Via Electronic Filing
Ms. April Tabor
Office of the Secretary
Federal Trade Commission Suite CC-5610 (Annex B) 600 Pennsylvania Avenue, NW Washington, DC 20580
Re: Commercial Surveillance ANPR, R111004
Dear Secretary Tabor:
November 21, 2022
T he Entertainment Software Association (“ESA”) submits these comments in response to the above-referenced Advanced Notice of Proposed Rule making (“ANPR”) published by the Federal Trade Commission (“FTC”) seeking feedback on potential regulations clarifying whether certain practices are“deceptive”or“unfair”under Section 5 of the FTC Act.
ESA is the U.S. association for companies that publish computer and video games for video game consoles, handheld devices, personal computers, and the Internet. ESA’s members are the innovators, creators, publishers, and business leaders who are reimagining entertainment and how consumers interact, learn, and play