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REPORT OF THE CHAIRPERSON
INTERNATIONAL TELECOMMUNICATION UNION

EXPERTS MEETING ON ELECTRONIC SIGNATURES AND CERTIFICATION AUTHORITIES:  ISSUES FOR TELECOMMUNICATIONS

 Document No. 6

23 December 1999  

English only  

 

Geneva, 9-10 December 1999  

 

REPORT OF THE CHAIRPERSON

  

            At the invitation of the Secretary-General of the International Telecommunication Union (ITU), a High-Level Experts Meeting on Electronic Signatures and Certification Authorities: Issues for Telecommunications was held in Geneva, December 9-10, 1999. Thirty-four experts, drawn from industry, government, and academia in 14 countries, participated as individuals. A list of participants (Doc. No. 5) is attached.

At the conclusion of their meeting, the experts agreed to a document including a summary of their discussions and their recommendations. That document (Doc. No. 4(Final)) is attached. This report, prepared by the Chairman of the meeting, provides additional information about the experts' recommendations and discussion, particularly regarding those topics that were the subject of considerable attention, but about which there was too little time in a two-day meeting to reach broad consensus. This report also contains the conclusions of the Chairman, and he alone is responsible for its contents.

Introduction to Electronic Signatures and Certification Authorities

            The technologies for providing electronic signatures and certification are many and complex, exceeded perhaps only by the variety of terms used to describe the operations they perform. The concepts, however, are comparatively straightforward, and a brief introduction will help clarify both the subject of the meeting and the material in both the consensus document and this report.

  1. Encryption

            "Encryption" is a way of encoding a message to hide its content. Early military codes are examples of encryption. In the context of computers, encryption is the process of applying a mathematical algorithm to a readable message to generate an unreadable, encoded message. The encoded or encrypted message will appear as gibberish to anyone who should intercept it, but it can be reconverted back to a readable message by anyone who has the appropriate mathematical algorithm. That algorithm is known as the "key" and is usually measured by its length in bits. A longer key (e.g., a 64-bit key) generates a more secure message than a shorter key (e.g., a 40-bit key).

a.       Private Key Encryption

            There are two primary forms of encryption systems in use today. "Private key encryption," also known as "symmetric" or "single key" encryption, relies on a single key to both encode and decode the message. Therefore, anyone with the key can both create encrypted messages and read encrypted messages created with that key.

b.       Public Key Encryption

"Public key encryption," also known as "symmetric" encryption, uses two different keys: one (the "public key") to encrypt the message, the other (the "private key") to decrypt it. The two keys are mathematically linked, but the public key cannot be used to discover the private key (much like two numbers can be multiplied to determine a third number, but knowing that third number does not necessarily make it possible to derive the original two numbers). In a public key system, if A wants to send B an encrypted message, A first obtains B's public key from B or a directory of public keys. A then uses B's public key to encrypt the message, which he sends to B. B uses her private key to decrypt the message.

  1. Electronic Signatures

            An "electronic signature" or "digital signature" (those terms are often used interchangeably) is a way to authenticate the source and in many cases the text of an electronic message. One of the most common ways to do this today uses the public key encryption system ("public key infrastructure"), but in reverse order. If A wants to digitally sign a message that he is sending to B, A first runs the message through a "one-way hash function"¾a mathematical algorithm that creates a unique "message digest" for the message. Every time that algorithm is applied to that message it will generate the same message digest. If, however, the message is altered, then when the algorithm is applied it will generate a different message digest. As described above with public key encryption, however, knowing the message digest will not allow one to recreate either the message or the algorithm.

            Having created the message digest, A then encrypts it with his private key, attaches the original message (which can be unencrypted or encrypted using B's public key), and sends both to B. A has now digitally signed his message to B. B uses A's public key to decrypt the message digest. The fact that A's public key decrypts the message digest shows B that A's private key was used to encrypt the message digest: this helps B verify that A is in fact the sender of the message ("identity authentication"). B can perform the same one-way hash function on A's message to verify that it generates the same message digest. If it does, then the text of the message has not been altered ("content authentication").

            Other forms of electronic signatures are also in use and under development, such as the use of biometric identifiers (retinal scans, fingerprints, etc.). These can be used to authenticate the source of the message, but generally not the content.

  1. Certification Authorities and Digital Certificates

            One critical issue with all current forms of electronic signature systems is establishing a physical connection between the sender (or the signor) and the signature. In the public key example above, the fact that B can use A's public key to decrypt the message digest encrypted with A's private key, tells B that the two keys are linked, but it doesn't actually tell B who A is (just as when a consumer countersigns a traveler's cheque, the fact that the signatures match only tells the merchant that the signor is the same person who signed originally, not who the signor is). This is where a "certification authority" comes in. A "certification authority" is a trusted third party that issues a "digital certificate" attesting to the fact that A is who he claims to be and verifying A's public key does in fact belong to A. Certification authorities must authenticate the identity of their customers (much like a notary must verify the identity of the person whose signature he is notarizing), and must themselves be perceived as reliable.

  1. Repositories

For both public key encryption and electronic signatures to work in their current form, there must be one or more "repositories" where digital certificates and public keys can be found. Today, repositories are generally maintained by certification authorities. In addition to providing information about valid digital certificates, repositories also need to include information about revoked certificates to prevent the continued use of stolen public keys.

5.       Summary

The various functions described above may sound cumbersome, but they take place electronically, usually automatically, in real-time, and without any direct action by, or even knowledge of, the user. When used together, electronic signatures and certification authorities greatly facilitate e-commerce by making it possible to authenticate both the identity of the sender of a message and the content of that message. The ability to do both is critical to conducting high-value transactions via digital networks, especially between parties who have no pre-existing or face-to-face relationship. Electronic signatures and certification authorities have other potential uses, for example, in facilitating electronic voting, or providing authentication of identity and/or message content in many other contexts. The methods described above are not the only ways available for authenticating identity and content. As a result, rather than focus on specific applications of electronic signatures and certification authorities, it is more accurate to speak of "authentication" measures generally and that is how the participants in the expert's meeting generally conceived of their topic.

      6.   Additional Informatio 

            There are many excellent sources of further information about encryption, electronic signature, and certification measures. Two particularly readable and timely sources, on which the above discussion is largely based, are David L. Gripman, "Electronic Document Certification: A Primer on the Technology Behind Digital Signatures," 17 John Marshall Journal of Computer and Information Law 769 (1999), and Sanu K. Thomas, "The Protection and Protection of E-Commerce: Should There be a Global Regulatory Scheme for Digital Signatures?," 22 Fordham International Law Journal 1002 (1999).

 

Summary of Discussion

Mr. Y. Utsumi, Secretary-General of the ITU, opened the meeting. The Secretary-General asked the experts participating to address three questions:

  1. What new technical standards are needed in the area of electronic signatures and digital certificates?
  2.        What approaches can be taken at the ITU and at the international level to respond to the growing trend toward divergent national approaches on the policy and legal aspects of electronic signatures and certificate authorities and to facilitate the use of authentication across borders?

3.       What steps need to be taken by the ITU to address the needs and responsibilities of the telecommunications community in the area of authentication?

Following the recommendation of the Secretary-General, the participants selected Professor Fred H. Cate to chair the meeting. Professor Cate is Professor of Law, Harry T. Ice Faculty Fellow, and Director of the Information Law and Commerce Institute at the Indiana University School of Law-Bloomington, and Senior Counsel for Information Law in the law firm of Ice Miller Donadio & Ryan in the United States.

After introductory remarks by the Chairman and the approval of the agenda (a copy of which (Doc. No. 1) is attached) and the organization of the work of the meeting, the participants heard six presentations on key issues concerning electronic authentication:

1.       Brian Moore, formerly responsible for company-wide standards coordination at British Telecom and currently on contract to Lucent Technologies, and the Chairman of ITU-T Study Group 13, spoke about "The Need for Further Standards and Technical Developments."

2.       Jurgen Schwemmer, Head of Section for Digital Signatures at the German Regulatory Authority for Telecommunications and Post, gave "A National Perspective," focusing on Germany's recent Signature Act, which he is responsible for implementing.

3.       Professor Cate outlined international authentication issues under the heading "The Global Dimension: Cross-Border Recognition of Electronic Signatures, Digital Certificates and Certification Authorities."

4.       Naoshi Shima, Vice President, Multimedia Services and Business Promotion, NEC Corporation, addressed "The Needs of the Business Community," with particular attention to the recommendations of the Authentication and Security Issue Group of the Global Business Dialogue, whose Chairman, Eiichi Yoshikawa, Mr. Shima supports.

5.       Michael Peeters, a Partner and Head of the Technology Law team in the Leeds office of Pinsent Curtis in the United Kingdom, spoke about legal issues and instruments affecting the telecommunications industry under the heading "The View from the Telecommunications Community: Obligations, Liabilities and Responsibilities."

6.       Professor Kazunori Ishiguro, Professor of Law and holder of the Chair of Economic Law: Conflict of Laws at The University of Tokyo, made a brief presentation on standardization issues, particularly in light of the Japanese Ministry of Posts and Telecommunications' document, "Legal Provisions Relating to Electronic Signatures and Certification: Promoting Electronic Commerce and Otherwise Laying the Foundation for Network-Based Social and Economic Activities," which he distributed.

Copies of the written notes and outlines for the presentations were distributed and are attached to this report.

            Arthur Levin of the Secretariat then made some general comments and Stewart Baker then presented the key elements of a briefing paper on Background and Issues Concerning Authentication and the ITU, which he and Matthew Yeo from the law firm of Steptoe & Johnson in Washington, D.C., had prepared for the meeting in collaboration with the ITU Secretariat (a copy of which (Doc. No. 2) is attached). A former General Counsel of the U.S. National Security Agency, Mr. Baker is acting Chairman of the U.S. President's Export Council Subcommittee on Encryption, a member of the Free Trade Area of the Americas Experts Committee on Electronic Commerce, and a member of the UNCITRAL Group of Experts on Electronic Signatures. The participants' discussions were greatly aided by Mr. Baker and Mr. Yeo's briefing paper, which the ITU Secretariat had circulated in advance of the meeting.

            The balance of the two-day meeting was spent discussing the substantive issues concerning electronic signatures and certification authorities. This report highlights nine themes that emerged during that discussion.

1.   Features of the Technology and Rapid Pace of Change

            Many participants noted the distinctive features of the Internet and World Wide Web¾especially the inherently global nature of these media (they are accessed in 205 countries), the absence of centralized control over their use, and the power and convenience they provide people who have access to them. Much discussion focused on the speed with which these technologies have proliferated: First made available to the public in 1992, the Web is used today by more than 171 million people, making it the fastest-growing medium in human history. From 1998 to 1999 the number of Web users world‑wide increased by 55 percent, the number of Web servers increased by 128 percent, and the number of new Web address registrations rose by 137 percent.

            On-line commerce has demonstrated a similar phenomenal expansion. Three years ago, e-commerce was virtually nonexistent. Last year, according to a University of Texas study, the Internet generated US$301 billion in revenue in the United States alone, including US$102 billion in online sales. In July 1999, Nature magazine reported that 83 percent of all World Wide Web sites were commercial.

While many nations, or the states or provinces within a nation, have either taken inconsistent legal actions, or have taken no legal action, to facilitate electronic commerce (see below), both the Internet and e-commerce have nevertheless proliferated. Many participants noted, therefore, that while international action regarding electronic signatures and certification authorities might be beneficial, e-commerce and other online activities are not at a standstill waiting for that action; in fact, any such action will always be directed towards a fast-moving target.

This is not to suggest that international legal action is irrelevant. On the contrary, as participants noted, it is precisely because of international standards that the Internet and World Wide Web have proliferated globally. Without standard formatting and communications protocols, it would be impossible to interconnect disparate computer systems and networks to create the Internet, and information would not flow seamlessly from one system to another as it does today. Rather, participants were mindful that any such action must occur with a real awareness of its technological context.

2.   Features of the ITU and its Current Standard-Setting Activities

            The participants noted a number of unique features of the ITU that are relevant to its future activities relating to authentication measures:

      a.   Make-up of the ITU

            The ITU works extensively with both national government and private industry. Its large and inclusive membership includes 189 Member States and nearly 600 Sector Members, making the ITU the most truly global of all international organizations.

      b.   Experience of the ITU

            The ITU has 134 years of experience in standard-setting and ensuring interoperability; facilitating continued development of the telecommunication infrastructure—an essential conduit for access to the Internet and the World Wide Web—around the world and especially within developing countries; educating industry leaders and regulators alike, often using advanced technologies to deliver that education at great distance; facilitating exchanges of information among and between telecommunications companies and regulators; and dealing with new, rapidly developing technological issues. In fact, the online systems for ensuring that Internet communications are secure¾the essential foundation for electronic commerce¾are based on ITU-T Recommendation X.509.

      c.   Tools of the ITU

            The ITU wields an unusual array of tools, including its standard-setting bodies, policy fora, workshops, international agreements and memoranda of understanding (MoU). These tools can involve global participation from industry and national governments, and a high degree of flexibility in using the appropriate tool to address a wide range of fast-moving issues.

3.   Divergence of National Approaches to Authentication

            Many participants noted the wide variety of approaches to electronic signatures and certification authorities reflected in national and state and provincial law, including recent enactments by Argentina, Chile, Denmark, the European Union, Germany, Italy, Malaysia, and many U.S. states. These enactments often differ on a number of important points:

Ø      Definition of Digital Signature. Some legislation defines digital signatures by technology; some legislation defines digital signatures by attribute or functional criteria (such as "is unique to the person using it" or "is capable of verification").

Ø      Effect of Meeting a Statutory Definition. Some legislation requires that a digital signature conform to a specific definition to be valid; authentication measures not within that definition are invalid under such laws. Other legislation creates a presumption of validity if a digital signature meets the legislative definition, but recognizes that other authentication measures may also be valid.

Ø      Purpose of Digital Signatures. Legislation reflects many different purposes for digital signatures: verifying identity, authenticating the text of a document, ensuring the integrity of the text of a document, indicating consent, establish the legal effectiveness of a document, etc.

Ø      Scope of Application. Some legislation explicitly limits the scope of digital signatures to transactions with the government or to exclude wills and testamentary dispositions.

Ø      Digital Certificates. Some legislation provides specific requirements for digital certificates, including who can issue them, to whom can they be issued, for what purpose, etc.

Ø      Certification Authorities. Some legislation regulates certification authorities: who can be one; how does one become one; what specific activities are required of, or prohibited by, a certification authority; what is the role of the government, if any, in registering, auditing, bonding, and otherwise monitoring certification authorities; and what is the liability (or limit on the liability) of a certification authority.

Ø      Cross-Border Recognition. Some statutes specifically address cross-border recognition of digital signatures and certificates; others are silent on this key issue,

Ø      Beyond Digital Signatures and Certification Authorities. Some legislation amends existing law to provide that "signature" and "writing" requirements can be met electronically. These enactments protect against inconsistency between digital signature legislation and other laws that would appear to require manual signatures or writings.

            There are many other points of disagreement; these points provide only some of the broad categories of divergence among national, state, and provincial authentication laws. And it should be remembered that the majority of nations have taken no action to facilitate the use of electronic authentication measures.

4.   Importance of Harmonization, Not Unification

            There was widespread agreement among the participants that harmonization among these widely divergent national, state, and provincial authentication laws is essential. While the two-day meeting did not provide sufficient time to reach consensus on precisely what form if harmonization was desirable or achievable, many participants suggested that, at minimum, harmonization must include facilitating the use and recognition of authentication measures across borders. At the same time, many of the participants recognized that harmonization could not and should not entail efforts to achieve uniformity among authentication measures.

5.   Key Role of Private Action

            Many participants stressed that harmonization efforts should facilitate the use of different levels and types of authentication measures each appropriate for different uses, the development of new measures, and the use of private agreements, contracts, policies, and other non-technological measures. In sum, government action should facilitate a vigorous, competitive private market for authentication measures.

Many participants also highlighted the importance of ensuring that legal actions on the national and international level not interfere with global Internet communication or with the development of new, effective authentication measures. Thus, laws that require the use of a specific technological measure are highly disfavored, both because of their likely incompatibility with other nation's laws and because of their tendency to slow development of improved authentication measures.

6.   Proliferation of International Activity

            The participants noted the extensive regional and international activity¾involving national governments, intergovernmental organizations, the private sector, and consumer and other not-for-profit organizations¾addressing authentication measures and already attempting to harmonize divergent national approaches. There was widespread agreement among the participants that ITU activities concerning authentication measures should not duplicate those of other organizations, but rather should complement or expand upon those activities.

7.   Broad Range of Issues

            As noted above, there are many legal and other issues associated with authentication measures, but there was widespread agreement that the ITU should focus its future efforts on the tools used for authentication, not on the application of those tools. Whether a digital signature can be used to sign a will or what evidentiary presumption attaches to a legal signature are maters for national law. International efforts are better focused on facilitating the cross-border recognition and interoperability (or, at minimum, compatibility) of the tools necessary for electronic authentication, whatever their legal effect.

8.   Importance of Telecommunications Industry

            Many participants highlighted the importance of the telecommunications industry to authentication issues generally. Telecommunications companies provide the key link (i.e. the conduit) that most people use to access the Internet and the World Wide Web. In addition, the telecommunications industry was one of the earliest providers of authentication measures, including serving as certification authorities. Finally, the telecommunications industry itself relies on authentication measures in its dealings with suppliers and customers.

            All of the participants recognized the ITU's established expertise in dealing with telecommunications issues and with the telecommunications industry. The ITU provides the global legal framework through which all international telecommunications traffic occurs, and it has contributed in many ways to the development of the telecommunications infrastructure throughout the world. Similarly, the ITU is a significant contributor to the capabilities of national telecommunications regulatory authorities and to global discussion of new and critical telecommunications policy, regulations standards, and technology issues. There was widespread agreement that the ITU should focus special attention on the diverse needs and responsibilities of the telecommunications industry with regard to authentication measures, from both a technical and regulatory perspective.

9.   Development and Developing Countries

            Many participants noted the vital issues presented by authentications measures, and by the growth of the Internet and e-commerce generally, for developing countries. The migration of essential activities to digital networks that authentication measures facilitate poses special issues for countries with lower Internet penetration rates. The importance of those issues¾the potential for creating a digital divide between more and less developed countries¾could hardly be overstated. As noted, the ITU has a long history and extensive work currently underway concerning telecommunications infrastructure and issues in developing countries.

Chairman's Recommendations on the Future Activities of the ITU Concerning Authentication  

            The Chairman wholly supports the consensus recommendations reached during the two-day meeting. The fact that there was such broad consensus on so many important issues in only two days is noteworthy.* However, those recommendations are necessarily broad and general, given the press of time and the compromises that are an inevitable part of reaching consensus. The Chairman therefore offers five additional recommendations that flow from the two days of discussion and expand on the consensus recommendations.

1.   Activities with Regard to the Telecommunications Industry

            Given the particular importance of the telecommunications industry to the development and use of authentication measures, and the ITU's vast experience with, and special responsibility for, international telecommunications, the ITU should vigorously pursue activities with regard to authentication in the context of telecommunications. These activities should include not only providing the educational and information-sharing opportunities included in the consensus recommendations and discussed below, but also:

Ø      special attention to electronic authentication issues in the development of ITU telecommunication recommendations;

Ø      efforts to better understand and facilitate the telecommunication industry’s own use of authentication measures, not just in the context of the Internet but also related to other telecommunications services, such as authenticating the identity of a user of a mobile network;

Ø      policy and regulatory fora on issues raised by the telecommunications industry's provision of authentication and Internet access services;

Ø      ensuring that the interests of the telecommunications industry are fully represented in other international discussions concerning authentication; and

Ø      the negotiation of flexible legal instruments, such as memoranda of understanding, to address pressing issues that threaten to restrict the development, provision, and use of authentication measures, as well as other digital information services, within the telecommunications industry.

Although this meeting addressed authentication issues, it is important to note (as many participants did), that the telecommunications industry provides many people's essential link to the Internet. Regulations and unresolved issues that threaten the viability of providing that link, such as the potential threat of liability for carriers for digital content of which they are not aware and over which they exercise no control, impose costs on service providers and users and threaten the availability of both authentication measures and information services more generally.

The ITU's activities concerning authentication in the context of the telecommunications industry should focus not only on the private sector, but also on national regulatory authorities responsible for telecommunications issues. As noted above and in the consensus recommendations, the ITU has vast experience in working cooperatively with, educating, and providing fora for information-sharing among national regulatory authorities, and those activities will be more important than ever in the context of issues posed by digital information.

2.   Standard-Setting Activities

            The consensus report includes a recommendation that the ITU, in close cooperation and consultation with other organizations with related initiatives, should continue and expedite its standard-setting activities relevant to authentication. The importance of this recommendation is worth underscoring. The ITU has unparalleled experience in international standard-setting and dealing with technical issues. Moreover, the size and inclusiveness of its membership gives the ITU an unusually broad perspective and makes it a truly global forum for the consideration of authentication standards. Finally, as noted above, the ITU's membership includes both national governments and private companies, and the ITU has a demonstrated ability to work cooperatively with other governmental and nongovernmental organizations. All of these attributes highlight the importance of the ITU taking a leadership role in crafting the voluntary standards that can serve as the technical basis for national and regional enactments concerning the recognition of foreign digital certificates. Those standards, typical of ITU recommendations, would not address the legal effect of a digital certificate, but instead would provide the essential technical foundation for the operation of those national laws.

            Of course, and as is stressed in the consensus recommendations, the ITU should pursue this activity in close cooperation with other organizations, but it is important to recognize that the wide variety of international activities concerning authentication measures does not create a disincentive for ITU involvement. Rather, the wide array of disparate activities heightens the importance of active ITU participation to provide leadership, a truly global and inclusive forum, and its special competence in technical standard-setting. As noted above, this is not a new area for the ITU. ITU-T Recommendation X.509 is the foundation of international encryption exchanges on the Internet, and other recommendations in this area are in the process of development. That same expertise and process is urgently needed in the context of electronic authentication.

3.   Cross-Recognition Activities

            The consensus report included a recommendation that the ITU, in close cooperation and consultation with other organizations with related initiatives, should investigate and evaluate models for facilitating authentication across borders. This recommendation, too, warrants serious attention. Although many organizations are currently involved in developing models for ensuring the cross-recognition of certification authorities and digital certificates, none of these initiatives takes place in a forum that is as global as the ITU. Clearly, the ITU should not duplicate existing work, but ITU involvement in these activities could provide them with a more universal basis, particularly involving lesser developed countries, which are key participants in ITU organs and processes. The ITU has much to contribute to those initiatives (e.g. those underway at OECD and APEC), including providing a truly global forum for development of frameworks, serving as a repository for model agreements, MoUs and national laws (discussed in greater detail below), and contributing its extensive experience and expertise in the development of flexible, international agreements and consensus instruments.

4.   Forum for Information Sharing, Educational Activities, and Data Repository

            In a number of their recommendations, the experts stressed the critical role of the ITU in providing training, especially in developing countries; a forum for information-sharing about the development and use of authentication measures; and other coordination services, such as maintaining a glossary of key terms and their accepted meanings or of common provisions and formats for evaluating authentication measure’s fitness for their intended purpose. One of the major obstacles to the harmonization of authentication systems is the lack of centralized information about technologies, national laws, international initiatives, model agreements, private sector initiatives, and the like. In addition, for current public key infrastructure systems to work, there needs to be reliable access to accurate information about certification authorities, digital certificates (valid and revoked), and public keys. The ITU is well-placed to serve as a central repository of such data, making them available through the World Wide Web and other means, and incorporating them into the ITU's own educational efforts concerning authentication and other digital information issues. Not only does the ITU have experience in this function, but it also is known throughout the world as the source of information about international telecommunications issues. Expanding that role would provide a great service to national governments, industry, other organizations and initiatives involved in this area, academics, and ultimately to the public

5.   Other Activities

            The Secretary-General convened a High-Level Experts Meeting on Electronic Signatures and Certification Authorities, and the participants' discussion was generally limited to these issues. Nevertheless, it is clear that the very attributes that argue for the ITU to assume a more prominent role in relation to authentication measures, also argue for the ITU to address a wider range of international digital information issues. For example, the world is increasingly divided by two starkly different approaches to information privacy, while the Internet and the World Wide Web are vastly expanding the opportunities for confrontation between those divergent approaches. A truly global approach is necessary, and that will require not only an inclusive forum, but also access to a range of flexible and innovative instruments for achieving the necessary accommodation. The ITU is ideally suited to take on this critical task.

            There are many similarly pressing issues concerning access to, and the use of, the Internet. While all of the participants are aware that the ITU faces serious resource limitations and that the Council and the Secretariat face many competing demands for limited resources, expanding the ITU's activities with regard to digital information issues generally not only provides a valuable service, but also highlights the continuing critical need for the ITU's skills and experience in the next century.

            Respectfully submitted,

 

 
FRED H. CATE
Chairperson

 

 



* There were only two points about which any participant in the meeting asked to have his reservations reflected on the record. Professor Ishiguro objected to the use of the phrase "not to impede" in Recommendation 2(f) and to the omission from Recommendation 3(e) of reference to telecommunications companies' potential liability as one area for particular attention by the ITU. The Chairman assured Professor Ishiguro that his objections would be noted in this report.

 

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