Dan Caprio, McKenna Long & Aldridge LLP, was a speaker and panelist at the “Internet of Things” in Brussels. The conference addressed fundamental issues relating to the future of the Internet, the concerns regarding embracing its development for the benefit of European society and the challenges ahead.

The premise of the Internet of Things assumes an evolution from today’s networks of interconnected computers to a future network of interconnected objects. The future Internet of Things promises many societal benefits including e-accessibility, home health monitoring systems, sustainable development, smart electric grids, and environmental protection to name a few. 

The premise of the Internet of Things, however, assumes direct connections to the Internet and ignores likely deployment scenarios where connectivity will be via machines and appliances that are read on local area networks. The so-called the Internet of Things would involve hundreds of identifier namespaces with countless authoritative sources of information about the objects with those identifiers. There are many different namespaces in existence that are managed by a broad range of organizations and the registries of the different namespaces can be private or public depending on their respective applications and business models. Most, if not all, items will be “tagged” in some fashion, and readable. It seems less likely that they will be directly linked to the Internet.

Some have opined that an Internet of Things gives rise to greater privacy and security concerns. However, this view fails to take into account the capability to build security and personal controls into devices and machines.  Given the evolving aspect of the Internet of Things we need to take a flexible, forward-looking policy approach with a view toward maintaining an environment that promotes innovation.   

These points reinforce the notion that governance questions concerning the Internet of Things must be considered in a contextual setting. While the commonly shared objective is to promote economic growth and support a globally interoperable platform, there is no “one-size fits all” policy approach. 

Rather, a flexible framework that considers the public and private/closed nature of the network(s), the diversity of identifier systems and the multiplicity of technological solutions resulting from an innovation-friendly environment should be the goal. While we see the potential of the Internet of Things, an overly regulatory regime, at this point, will surely lead to an Internet of far few things.

The Connection between People, Policies, Practices and Technology 

Solutions will exist at the intersection of these topics, treating them in isolation leads to an unreasonable belief that any one of the topics alone can provide a solution. The Internet of Things must not create a false dichotomy rather -- it must prompt us to consider a

Continuum of Internet connectivity. Mobile commerce, things, people, and machines will all be part of our future Internet connectivity. Tags, devices, and services will require different levels of information and will contain and protect that information in different ways.

DNS and ONS

Comparisons between the Domain Name System (DNS) and the Object Name System (ONS) bring an overly broad perspective.  Since they are not completely analogous systems, drawing ONS conclusions based on DNS issues is not advisable. It would be more useful to assure an adequate understanding of how ONS functions today, posit future developments and effectively address issues as they arise. Data over the ONS is not publicly available despite the fact that it uses the Internet infrastructure.

FRAMEWORK

Our discussions should focus on the framework conditions of fairness, access, transparency, competition, interoperability, trust and confidence. Only where these issues cannot be appropriately resolved should alternative infrastructure concepts be considered and then with a view to avoiding fragmentation.

The Internet of Things is by definition global (if not universal,e.g. items in Space may also be connected) and should be considered in a global context even while recognizing that legislative and regulatory inquiries must by nature consider a locality, nation or region. In concert with global considerations, a focus on interoperability may be more useful than harmonization as it is easier to find ways for systems and regulatory policies to work together short of mandating identical regulatory approaches. So, our solutions must be technology neutral.

The Internet is ultimately a collection of private and public networks with an open architecture that can both accommodate many different needs and encourage innovation. Any future Object Namespace will build on this flexibility and create its own customized networks based on their respective applications and business models.  The Internet of Things is too undefined (and its adoption too slow) at this point to commit its future parameters to a concrete control model. It would be premature to base any such decision on considerations of control that go beyond the concern for a technologically optimal governance structure.

While parallels may appear to exist between the Internet and the Internet of Things, borrowing concepts from Internet Governance discussions (i.e. “control” issues) and applying them to the Internet of Things may not achieve desired results given the different network nature and needs of the Internet of Things. Such efforts may result in misplaced emphasis on certain technological aspects of the Internet of Things which themselves may become less critical as the Internet of Things evolves. Moreover, innovative technologies and business practices, shaped by the Internet of Things network and user environment, may have the effect of minimizing what appear to be potentially significant “control” issues today. 

CONCLUSION

The Internet of Things must be seen as a vision where "things”, especially everyday objects, such as home appliances, furniture, vehicles, roads and smart materials, and more, are readable, recognizable, locatable, addressable and/or controllable via the Internet. This vision will surely change with time, especially as synergies between Identification Technologies, Wireless Sensor Networks, Intelligent Devices and Nanotechnology will enable a number of advanced applications and societal benefits.

On the other hand, the Internet will continue to go through many transformations. Taking a very simplistic yet useful short-cut to the history and destiny of the Internet, it is possible to distinguish three main trends that partially overlap and have the potential to change the way the Internet works and affects how we live. Internet 1.0 was been about linking and computers and sharing data. Internet 2.0 is about sharing content. Applications like Myspace.com, Facebook, and Linkedln are becoming the hub of the Internet activity. Internet 3.0 with sensor networks, connectivity, smart grids, environmental sustainability, e-accessibility, and many other societal benefits is the future.

A dialogue addressing privacy and governance is healthy and a necessary component of the Internet of Things. These discussions can not be focused on one particular technology; rather the focus should be on principles that both ensure a vibrant Internet that supports privacy, security and innovation.

Caprio will begin his work with the EU at its kick-off meeting on July 8, 2009. In the upcoming months, the group will examine the following topics:

• Development of a Privacy and Data Protection Impact Assessment (PIA) framework – this will be the priority for achieving the set deadline of May 2010;
• Identification of those RFID applications that might raise information security threats with implications for the general public;
• Identification of good practices and/or the definition of concise guidelines regarding information and transparency on RFID, with special emphasis on the use of European sign(s);
• Deactivation of tags in retail trade, including a review of existing technical options and a reflection on the feasibility and opportunity of "consumer empowerment" as a novel approach enabling the consumer to stay in control of the deactivation and/or reactivation of RFID tags.

More than 300 privacy-related laws are on the books, in both Washington, D.C. and state capitals. Privacy-related consulting services provided by law and accounting firms are a $500-million-a-year business and have been growing at double digits.

Expenses inside companies for privacy compliance easily run into the billions; a growing number of firms, for instance, now have their own "chief privacy officer." The International Association of Privacy Professionals, less than ten years old, has 6,200 members, and membership has grown as much as 40% a year for the last five years. "I don't think many professions can say that," says J. Trevor Hughes, its executive director.

So what, besides a gravy train of regulators, consultants and activists, are we getting for all this effort? Unfortunately, not much privacy protection.

On the one hand, laws designed to keep consumers apprised of privacy issues have resulted in a deluge of privacy notices, consent forms and security alerts into mailboxes, both real and electronic. You can't see a doctor, sign up for a bank account or visit a Web site without collecting your share of this paperwork. Rather than making people more private, though, the torrent of notifications leaves most of them so desensitized that they stop caring.

In other instances, the American approach to privacy occasionally produces too much of it, notably when it comes to medical research. Federal privacy laws involving health records are often so stringently interpreted by bureaucrats that studies involving life-threatening diseases have had to be scaled back or canceled. A pioneering, decades-long study of strokes and heart attacks shut down this year when researchers weren't able to get the necessary patient-consent forms signed.

A recent report from the Institute of Medicine says privacy laws have created a crisis for U.S. researchers. Lawrence O. Gostin, the Georgetown University law professor who presided over the study, complains that the consent forms that are a centerpiece of many laws don't even do a good job in protecting medical privacy. "Patients don't understand what they are signing," he says.

No one in this age of hackers and identity theft questions whether privacy and data security should be a priority. No one would want government agencies or companies to be sloppy when encrypting their databases and restricting access to personal information.

But many privacy efforts are proving counterproductive. Security "breach notices" are an example. First required by the state of California in 2003 but now widespread, these are the letters sent by companies to their customers letting them know about problems connected with their personal data. The worst case would be a hacker breaking in and stealing credit card information.

In principle it makes sense to force companies to fess up to their data glitches and give consumers the ability to fix any resulting problems.

In practice, though, companies are increasingly sending out the notices at the slightest provocation, leaving recipients confused about what, if anything, they need to do. It's a classic case of information overload.

Late last year, for example, there was a hiccup in the Web site software used by the International Cake Exploration Societé to collect members' $60 dues. Some of the personal information of the 3,500 hobbyist bakers who belong to the group may have been exposed online for a few weeks. The bug was fixed as soon it was discovered, and there was no reason to think that any private information had been accessed.

Nonetheless, Glenda Galvez, a Wichita Falls, Tex. wedding cake baker who is the group's president, found she had a legal obligation to notify her members. She was referred to Amir Azaran, with the Chicago law firm of Neal, Gerber & Eisenberg, who helped prepare the breach notices that were sent to every member in the group. Considering the minor nature of the problem, the blanket notification "didn't make much sense," says Azaran. But still, for him to have suggested any other course of action "would have amounted to telling a client to willfully ignore the law."

The legal bill will be a few thousand dollars. The bakers got off cheap. The Ponemon Institute, which studies privacy, estimates that lost or stolen laptops typically cost a company $50,000, much of it in the form of legal notifications.

Since many states put these notices on their Web sites, it's easy to track their frequency. Over the last 12 months, for example, Maryland residents have received 224 of them, from firms such as AT&T, Goldman Sachs, hp, Google, Facebook, 3m, Verizon Wireless, Kraft Foods, Continental Airlines and Starbucks. A quarter of those notifications were triggered by lost or stolen laptops. But sometimes the incident is trivial: One small Wall Street accounting firm bothered its customers with the news that an employee had seen a file he wasn't supposed to have.

Because of this overdisclosure, consumers seem to be caring less, not more, about privacy threats. Big companies sometimes provide a year's worth of free credit monitoring in connection with breach notices as a way of mollifying customers. Jay Cline, a consultant in Minneapolis who tracks privacy issues, says that in the early days of the notices, up to a third of recipients would take up such offers. Now, he says, the figure is below 5%.

Lawyers who spend their workdays preparing privacy-related notices freely admit that scarcely anyone reads them. The yearly privacy updates from banks required by the 1999 Gramm-Leach-Bliley Act are commonly cited as especially useless; no less an authority than Ralph Nader says the mailings are among the biggest wastes of paper in human history.

"Whenever I am speaking, I ask the audience if anyone has ever made use of one of those forms," says Kirk J. Nahra, an attorney with Wiley Rein in Washington, D.C. "If even one person raises their hand, I am amazed."

This legalistic, paperwork-based privacy can be privacy-hostile. Sleazy companies exploit the fact that no one reads privacy notices. This explains the profusion of Web gimmicks like "real age" tests, opinion surveys and iq exams. Their real purpose is to extract personal information from bored Web surfers, data that can later be sold for marketing purposes. "If a company wants to play fast and loose, all it has to do is bury something in 40 pages of legal mumbo jumbo," says Douglas Farry, with the law firm of McKenna Long & Aldridge.

If this emerging Everest of new privacy paperwork sometimes ends up creating too little privacy, other parts of the modern privacy industrial complex make for too much.

Medicine offers heartbreaking examples. The federal Health Insurance Portability & Accountability Act, or Hipaa, places so many new privacy restrictions on medical data that dozens of studies for life-threatening ailments--heart attacks, strokes, cancer--are being delayed or canceled outright because researchers are unable to jump through all the privacy hoops regulators are demanding.

Every five years, starting in 1979, doctors connected with the Minnesota Heart Study would look at the charts for every cardiac-related emergency room admission in the Twin Cities--45,000 charts in all. It's one of the world's most important ongoing heart studies and has led to numerous lifesaving breakthroughs in treatment, including documenting how many lives get saved by quickly giving thrombolytics to stroke patients.

Enter Hipaa and its requirement that patients give consent for their records to be examined. That can be nearly impossible to obtain when someone is having a heart attack. The study lacked the staffing resources needed to track down patients afterward. So the researchers folded up the operation.

"We had lots of useful clinical data, and we never had any sort of security breach," says an exasperated Russell V. Luepker, a University of Minnesota cardiovascular expert who ran the study. "Now the lawyers say that giving us the data would be risking a felony. It stinks."

Stanford University oncologist Sandra Horning has a three-year grant to study cancer tumors; her goal is to look at 450 tissue samples situated at a few dozen research centers around the country. Even though she doesn't need to know the names of any patients, Horning's team has spent two years dealing with Hipaa consent forms. In all that time no science has been done. "We are two years behind where we should be," she laments.

Sometimes bureaucrats end up protecting privacy rights that medical patients may not even know they have. Roberta B. Ness, now the dean of the University of Texas School of Public Health, was once researching risky pregnancies in a maternity clinic. Briefly peeking at medical records to find patients with telltale signs like hypertension was out of the question. But clinic regulators also said it was a privacy invasion to simply ask pregnant women waiting in the lobby if they'd like to volunteer for a study.

As a result, Ness said, enrollment in the study was reduced by half. Worse, researchers say the results they get from these reduced studies are methodologically suspect, since the sorts of people who consent to privacy forms are often not representative in income, race and education levels of the population as a whole.

Why haven't researchers spoken out? One reason involves the oversize role played in policy debates by privacy protest groups. Elaine R. Rubin, vice president for policy of the Association of Academic Health Centers, says that many scientists are reluctant to suggest rethinking the laws because they "worry about being accused by privacy absolutists of not favoring privacy at all."

Privacy advocates have become a staple in these debates. Many of them work hard at finding a reasonable balance between privacy and other social goods. Others, though, get attention with absolutist positions motivated by fringe personal beliefs. One argument advanced against radio-frequency ids--the electronic tags that handle toll passes and inventory control--is that the chips resemble the "Mark of the Beast" prophesied in the New Testament.

Some complainers are obsessed with anonymity and appear bothered by any data sharing at all, even when entirely voluntary. It's reminiscent of the Navajo belief that letting someone take your picture is letting them steal a piece of your soul.

This preoccupation with keeping data anonymous can lead to surreal outcomes. Fred H. Cate, director of the Center for Applied Cybersecurity at the Indiana University School of Law at Bloomington, notes that privacy advocates helped block a federal proposal to require air travelers to give their addresses and birth dates when buying tickets. While labeling the effort an invasion of privacy, they seemed unconcerned about the vastly more invasive alternative: federal agents performing body searches and rummaging through luggage.

RFIDs are a good case study of the peculiar public relations dynamics of privacy, and show that technology vendors are terrorized by suggestions that they aren't sensitive to privacy concerns. When probed by special scanners a few feet away, the chips report back a few dozen characters of manufacturer information, akin to what's found on a bar code. RFID tags are typically both readily visible and easily removable.

But some privacy advocates tell dark tales of RFIDs being part of an Orwellian nightmare in which citizens, by simply walking down the street, reveal everything about themselves to a network of ubiquitous scanners. Not only are the risks of the chips comically exaggerated, but the benefits--more effective counterfeiting controls, better monitoring of product safety and reliability--are never mentioned.

In the name of privacy, there have been campaigns against the RFID tagging of pets in Texas, while some New Hampshire citizens have argued about whether tagging a body inhibits the soul's progress to heaven. In California legislators briefly considered a proposal that the state publish a map showing the location of every RFID reader, as if they were toxic waste dumps.

Many companies have become reluctant to talk about RFIDs, even as they explore using them. One consumer products company, after describing in an interview its plans to eventually use the chip in its widely known household products, called back and asked that the products not be mentioned, lest it create p.r. headaches before the company was ready for them.

Is there a way out of the current, overly legalized approach to privacy, which seems to make no one happy?

Hints are emerging on different fronts. The Federal Trade Commission is beginning to nudge companies into being less wordy and thus more useful in describing their Web privacy policies.

Another approach involves realizing that "privacy" might be the wrong way of thinking about some issues. For example, many privacy advocates usually lobby to keep sensitive information out of medical records in order to prevent discrimination against people with stigmatized diseases. But this can make the records so sanitized as to be useless, which in fact is emerging as a concern as the country moves to a system of electronic medical records.

A better approach might be to make records as complete as possible but to crack down hard on anyone making improper use of them.

Protecting absolute privacy usually has a cost. Turning off cookies in Web browsers makes the Internet vastly less convenient. Similarly, assuring emergency room heart attack patients that no one besides their doctor will ever see their records may also result in their future care not being as good because important studies have to get canceled.

"Privacy is obviously a very important value," says attorney Cate, of Indiana University. "But sometimes it competes with other values. And that's something that many people don't seem to understand. We should be able to have frank discussions about social policies without the privacy card always automatically trumping everything."

As she promised, the redoubtable Viviane Reding, the European Union's Commissioner of the Information Society and the Media, has acted swiftly to publish a list of recommendations designed to protect EU citizens from possible, indeed probable, breaches of their right to privacy that may be occasioned by the use of RFID chips, writes Martyn Warwick.

McKenna Long & Aldridge LLP cordially invites you to join Managing Director Doug Farry and the San Diego Regional Chamber of Commerce for a policy forum on cyber security.

Friday, April 10, 2009
7:30 AM – 12:00 PM
San Diego State University
Student Services 1500

The importance of cyber security as a national concern and policy issue cannot be overestimated by business leaders. The U.S. Chamber of Commerce and the U.S. Department of Homeland Security seek to increase cyber security awareness and encourage cyber security investment by the private sector by explaining the importance of integrating cyber security into organizations’ enterprise risk management planning. The U.S. Chamber-DHS partnership allows leading experts from federal, state and local, and business sectors to bring cyber security practices to the wider business community.

There is no charge for the seminar, however, reservations ARE REQUIRED. For additional information, please contact Angela Flori at (619) 544-1343 or click here to register.

Recently, the National Federation of Independent Business(NFIB) polled its members on the top issues facing small businesses in Alaska. The results of the poll will be used to shape the lobbying position of NFIB during the current session of the Alaska Legislature.

One of the questions in the poll asked if the Alaska Legislature should pass legislation controlling the use of RFID by businesses in tracking inventory and other electronic transaction.  The majority of respondents (56 percent) voted no, while 24 percent voted yes, and 20 percent were undecided.

For complete poll results, please click on the attached press release, or visit http://www.nfib.com.

State government efforts to address privacy concerns about RFID are ongoing. New York is just the latest addition, following the "privacy advisory board" concept already in place in New Hampshire, California and other states.

For any questions about this bill and how it affects your business, you can contact John Harris in our Albany office at john.harris@mckennalong.com.

The latest RFID legislation from the state of New Hampshire is attached. Feel free to share your thoughts on the RFID Law Blog.

We see the development of a secure supply chain and expedited entry as a significant opportunity on a going forward basis. The full text of the FDA announcement can be found here.

Download file

The impact of this (see attached), among other things, is that if the FDA chooses to require RFID tags on pharmaceutical products to address e-pedigree and drug safety objectives, retailers that carry pharmaceutical products would have new requirements and obligations if this law is enacted in NY. Different states have introduced, and some have passed similar - but not identical - legislation. This could create an inconsistent network of requirements and standards.

The U.S. Department of Commerce and the European Commission are eager to promote RFID in Europe this spring within the context of the Transatlantic Economic Council.  Following a very successful U.S./EU RFID symposium last fall, both sides have committed to jointly pursue frameworks for advancing transatlantic economic integration to build upon the success of an initial RFID pilot project to demonstrate best practices in other areas including health care and environmental sustainability. 

Companies concerned with how upcoming RFID/SCM requirements will affect their global supply chains have an opportunity to influence the outcome.

The U.S. Department of Commerce and the European Commission are expected to continue collaboration on RFID within the context of the Transatlantic Economic Council.  At the 2007 U.S./EU summit, there was a commitment to jointly pursue adoption of a framework for advancing transatlantic economic integration. The initial U.S./EU collaborative RFID pilot project to sort, track, and monitor medical and industrial radioisotopes in commerce was announced in October 2008.  Both sides want to build on the success of that pilot project to demonstrate best practices in other practice areas.  As a continuation of this initiative, the European Commission is planning a symposium and "matchmaking" RFID event this spring in Brussels - bringing suppliers, customers, and government entities together to develop mutually beneficial solutions.

Since policymakers in both the EU and U.S. will be carefully monitoring the initial pilot project to inform their decisions about laws and regulations governing RFID in pharmaceutical and medical device supply chains, this forum and matchmaker event is an outstanding opportunity for companies to participate and help shape outcomes with regard to their business strategies.

U.S. Federal E-Pedigree Standards Deadline

In the summer of 2007, the U.S. Congress passed the Prescription Drug User Fee Reauthorization Act, allowing the FDA to collect fees from those seeking drug approval in the U.S. to fund regulatory and oversight operations.  Improved drug safety, particularly the need to reduce contaminated and counterfeit drugs from entering U.S. supply chains, continues to be a key focus of federal lawmakers.  The legislation gave the FDA 30 months to develop technology standards for imposing electronic pedigree requirements on pharmaceutical products and eventually medical devices.  That deadline expires in Spring of 2009.  While it is likely to slip, since the new Obama Administration’s political appointments will not be confirmed by then, 2009 will be the year that FDA establishes Federal ePedigree standards.  Given the history of support for the technology, that standard will likely include RFID in some way.

This has both positive and negative consequences – the standards established may or may not be consistent with your existing SCM systems, and the likely “phased-in” implementation of new drugs and devices to be covered by the requirement may or may not be consistent with your business strategy.  With the recent election of Representative Henry Waxman (D-CA) as chair of the House Energy and Commerce Committee, Congress will likely see a more aggressive and regulatory-minded policy maker overseeing the FDA and it’s implementation of these standards.  New liabilities, including requirements involving data privacy and security, may enter the debate in new ways.

 Contact:  Charlie Greenwald at 703-284-5305, cgreenwald@itaa.org

 ITAA Cautions Against Over-Regulation of the ‘Internet of Things’

 Joint Letter to European Commission Explains Concerns of ITAA and Other Associations

 Arlington, VA – Joining forces with a diverse group of global business councils and trade associations representing retail, healthcare, manufacturing, food and grocery sectors, the Information Technology Association of America (ITAA) has expressed concerns about a European Commission staff working document prepared for a planned “Communication on the Internet of Things” in the second quarter of 2009.

 The associations commented that the premise of the “Internet of Things” assumes an unlikely deployment scenario for Radio Frequency Identification (RFID) technology. While they agreed with the concept that, in the future, most if not all items may well be “tagged” in some fashion and thus readable, they said it was less likely that as many will be directly linked to the Internet as the Commission document appears to assume.

 Signed by ITAA President and CEO Phil Bond and other association leaders, the joint letter expresses appreciation for the “open and inclusive process” of developing European Commission policy but noted, “While we understand and appreciate the rationale for thinking of the Internet of Things, we remain concerned that it creates a false dichotomy rather than prompting us to consider a continuum of Internet connectivity.”

 The Commission document also fails to appropriately highlight the intersection of people, policies, practices and technology in addressing these issues. It is looking ahead to the time when many consumer and commercial products will be embedded with RFID or other devices that permit them to be read by sensors or in some cases communicate with computer systems or the Internet.  These may range from a commercial soda vending machine to a refrigerator connected to a home’s local area network.

 ITAA and other business groups are worried that the commission’s understandable concern for security and privacy may  lead to premature and overly burdensome regulation of these and other technology advancements, if the Commission proceeds under such unlikely assumptions and incomplete picture of privacy and security. Such regulations could increase costs, discourage applications and delay the potential benefits to consumers, businesses, governments and national economies. 

 Bond and others signing the joint letter closed by saying, “We commit to continuing to work together to create an environment where innovation will continue to develop beneficial uses of technology and individuals will have trust and confidence to use such technology.  We look forward to our continued dialogue to further refine recommendations so that individuals’ rights are protected while encouraging innovation and the societal benefits we stand to reap with new technology.”

 Joining ITAA in the input to the European Commission’s Information Society and Media Directorate General were the European-American Business Council, Food Marketing Association, Grocery Manufacturers Association, U.S. Council for International Business, Association for Automatic Identification and Mobility (AIM Global), Retail Industry Leaders Association, Healthcare Distribution Management Association, National Retail Federation and National Association of Manufacturers.

 A complete copy of the associations’ response is available at the following link: http://www.itaa.org/upload/RFID/Internet_of_Things.pdf

 ###

 About ITAA

 The Information Technology Association of America (ITAA) is the premier IT and electronics industry association working to maintain America’s role as the world’s innovation headquarters. Following its April 1, 2008 merger with the Government Electronics and Information Technology Association (GEIA), ITAA provides leadership in market research, standards development, business development, networking and public policy advocacy to some 350 corporate members doing business in the public and commercial sector markets. These members range from the smallest start-ups to industry leaders offering Internet, software, services and hardware solutions. ITAA offers the industry’s only grassroots-to-global network, carrying the voice of IT to companies, markets and governments at the local, state, national and international levels to facilitate growth and advocacy. The Association maintains a formal alliance with more than 40 regional groups in the U.S. and Canada, representing 16,000 technology-related companies through the Technology Councils of North America. ITAA is also the U.S. member of the World Information Technology and Services Alliance, a network of nearly 70 industry associations from around the world. For more information, visit www.itaa.org

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