expense of doing it on a state-by-state basis. Yes, sir?

Q: What do you think about the disbanding of NIPC [National Infrastructure Protection Center] and the reorganization of the [unintelligible] FBI [unintelligible] Office of Homeland Security now?

LF: Well, we set up the Infrastructure Protection Center in the mid-90s because we were working in a vacuum where, if you had to conduct a forensic computer investigation, not only was the expertise not centrally available in the FBI, but it was no other place available. I think not only has the growth of Internet crime since that period, the mid-90s, just exponentially increased, but given the global venue in which these cases play out, I think it was a very good idea to centralize it in a department that has not just security requirements, but also national economy requirements as well as national security requirements.

We found, for instance, in many of the cases that came into the Infrastructure Protection Center, somebody was using an ISP in Turkey [unintelligible]. And one of the reasons we opened 25 offices around the world, in addition to being concerned about terrorism, was also because the Internet had changed crime, particularly white collar type crime, from a local and nationally-based platform to an international one.

So I think the continuing efficiency to centralize these assets, these investigative assets and making them more than just criminal justice assets, but actually national economic security assets is a very good step. The gentleman behind you had a question.

Q: I’ve been active in industry-led standards for about 20 years at this point. About 1995, the U.S. government backed out of that activity substantially and as a result, industry has backed out substantially as well. I guess my question is, if it is a value to the government to see voluntary consensus standards develop and mature, how do we get the government back engaged to support that activity?

LF: You know, I think one of the reasons why you may have seen some retrenchment is the notion that this is something situated for required regulation and sort of government intervention or oversight. I think part of the retrenchment is confusion about whether or not a voluntary standard, one, is going to work, and two, be credible. Or is the government wanting to reserve its right to do something more on the supervisory side? I think the experience since the period that you cite is that the global issues with respect to what has to be done to build and sustain trust in the Internet cannot be regulated by a state, by a national government, by a regional association, by a international association, except by voluntary compliance and cooperation.

So I think, if you look at Homeland Security and the result of the White House efforts which I just alluded to, they’re clearly shifting into the voluntary promotion of guidelines and standards. And I think that’s where it has to end up.

Q: I agree with where it needs to go, but the government is not doing, putting people in the standards bodies, so they’re not supporting it. They’re putting people in leadership positions, where they can take the user perspective into those bodies and help dissuade the tentative industry to try to go this way for that company and that way for that company. And they’re not purchasing the product that result from that, so we don’t have a financial incentive. That’s why I’m worried about government [unintelligible].

LF: Well, it’s a good point and a serious concern. I mean, the whole issue with voluntary encryption standards was that the government was going to purchase the products that had, you know, the voluntary compliance standards but then it didn’t purchase them, so of course it undercut completely any economic interest in doing it and you can’t operate in [it in a consistent] fashion. Yes, sir?

Q: Could you also talk about criminal [unintelligible] spam? Do you think it’s a good idea [unintelligible]?

LF: Well, I think it just butts up against the issue, again, of commercial speech. The Supreme Court says you can walk around a neighborhood and knock on people’s doors for any purpose. Whether it be religious promulgation or economic entreaties and whatnot. And we’ve had since the earliest days of the Republic, the ability to walk across the village green and knock on your neighbor’s doors. And yet in terms of technology, now we’re worried about making telephone calls or spamming email and whatnot. I think there’s got to be a balancing of the legal principle. I don’t think you can have two separate rules for two channels of free speech or, in this case, commercial speech.

Now, commercial speech, granted, doesn’t get the protection that First Amendment speech, including religious speech gets. But there’s a strong body of law, Supreme Court law that says commercial speech is a fundamental right and one that the government has to tread on cautiously.

And to single out spam or telemarketing from knocking on your door, you have to ask yourself what would you find more intrusive? A telephone call at dinner or somebody knocking on your door who won’t let you close the door because they won’t stop soliciting. And I’m not so sure there’s a difference and I don’t think the law is really at the point where it would distinguish something. Other questions? Yeah?

Q: Voluntary requirements sound terrific in principle, but at some point, there needs to be some kind of incentive [unintelligible]. What would you suggest?

LF: You know, I think the market and the technology have to develop more. I mean, the basic question is, should there be a policeman on the Internet? And people with law enforcement backgrounds say yes. One of the things that we worked on very hard with the Center for Missing and Exploited Children is the whole issue of predators and Internet predators with respect to children.

It’s interesting, if you ask people, “Do you want the government to do something to prevent a pedophile from speaking to your 10-year-old on the computer?” They’ll say, “Absolutely, you know, shoot ‘em.” And yet, if we talk about the same issues in different terms, you get a different answer.

So I think there’s got to be some rules of the road with respect to traffic on this highway, even though it’s an information highway. And I think what will happen. We were talking about this earlier. You know, unless the voluntary efforts are successful, and they may not be, this may be too big a piece for a diverse and dynamic industry and economy to digest and do right. If that doesn’t happen, the government will act. I mean, at some point, the Congress, as it is wont to do, will act because of a series of pedophile cases, or a series of things that will happen. Now, even more so, national security issues, when we’re talking about terrorism and terrorists not blowing up buildings, but shutting off the energy grid in the Northeast United States in the middle of the winter.

So I think, unless voluntary compliance becomes efficient and successful, the government will start to build a road that has some rules. And it’s like when the automobile was invented. You know, if you bought an automobile, you didn’t need a license, there were no traffic lights, you’d just drive wherever you wanted. And then, pretty soon, there were a lot of cars. And the cars started hitting each other, they started going interstate, because the bank robbers figured out that the state police had no jurisdiction across the lines. And then what do we have? We have traffic jams, but we have traffic rules and interstate commerce intervened on behalf of a hugely regulated industry and activity. And I think that’s what will happen here by way of analogy.

Okay, well, thank you very much. Have a good conference.

END OF SPEECH