Comment from Laura Cusson

89 Degrees works with retailers, including some manufacturers who will be responsible for being in compliance with this proposed rule. In order to create a unified customer experience, it would be in the interest of the consumer to place product registration within existing consumer opt-in processes. This requires a log-in by the consumer, and allows for ease of use when updating personal information including email address and physical mailing address. An opt-in allows easy access to this tool, while reducing the potential for duplicate records. Furthermore, placing the product registration alongside existing registration mechanisms gives it additional visibility to the end user, making it more likely that consumers will register their products. In order to maintain credibility and security of consumer information, the Commission should not restrict navigation to other pages or web sites. A retailer/manufacturer’s website typically contains global header and footer navigation that also generally includes the company logo. This identifiable mark ensures that the consumer is still on said company’s website and that they have not been redirected to an unsecure 3rd party, where they may not feel comfortable submitting personally identifiable information. In order to minimize the number of times consumers must enter information, as well as streamline information, the Commission should allow the registration process to be incorporated into existing registration mechanisms, including those that may encompass marketing messages, as long as the implementation is extremely clear to the consumer. Lastly, we recommend that an email address be required on the online registration form. This will allow for individual records to be identified to a single household. Without a primary database key, all purchase records for a household may be mismatched when a consumer attempts to update a mailing address in the event of a move.