Benjamin Wright
                      Attorney & Counselor
                        3431-1/2 Granada
                    Dallas, Texas  75205-2233
                       Tel: (214) 526-5254
                    73457.2362@compuserve.com

                         August 20, 1996

Thomas J. Smedinghoff, Esq.
McBride Baker & Coles
Chairman of Illinois Commission on Electronic Commerce and Crime


Dear Tom:

     This responds to your letter of July 30 inviting PenOp, Inc.
to comment on the idea that Illinois adopt electronic signature
legislation.

     PenOp supports intelligent law reform in the field of
electronic commerce.  Yet the precise direction that reform should
take is not clear.

     As you know, several states have enacted statutes touching on
electronic signatures.  The striking thing about the statutes is
how many different approaches there are.  We are in a period of
experimentation -- which is healthy.

     The only unhealthy thing we have seen is the anti-competitive
effect of the Utah Digital Signature Act (and its virtual twin in
Washington).  The best example is Section 46-3-403 (Utah Code
Annotated 1996), which grants special status to certain asymmetric
cryptosystems by declaring electronic documents signed with them to
be as legally valid as if they were written on paper.

     To be as legally valid as paper is the aspiration of all
electronic commerce technologies, but absent special legislation
fulfillment of that aspiration is somewhat uncertain.  With Section
46-3-403 Utah wipes away that uncertainty for some asymmetric
cryptosystems, while leaving it in place for all their rivals,
regardless of merit.  This dampens competition and innovation
because it gives an undeserved advantage to one technology.  (With
that stated, we want to add that we believe the people behind the
Utah law acted in good faith.)

     Full competition among technologies is no doubt what the
people of Illinois would prefer.  Any legislation in Illinois
should be even-handed.

     You asked, Tom, for information on PenOp.  Following this
letter are two articles ("Eggs in Baskets" and "Signing Tax Returns
with a Digital Pen") describing PenOp.  Additional information,
including a screencam demonstration, is available at
http://www.penop.com.  PenOp would be pleased to tell you more.  It
also requests permission to present an in-person demonstration to
the Commission.  Please let us know when you hold your next
meeting.

     PenOp, Inc. appreciates the opportunity to comment and would
be pleased to lend further assistance.  Please keep us informed of
the Commission's work.


                              Very truly yours,

                              Benjamin Wright

cc:  Jeremy Newman, PenOp, Inc.