Elizabeth Harris, Acting Director
New Jersey Division of Consumer Affairs
124 Halsey Street
PO Box 45027
Newark, NJ 07101
RE: Public Comment on New Jersey Data Privacy Law Rulemaking
To Whom it May Concern:
“The Entertainment Software Association (“ESA”) submits these comments regarding the rules proposed by the New Jersey Division of Consumer Affairs (the “Division”) implementing the New Jersey Data Privacy Act (the “Act”).
ESA is the U.S. trade association for the video game industry. Our members are the innovators, creators, publishers, and business leaders reimagining entertainment and transforming how America plays video games on consoles, handheld devices, and personal computers. With over 120 video game companies in the state of New Jersey and an economic impact of more than $300 million in the state, ESA’s members support the statutory goals of promoting the privacy and security of consumers’ personal data. ESA urges the Division, however, to make the following revisions to the Proposed Rules to help ensure the rules are consistent with the statutory text and focus on concrete, rather than speculative, consumer harms:
