SIIA joins multiple organizations representing various sectors have expressed their concerns regarding the Federal Trade Commission’s (FTC) proposed rulemaking to amend the Negative Option Rule. While we have many concerns with the NPRM, at the forefront, the FTC has insufficient legal authority to move forward with the NPRM in in its current form. Furthermore, the cost-benefit analysis is insufficient and fails to provide commentors with sufficient information to analyze the impacts of the NPRM. Moreover, we express strong concerns that many aspects of the NPRM are ambiguous, impractical, and harmful to consumers.