[arin-ppml] ISP Customer Data Privacy Proposal

Thomas Kubic tkubic at psi-inc.org
Thu Apr 15 13:21:09 EDT 2010



I am writing to post a comment on the question of the ISP Customer Data
Privacy Proposal.


The Pharmaceutical Security Institute (PSI) is a not for profit organization
established in the early 1990's by the security directors from twenty-four
international, research based pharmaceutical manufacturers.  Now
headquartered in the Washington, D.C. area, the mission of PSI is to assist
member pharmaceutical manufacturers to collect and analyze information
related to the counterfeiting, illegal diversion and theft of
pharmaceuticals and to disseminate that information to law enforcement and
drug regulatory authorities.   The objective of these efforts is to disrupt
well-established counterfeiting groups.


Counterfeiting is viewed as a serious public health menace promoted by
criminals with little regard for the health and safety of patients.  The
security directors and their staff regularly work with the authorities to
stem the follow of illegal, unapproved and dangerous medicines.  


                One area of continued concern is the continued deluge of
unsolicited spam advertizing discount prices for medicines that has
bombarded the public.  A 2009 report from LegitScript and KnujOn found that
80 to 90 percent of the search engine-sponsored advertisements of online
drug pharmacies violated federal and state laws.[1] (see:



The World Health Organization has consistently warned against on-line
purchases of medicines noting the high percentage of counterfeit drugs being


It seems to me that hiding the identity of the business user of an IP
address would further aggravate this problem for law enforcement officers,
customs agents and drug regulatory authorities.  Importantly, I see the
following negative impact on patients and consumers:


            It would deny the consumer access to the true identity of the
owners - today, consumers have few resources available to verify the owners
of the business sites;


It would facilitate fraudster's ability to steal money from consumers -
these fraudsters already exploit the internets' anonymous environment and
deny consumers protection against fraud;


It would complicate a consumer's ability to redress legitimate grievances;
and, finally,


It would further limit transparency in business transactions.  


            Would you kindly post my remarks,


            Thank you,


            Tom Kubic


[1] See:  http://r20.rs6.net/tn.jsp?t=hxlt9mdab.0.9p97cqdab.ynkefvbab.2522

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