PayPal

July 22, 2011

Ms.

Jennifer J. Johnson

Secretary. Board of Governors of the Federal Reserve System

20th Street and Constitution Avenue. N.W.

Washington, D.C. 2 0 5

5 1

Via email: [email protected]v

RE;

Docket No. R-1419; Proposed rules regarding global remittance services.

Dear Secretary Johnson:

This letter is submitted on behalf of PayPal, Inc. ("PayPal") in response to the proposed

rule published in the Federal Register on May 23, 2011, regarding consumer initiated remittances

to foreign recipients. The rule was proposed by the Board of Governors of the Federal Reserve

System (the "Board") pursuant to authority granted under Section 1073 of the Dodd-Frank Wall

Street Reform and Consumer Protection Act ("Section 1073") which was signed into law on July

21,

2010 (Pub. L. No. 111-203,124 Stat. 1376 (2010)).

PayPal is a leading online payments company, available in 190 countries, with more than

94 million active user accounts, supporting payments in 25 currencies. Headquartered in San

Jose.

California, PayPal has offices in several states in the United States, along with its

international headquarter in Singapore and European headquarter in Luxembourg. PayPal

payments solution connects into and leverages the traditional payment networks (whether ACH,

bank card networks, or PIN networks) enabling its users to make and receive both personal and

purchase payments in a safe, efficient and cost effective manner.

Currently licensed in 42 U.S. states and two territories as a money transmitter, PayPal

enables cross-border person-to-person payments as well as cross-border commercial payments.

In this capacity. PayPal facilitates both the ability of merchants to accept payments creating a

more global economy, and the ability of consumers to economically transfer funds to friends and

family domestically and abroad. The vast majority (more than 94%) of the payments that PayPal

processes are for commercial purposes.

PayPal appreciates the opportunity to submit the following comments about the potential

implications of Section 1073 and the proposed rule on money transmitters and alternative

payment providers and thanks the Board for its consideration of the concerns and suggestions set

forth below.

I. General Comments

A. The definition of remittance transfers should be limited to consumer-to-consumer

transactions.

The World Bank, in setting forth its General Principles for International Remittance

Services, defines a "remittance" as a cross-border person-to-person payment of relatively low

value. Footnote 1.

World Bank. Payments and Remittances,

http;//siteresources.worldbank.org/INTPAYMENTREMMITTANCE/Resources/New_Remittance_Report.pdf end of footnote.

PayPal recommends that the Board adopt a similar approach in defining remittances in

its final rule. Specifically, PayPal suggests that the Board limit its definition of remittances to

person-to-person payments, and expressly exclude from coverage payments made by a consumer

to a business. This position is extremely important when considering payments companies such

as PayPal which provide a global ecosystem in which users can exchange money almost

instantaneously for the purchase of goods or services, or for a variety of personal reasons.

Today, approximately 84% of the cross-border payments initiated by PayPal users in the

United States are payments for the purchase of goods or services ("purchase payments"),

approximately 10.6% are business-to-business or business-to-consumer payments, while

approximately 5.4% are personal payments. When a transfer is made. PayPal's system moves

funds from the sender's funding source (which may include a balance in the senders PayPal

account) to the account of another user(s) (the recipient(s)). In terms of how the payment is

treated, payments made at a merchant/receiver's Website are identified as commercial payments,

and the receiver always pays the applicable fee. In payments made through PayPal's Website,

the sender has the ability to identify the payment as a person-to-person payment or as a

commercial payment. The sender also has the ability to identify the currency in which the

transfer should take place, and, for personal payments, to choose whether the sender or receiver

will pay the transaction fee. Based on these characteristics, PayPal applies the relevant fees.

If the Board concludes that a cross-border payment made by a consumer in the United

States to a business in a foreign country is subject to the final remittance transfer rules. PayPal

customers would be adversely impacted. For one, all cross-border transfers would now be

subject to the disclosure and error resolution requirements of Section 1073 and the proposed rule.

This could result in increased costs to customers as PayPal and other similar primarily

commercial payment services would have to build out the infrastructure to support these

requirements. Further, PayPal and other similar services, faced with significant negative

consequences under the rules if they miss the designated date for delivering the payment to the

recipient, may set longer delivery periods, resulting in delay and potential confusion for both

buyers and sellers in completing their transactions. And, all of this for no apparent benefit,

because in the case of a commercial payment, it is the merchant that pays the fees associated

with the transaction and therefore, if fee disclosures to the sender are required, the sender has

been provided with a lot of information that is generally meaningless to him or her.

This position becomes even more untenable in the bill payment context (which the Board

acknowledges may be included within the scope of a remittance under the EFTA). If a consumer

initiates a cross-border bill payment and then decides to cancel the payment (perhaps due to a

dispute with the merchant). PayPal as the party facilitating the remittance transfer is the party

that bears the financial cost of the canceled payment under the proposed rule. While PayPal

understands that the Board may be looking to serve the consumer interest in traditional person -

to - person payments, this analysis and protectionism does not make sense in the context of

commercial payments.

In addition to the above, the Board should clarify that the rules don't apply to transfers

that cannot be identified by the remittance transfer provider as cross-border at the time the

transfer is requested, irrespective of whether the recipient is a person or a business. By

specifically soliciting comment on whether there may be situations where a remittance transfer |

provider only has access to the recipient's email address and no other information, the Board has

indicated that it is aware of some of the more technologically advanced remittance forms (such

as a transfer using an email address or a mobile number) and the fact that remittance transfer

providers may not always be able to determine whether a payment is going cross-border. In

these "unilateral" payments, remittance providers such as PayPal do not know the location of the

recipient until they claim the payment (and in some cases the intended recipient never claims the

payment, which is returned to the sender). Applying the disclosure and error resolution

requirements of Section 1073 in these situations would create an undue and unjustified burden on

remittance transfer providers. This is particularly true for remittance transfer providers that don't

impose any cross-border fees on these types of unilateral payment transactions.

Finally, the Board should clarify that where funds are going from one account to another

account, the location of the recipient's account and not the temporary location of the actual

recipient will determine whether a payment is going cross-border. For providers that offer global

services using the Internet, such as PayPal, funds are simply flowing from one PayPal account to

another PayPal account. There is no physical location that a customer walks into to receive its

funds.

Thus, a recipient can access its funds from most countries in the world if he or she has

Internet access, but when the transfer is initiated, PayPal would only know the location of the

recipient from the region/country in which it established its account and provided its address.

Many customers based in the U.S. visit other countries on vacation or business. Accordingly,

PayPal and other similar services would not know to provide the disclosures required by the

proposed rule when initiating a transfer from a US account holder to another US account holder

who is temporarily visiting another country and PayPal would treat the transaction as a domestic

transaction (including for purposes of applying fees).

These points are extremely important when balancing the consumer protection objectives

of Section 1073 with the ability of remittance transfer providers to continue to provide cost

effective, competitive remittance transfer services. This is particularly true for companies such

as PayPal that are engaged in proving cross-border payments as part of their core business, but

have priced and treated person-to-person payments as distinct from commercial payments, with

lower fees for personal payments. Forcing a consumer protection statute on a commercial

payment in the context of a company such as PayPal may in fact negatively impact consumers

making traditional remittance payments, because they may now find their prices increasing to

help absorb the cost associated with compliance for commercial payments.

The Board should carefully consider the disclosure requirements for remittance transfers,

particularly in the context of alternative payment providers and new technological

developments.

Section 205.31 of the proposed rule sets forth various disclosure requirements applicable

to remittance transfer providers. Included within these are requirements as to the form, timing

and content of disclosures.

Specifically, Section 205.31(b)(1) of the proposed rule requires that pre-pavment

disclosures setting forth the following information must be provided to consumers sending

remittance transfers prior to their payment for a remittance transfer: (i) the amount that will be

transferred to the designated recipient in the currency in which the funds will be transferred; (ii)

any fees and taxes imposed on the remittance transfer by the provider, in the currency in which

the funds will be transferred; (iii) the total amount of the transaction, in the currency in which the

funds will be transferred; (iv) the exchange rate used by the provider rounded to the nearest

1/100th

of a decimal point; (v) the amount that will be transferred in the currency in which the

funds will be received; (vi) any fees and taxes imposed on the remittance transfer by a person

other than the provider in the currency in which the funds will be received by the designated

recipient; and (vii) the amount that will be received by the designated recipient in the currency in

which the funds will be received.

Section 205.31(b)(2) further sets forth requirements for receipts provided to senders

which, in addition to the information required by Section 205(b)(

)(i)-(vii). must also set forth:

(i) the date of availability of the funds to the recipient, (ii) the name and telephone number and or

address of the designated recipient (if provided); (iii) a statement regarding error resolution and

cancellation rights; (iv) the name, telephone number and Web site of the remittance transfer

provider, and finally (v) a statement that the sender can contact the state agency that regulates the

remittance transfer provider and the Consumer Financial Protection Bureau for questions or

complaints about the remittance transfer provider.

Per Section 205.31(a)(2), the information required by Sections 205.31(b)(1) and (b)(2)

must be in writing, unless the sender electronically requests the remittance transfer provider to

send the remittance transfer, and must be made "in a retainable form". By way of example, the

Board states that a disclosure provided via the Internet is retainable so long as the consumer is

able to print the disclosure.

1. The Board should allow exchange rale disclosures to he rounded to the nearest 100th

decimal or better so thai remittance transfer providers have the option to provide

more accurate and detailed exchange rate information.

PayPal encourages the Board to expand the exchange rate disclosure required by Section

205.31(b)(iv). Specifically, proposed Section 205.31(b)(iv) requires the remittance transfer

provider to disclose the exchange rate used by the provider for the remittance transfer to the

nearest

1/100th

of a decimal point. PayPal assumes that this disclosure requirement is based on a

desire to provide senders with detailed and consistent information regarding the rate that will

apply to their transfer so that they may compare it to rates provided by others providing similar

services.

PayPal currently discloses the exchange rate used for remittance transfers to the nearest

1/10,000th

of a decimal point. For example, if the exchange rate used for a particular remittance

transfer is $0.0987. PayPal will disclose this rate, which provides greater specificity than is

required or permitted under the proposed rule (under which PayPal would have to round up the

rate to $0.10). While not all remittance transfer providers may have the ability to provide the

exchange rate disclosure beyond

1/100th

of a decimal point, PayPal would recommend that in its

final

rule,

the Board clarify that the exchange rate disclosure must be to the nearest

1/100th

of a

decimal point "or better". This will allow remittance transfer providers that can provide more

accurate disclosures with the ability to do so, without placing an undue burden on other

providers. At the same time, this language will ensure that senders are provided certain

minimum information and are able to engage in meaningful comparison shopping.

The Board should make clear in its final rule that disclosures are "retainable

long as they may be saved or stored by the consumer.

PayPal supports the Board's objective of providing consumers with documentation that

can be kept by the consumer, whether for accounting purposes, to assert errors, or otherwise.

However, PayPal is concerned that the Board' s interpretation of what it means for a disclosure to

be "retainable" is too narrow. Specifically, it is important for the Board to consider more recent

technological developments as well as consumer behavior when considering data retention.

Many consumers today are technologically savvy, and to the extent that they are making an

electronic transfer of funds using either the Internet or a mobile phone (smart phone), it is fair to

believe that they are more inclined to use these tools to help them manage information

electronically rather than printing and storing a paper receipt or disclosure.

In this regard, PayPal would suggest to the Board that it provide examples of data

retention capabilities that include taking and saving a screen shot, or downloading a PDF or

HTML file that can be saved on a computer. It is also recommended that for a transfer initiated

via a mobile phone, the Board allow for disclosure to be available on the phone, accompanied by

delivery of the retainable version of the same disclosure through the Internet, as mobile phones

typically do not allow for printing to an offline device. PayPal believes that the Board is a

proponent of innovation in the payments space and encourages the Board to consider these

options which allow users that choose to leverage technology to make a remittance transfer to

also use technology to retain information related to that transfer.

C. The Board should narrow the definition of an error, introduce consistency in error

resolution processes, and revisit the sender's rights to cancel a remittance.

The Board should clarify that an error does not result from funds not being available

on the stated funds availability date if the non-availability is due to action or inaction

by the recipient or due to a remittance transfer provider's compliance with regulatory

or risk requirements.

Section 205.31(b)(2)(ii) of the proposed rule provides that a remittance transfer provider

must disclose on the receipt provided to the sender the date by which funds will be made

available to the recipient. PayPal is generally supportive of this disclosure requirement and

understands the need for certainty associated with when the recipient will get its funds,

particularly in the traditional person-to-person remittance context. That said PayPal is concerned

with the broad definition of "error" when used in the context of a recipient not receiving funds

by the availability date stated on the receipt. In particular. PayPal notes that there may be

instances where a recipient will not receive funds by the stated date due to some necessary action

on the part of the recipient or because of risk and compliance considerations on the part of the

remittance transfer provider. In these contexts, the failure to meet the funds availability date

should not be considered an error.

By way of example, if a remittance transfer provider has to retain funds without making

them available to the recipient because there is a hold on the account of the recipient or as a

result of the transaction being marked as suspicious by an intermediary or by the remittance

transfer provider's own risk management processes, it may not be able to make funds available

by the stated availability date. In all of these instances, the delay may be considered to be

"within the control" of the remittance transfer provider (thus not subject to the force majeure safe

harbor provision of the rule), but the outcome could not have been anticipated with certainty at

the lime that payment was accepted and a receipt provided to the sender. However, under the

proposed rules, the remittance transfer provider would be liable for refunding to the sender both

the amount of the transfer as well as any associated fees, even in the absence of fault or control,

and apparently even if the recipient has subsequently received the payment a day or two later

than the stated funds availability date.

In these situations, PayPal is confident that the Board along with any other impacted

regulatory agencies would want PayPal (and other remittance transfer providers) to engage in the

appropriate risk management and regulatory compliance practices in which they would normally

engage and are usually required by law to engage. Failure to do so would create greater liability

for the remittance transfer provider and present risk to the financial markets generally.

Additionally, consumers may find themselves disadvantaged as remittance transfer providers

provide themselves with lengthy timeframes to deliver funds to recipients - something that

undermines the business model of many remittance providers who are trying to facilitate quick

payments between family and friends.

In order to better balance these various interests, the definition of error should be limited

to arbitrary delays in the availability of funds, and the safe harbor language proposed by Section

205.33(a)(1)(iv)(A) of the proposed rule should be expanded to include delays resulting from

documented compliance requirements and risk practices.

The Board should shorten the timeframe during which a sender can assert an error

from the proposed 180 days to 60 days.

Section 205.33(b)(1)(i) of the proposed rule provides the sender of a remittance transfer

with 180 days from the stated date of availability of the transfer to assert an error. PayPal

questions the need for such a lengthy period of time for asserting an error.

Specifically, PayPal notes that Regulation E. Section 205.11(b)(1), which also deals with

errors involving electronic fund transfers, provides a consumer with 60 days from the date the

institution sends the periodic statement on which the error appears to report the error. Footnote 2.

12CFR 205.11 End of footnote.

While the

commentary to Section 205.11 (b)(1) does not provide the rationale for the 60 day period, the

Board has clearly determined this time period as being a reasonable amount of time for a

consumer to notice and report an error. In fact, running the 60 day period from the date of the

periodic statement is logical because the consumer has been provided with documentation that

reflects the erroneous account activity and has reason to know that an error has occurred. This

interest is balanced, however, with the institution's need to move forward with certainty that a

specific transaction is accurate and that it can close its books with respect to the transaction.

The 60 day window in Section 205.11 better strikes this balance than the 180 day window

in proposed Section 205.33 because remittance transfer providers are being asked to hold the

liability associated with a transaction for half a year, a full three times longer than what

Regulation E would normally require. Further, to the extent that the remittance transfer provider

is also the provider of non-remittance electronic fund transfers subject to Section

205.11,

the

Board is asking these providers to put in place a whole new infrastructure for dispute resolution

of remittance transfers rather than letting them leverage their existing Regulation E compliant

processes. Footnote 3.

This requirement is even further challenging for remittance transfer providers who may also be the issuers of

credit subject to the Truth in Lending Act and Regulation Z. 12 CFR 226.13. which has its own error

resolution provisions. end of footnote.

PayPal questions the efficacy and need of tripling this timeline for remittance transfers.

In particular, it should be noted that the Board is already requiring remittance transfer providers

to comply with various disclosure and receipt requirements, ensuring that the sender receives all

applicable information at the time that it makes payment and sends a remittance. Included on

this receipt is information regarding the time at which the remittance transfer will be made

available to the recipient, the exact amounts that are going to be sent and received, as well as the

exchange rate that the provider will use. In the case of a majority of remittances, certainly

person-to-person remittances where family members are trying to get money to a friend or family

member quickly, the recipient is highly motivated to notify the sender if the remittance is not

received in a timely manner or in the expected amount. Further, for online services such as

PayPal, the sender can check at any time the status of their transaction including, for unilateral

payments, whether the recipient has claimed the payment, and PayPal automatically returns

unclaimed payments to the recipient after 30 days. PayPal cannot identify any scenario in the

transactions that it processes where the sender would reasonably not know for more than 60 days

whether PayPal has made funds available to the recipient.

It is, therefore, neither necessary nor justifiable that a remittance sender would have so

much longer to report an error than a consumer sending another Regulation E covered electronic

fund transfer. PayPal respectfully requests the Board to re-consider and shorten this time period

in its final rules to be consistent with Section 205.11 of Regulation E. Footnote 4.

It is also important to distinguish remittance transfers where funds may be sitting at the receiving location for a

period of time, awaiting pick up by the recipient, from those situations where the funds are transferred from a

sender's account to a recipient's account, such as would be the case with PayPal initiated transfers other than

unilateral payments. In this latter situation, most transfers would occur almost instantaneously and therefore

having a 180 day window for asserting an error is neither necessary nor justifiable. end of footnote.

Remittance transfer providers should be allowed to recover the costs associated with

a canceled transaction.

Section 205.34 of the proposed rule allows a sender to cancel a remittance transfer within

one business day after making payment so long as (1) the sender's cancellation request enables

the provider to identify the sender's name and address or telephone number along with the

particular transfer to be cancelled and (2) the transferred funds have not been picked up by the

designated recipient or deposited into the recipient's account.

PayPal supports the ability of a sender to cancel a remittance transfer if funds have not

already been transferred to the designated recipient. That said PayPal is concerned about the

Board's proposed requirement that when a legitimate cancellation request is received, the

remittance transfer provider refund the amount of funds tendered by the sender for the

"cancelled" transfer "including any fees imposed in connection with the remittance transfer".

In particular, PayPal is concerned that remittance transfer providers are being asked to

absorb hard dollar costs associated with sending remittance transfers prior to receiving

cancellation requests. Typically, a provider incurs costs for accepting a remittance transfer

request (which costs will now increase with the Board's proposed disclosure and receipt

requirements) even if the sender subsequently decides to cancel the transfer and funds are not

actually moved from one customer to another. While these costs may not equal the full amount

of fees that are associated with a completed remittance transfer, the amounts incurred by the

remittance transfer provider should in fact be retainable by it. To require the refund of all fees,

including actual costs incurred by the remittance transfer provider, may serve as a deterrent to

offering these services, as senders bear no accountability for initiating a transfer and providers

take all the financial burden of providing the remittance transfer service to senders who change

their minds about sending funds. This is particularly unjust where the remittance transfer

provider bears no fault for the cancellation. PayPal recommends that the Board re-consider this

requirement and instead require only that remittance transfer providers have to refund that

portion of any fees which arc not attributable to costs incurred by them prior to receiving a

cancellation request. Footnote 5.

It is also important to note that the Board's proposed rule places undue risk on the remittance transfer provider. On

the one hand, the remittance transfer provider bears liability under proposed Section 205.33 if it fails to make

funds available by the designated date (thereby incenting the provider to build a buffer around this date) and on

the other hand, the provider is liable for all costs associated with accepting a transfer if it is canceled and funds

are still in the provider's possession (thereby incenting the provider to remit funds to the recipient as quickly as

possible). PayPal recommends that the Board give due consideration to balancing the risk and responsibility of

each participant in the transaction and not place an unjustified amount of the burden on the remittance transfer

provider. end of footnote.

4. The Board should offer guidance reconciling the potential conflict between a

remittance transfer provider's role as the provider of credit, electronic fund transfers,

and remittance transfers.

As noted above, the error resolution provisions of proposed Section 205.33 create a new

set of dispute resolution requirements for remittance transfer providers. And. while the new

remittance transfer provisions are included in Regulation E. these new requirements differ from

those typically set forth with respect to electronic fund transfers under Regulation E. Footnote 6.

See 12 CFR 205.6 and 205.11 end of footnote.

This

disparity also exists with respect to the error resolution provisions of Regulation Z governing the

extension of credit. Footnote 7. 12 CFR 226.13 end of footnote.

While it may make sense to have different requirements for errors related

to each of these types of transactions, it is imperative that the Board provide guidance as to what

set of rules will apply in what circumstances, because there will be situations where the provider

of a remittance transfer is also the provider of the credit line or the electronic fund transfer that

was used to fund the remittance. Thus, these providers will need clarity as to what requirements

apply, both so that they are in compliance and so that they can help mitigate any customer

confusion that is sure to arise from these differing error resolution provisions.

Consider, for example, a US$100 remittance transfer initiated through the PayPal system

by a consumer to her mother in Guatemala. The transfer may be funded in part by a transfer

from the sender's PayPal balance and in part using a credit card linked to the sender's PayPal

account or an ACH transfer from the sender's bank account linked to their PayPal account. In

this situation, if the funds are not received by the recipient, and the sender asserts an error, what

set of error resolution rules govern?

Under proposed Section

205.33(f)(1),

a remittance transfer provider must comply with

the error resolution provisions of Section 205.11 governing electronic fund transfers if an alleged

error involves an incorrect electronic fund transfer from the sender's account. However, if the

remittance transfer provider also happens to be the party holding the account from which the

electronic fund transfer is initiated, then the requirements of Section 205.33 will apply. Section

205.33(f)(2) goes on to provide that with respect to errors involving an incorrect extension of

credit in connection with a remittance transfer, Section 226.13 of Regulation Z will apply if the

sender provides notice of the error to the creditor holding the credit card account (even if the

creditor is also the remittance transfer provider). If, however, the sender provides notice of the

error to the remittance transfer provider, then the error resolution provisions of Section 205.33

will apply. Finally, Section 205.33(f)(3) provides that if the alleged error involves an

unauthorized electronic fund transfer for payment in connection with a remittance transfer, then

Sections 205.6 and 205.11 of Regulation E will apply instead of Section 205.33. Similarly, if the

alleged error involves an unauthorized use of a credit card for payment in connection with a

remittance transfer, then Section 226.13 of Regulation Z will apply.

Based on the above, the rights of the remittance transfer sender in the example above will

ultimately depend on what number she decides to call to report the alleged error. If she calls the

customer service number on her remittance receipt, it seems she would get the 180 day window

provided for in Section 205.33(b) of the proposed rule. But, if she called the customer service

line for her PayPal account generally, then she may only have the 60 days provided for in

Section 205.11 to report the error. This result seems confusing and PayPal encourages the Board

to try to drive some clarity and consistency in the application of the remittance transfer error

resolution provisions. Specifically, PayPal would recommend that where multiple funding

sources are used for a remittance transfer the Board make clear that the error resolution

provisions of Section 205.33 will govern. Second, if a remittance transfer provider is serving

multiple roles (for example, providing credit as well as the remittance transfer), then the

remittance transfer provider should have the choice of which set of error resolution provisions to

apply, as long as that choice is clearly disclosed to the sender up front.

This clarity will help with the receipt disclosure requirements set forth in Section

205.31(b)(2)(vi) which may generate some confusion when a customer's receipt notifies them

that they have 180 days to report an error, but they call the provider and report an unauthorized

electronic fund transfer only to learn that they only had 60 days to report it. If remittance

transfer providers are able to determine up front what set of rules will apply (ideally these rules

being consistent as set forth in Section I.C.2 of this letter above), they would be able to provide

clearer disclosure as to the error resolution rights of a consumer, mitigating this customer

confusion.

II.

Conclusion.

PayPal appreciates the opportunity to submit this letter for the Board's consideration in

drafting its final rule. As a major participant in consumer cross-border payments, PayPal is

committed to serving the payments needs of its users in a cost effective and customer friendly

manner. However PayPal has significant concerns that the Board's proposed rule is too broad

and covers transactions that were neither part of the Congressional intent nor necessary from a

consumer protection perspective. Further, PayPal is concerned that the rule places a greater

burden on non-banks than it does on depository institutions. Given that the private payments

industry (and in particular the alternative payments industry) is still relatively young and in a

state of tremendous growth, PayPal would urge the Board to consider all of the comments and

suggestions herein, and to promulgate a final rule that more concisely balances consumer and

industry interests as related to remittance transfers.

If you have any questions or would like to discuss any of the issues raised herein, please

do not hesitate to contact me at (4 0 8) 9 6 7

- 1

2 3 3 or [email protected].

Sincerely,

Signed. John Muller

Vice President and General Counsel

PayPal, Inc.

2 1 1

North First Street

San Jose, C A 9

5 1 3 1