Ms. April Tabor
Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue NW
Mail Stop H–144 (Annex N)
Washington, DC 20580
Re: Negative Option Rule ANPRM, Project No. P064202
Dear Secretary Tabor:
The Entertainment Software Association (“ESA”) appreciates the opportunity to comment in response to the Federal Trade Commission’s (“Commission” or “FTC”) Advance Notice of Proposed Rulemaking regarding the Rule Concerning the Use of Prenotification Negative Option Plans (“ANPRM”). ESA is the U.S. trade association for the video game industry, and 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. ESA submits this comment to share the perspective of its members, which have extensive experience offering a wide array of subscriptions in compliance with the current legal regime.
