SEA Letter to New York Times Editors re Clipper (fwd)

[Simona Nass <simona@Panix.Com>]

I faxed this out last night. The press release is our next step. We are
looking to put together a more detailed, more technologically savvy version
to send to computer mags and stuff. Those who want to help, subscribe to
sea-media-request@panix.com. We can use your help on this next version. -S.

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						Society for Electronic Access
						Post Office Box 3131
						Church Street Station
						New York, NY 10008-3131
						Internet: sea@panix.com
						Phone Contact:
						Steve Barber, (212) 787-8421

						April 23, 1993

Via Fax:  (212) 556-3690

Letters to the Editor
The New York Times
229 West 43rd St.
New York, NY 10036

Dear Editor:

Last week the Clinton Administration proposed a new standard for
encrypting telephone messages and other electronic transmissions (see
John Markoff's articles in the New York Times, "Electronics Plan Aims to
Balance Government Access With Privacy," April 16, 1993, p.  A1, and
"Communications Plan Draws Mixed Reaction," April 17, 1993, p.  35). 
The announcement took by surprise many people who are concerned with the
security and privacy of digital communications.  The Society for
Electronic Access, an organization concerned with civil liberties and
access issues involving computers, believes that the government is
acting with undue speed in its desire to begin widespread use of the
"Clipper chip" in six months, before the full implications of its plans
have been explored.  We strongly believe that more thought and study
should be directed to the government's decision.  In its haste to
mediate between the desire of government agencies to intercept unlawful
communications and the right of citizens to privacy, the administration
may end up promoting a plan that is responsive to neither side. 

Among the issues that raise serious concerns:
 
+ Other encryption techniques currently in wide use have been subjected to 
rigorous public scrutiny, but the "Skipjack" algorithm embodied in Clipper 
is secret. No one knows whether it may contain unforeseen vulnerabilities 
or even deliberately-inserted backdoors for easy decoding. Examination by a 
government-picked panel of cryptographic experts is not sufficient to 
guarantee its security -- and certainly not the abbreviated examination 
that would be possible under the administration's fast-track plan for 
putting Clipper into service. At a very minimum, the Administration has an 
obligation to allow inspection by more independent experts, and to say why 
this scheme must be kept private, while other encryption standards of the 
past two decades have been widely published
 
+ The proposal to hold user's keys in escrow for wiretapping is
inadequately defined.  No one knows who will hold the keys, how they
will protect the key database from illicit access or how a Clipper phone
might be re-secured once its keys have been released for tapping. 
(Consider, by the way, that a magnetic tape cartridge holding keys for
all the telephones in America could fit in a shirt pocket.) Such crucial
issues should be settled before Clipper is even considered. 

+ By throwing its weight behind the Clipper chip, the government appears to 
be unfairly subsidizing a handful of companies at the expense of the rest 
of the U.S. telecommunications industry. (Indeed, others who have attempted 
to develop secure communications equipment have as often as not found 
roadblocks thrown in their way.) The rationale for awarding such an 
enormous potential windfall is unclear. 
 
+ Because the Clipper chip is not intended for export, U.S. companies that 
adopt it could be at a serious disadvantage in international markets. 
They would have to develop and maintain dual product lines or else 
cede the global competition for secure telecommunications to other 
nations.
 
The government should abandon its attempt to rush Clipper-based equipment 
into the market until these and other issues have been addressed. Although 
introduction of the Clipper chip does not (at least at the moment) appear 
intended to foreclose the development and sale of other encryption 
technologies, the government's preferred solution is likely to have a 
strong impact. If it turns out to be vulnerable, or if it impedes the entry 
of U.S. firms into the international market for secure telecommunications, 
both our constitutional freedoms and our economic competitiveness will be 
severely damaged. Any technology that bears such risks must be subjected to 
thorough public scrutiny and open debate before a decision is made on 
whether to adopt it. 


					Sincerely,



					Simona Nass
					President

Board of Directors:

Stacy Horn
Joe King
John McMullen
Simona Nass
Lance Rose, Esq.
Alexis Rosen
Paul Wallich