Steve Jackson opposes Clipper FIPS

[L. Detweiler]

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Date: Sun, 26 Sep 93 21:15:13 GMT
From: sj at 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 at 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The proposal should be withdrawn until all these issues can be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



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