===cut=here=== Date: Sun, 26 Sep 93 21:15:13 GMT From: sj@indial1.io.com (Steve Jackson) Subject: Comments on Clipper/Skipjack proposal Steve Jackson, President Sept. 26, 1993 Steve Jackson Games / Illuminati Online PO Box 18957, Austin, TX 78760 512-447-7866 sj@io.com National Institute for Standards and Technology (NIST) ATTN: Proposed FIPS for Escrowed Encryption Standard Technology Building, Room B-154 National Institute of Standards and Technology Gaithersburg, MD 20899 Sirs: I am writing in opposition to the Proposed Federal Information Processing Standard (FIPS) for an Escrowed Encryption Standard, docket # 930659-3159. As a publisher of both printed and online materials, I am deeply concerned by the potential effect of the proposed standard, which appears to me to have been produced in haste and to be lacking many significant elements required for informed citizen comment. I am in strong agreement with the points raised by the EFF and CPSR in their comments opposing the proposed standard. Private access to strong encryption is simply vital to protect the privacy of individuals in today's online environment. Legitimate business requirements for confidentiality also mandate free access to good encryption technology. The manner in which this proposal has been put forward is improper and incomplete. An algorithm intended for private and commercial purposes should not be classified as a "national security matter." And it is wholly improper to ask for meaningful "citizen input" while the algo- rithm itself is secret, the identities of the escrow agents are not firmly established, complete operating procedures are not available, and no legal recourse is yet proposed for the improper release of keys. In particular, the proposal fails to define what "legal authorization," other than a court order, might be available to compel the escrow agents to release a key. This omission is unacceptable. If keys are to be released to any authority except a United States court, the details must be made public immediately. Finally, a strong guarantee is needed that the Clipper/Skipjack system will never become mandatory, and that other forms of encryption will remain freely and legally available to all Americans. The proposal should be withdrawn until all these issues can be addressed. Only then can a legitimate period of citizen comment begin. Respectfully submitted - Steve Jackson ------- End of Forwarded Message