Comment on FR Doc # 2012-20881

-We, the undersigned members of the Fall 2012 undergraduate class for Contract Management, instructed by Dr. John B. Wyatt III, at California State Polytechnic University, Pomona, wish to submit the following comments in response to FAR Case 2011-020, titled “Federal Acquisition Regulation; Basic Safeguarding of Contractor Information Systems”. -Our primary concerns with the proposed rule fall into two specific areas. First, the requirements specified in the proposed rule are not specific enough from a technological standpoint to encompass the current state of information security technology. Those vague requirements do not afford contractors a potentially thorough understanding as to the effect of the proposed rule changes in the areas of potential software acquisition, future software updating, potential hardware acquisition, future hardware device replacement, and emerging technologies. Second, the ambiguities noted above create a condition where small businesses, without in-depth technological expertise, would not be able to adequately estimate current and future information security costs, thereby creating a significant inequitable burden on small businesses to comply with this proposed regulation. - Attached is the complete comment in full detail along with a list of contributors.