E commerce by 1x9O4ms


Electronic commerce (e-commerce) is going to have a profound
effect on the Government, the industry and the community on the
way people live and work. The Internet offers a convenient means
for e-commerce activities as transactions can be conducted almost
anywhere and at anytime the user wants. E-commerce can occur at
any stage of the supply chain, whether within an organisation,
between businesses, and between businesses and consumers. The
major barrier for the wider adoption of e-commerce is on the
concerns about security and the protection of personal data when
transactions are conducted over the Internet. The presence of
supporting infrastructures is extremely important to address the
identities of the parties involved, the integrity and
confidentiality of the information transmitted, and the
non-repudiation and legal status of the electronic transactions.
The Government has built an Electronic Service Delivery (ESD)
Infrastructure to enable the community to obtain public services
through the Internet and other electronic means. Private companies
can also make use of the Infrastructure for the conduct of
To instill public's confidence on the use of electronic
transactions, the Government has taken the lead to establish a
public Certification Authority through the Hongkong Post. The
Hongkong Post has established a Public Key Infrastructure. Through
the use of digital certificates and the public/private keys
mechanism, security and integrity of transactions conducted over
the Internet can be ensured.
The Government is also providing a legal framework through the
Electronic Transactions Ordinance to enhance certainty and
security in the conduct of electronic transactions. The Ordinance
seeks to give electronic records and digital signatures used in
electronic transactions the same legal status as that of their
paper-based counterparts. The other main objective of the
Ordinance is to establish a framework which will promote and
facilitate the establishment and operation of Certification
Authorities in Hong Kong.
A whole series of promotion and educational programmes have been
launched to enhance the awareness of the public and local
enterprises on the use of e-commerce. The Government has been
promoting ESD through roving shows, exhibitions and the launching
of a simulation software to provide hands-on experience for the
Industry support organisations such as the Hong Kong Productivity
Council (HKPC), the Hong Kong Trade Development Council (HKTDC),
the Hong Kong Article Numbering Association (HKANA) are actively
helping SMEs through organising seminars, training and workshops
as well as providing business and technical advisory services
and e-commerce solutions. Please also visit our SME Corner for
the services provided by these organisations.

Preparation for setting up E-Commerce
Setting up E-Commerce through Internet
Related Information

How does E-Commerce create business opportunities
In the 21st century, the rapid development of information
technology and the rapid increase in information exchange have
brought new drives and innovative ideas to the whole society.
The wide adoption of information technology by the community has
led to great changes. These changes are not simply in the context
of data processing or computing. They are changes which affect
how we communicate with each other, how we organise our daily
activities, how we educate the younger generation, and how we
run business. The development and wide adoption of information
technology, computer network and Internet have transformed the
mode of operation of many businesses, and at the same time have
brought along unprecedented business opportunities. Businesses
are now able to conduct transactions across geographical
boundaries, across time zones and at a high efficiency. E-Commerce
has become the market trend of the Century.
What's E-Commerce?
E-Commerce is doing business through electronic media. It means
using simple, fast and low-cost electronic communications to
transact, without face to face meeting between the two parties
of the transaction. Now, it is mainly done through Internet and
Electronic Data Interchange (EDI). E-Commerce was first developed
in the 1960s. With the wide use of computer, the maturity and
the wide adoption of Internet, the permeation of credit cards,
the establishment of secure transaction agreement and the support
and promotion by governments, the development of E-Commerce is
becoming prosperous, with people starting to use electronic means
as the media of doing business.
Benefits of E-Commerce
   · As computer network facilitates information exchange in a
      speedy and inexpensive way, Internet now penetrates into
      almost every corner of the world. Small and medium sized
      enterprises (SMEs) can forge global relationships with their
      trading partners everywhere in the world. High-speed network
      makes geographical distance insignificant. Businesses can
      sell goods to customers outside traditional markets, explore
      new markets and realize business opportunities more easily.
  ·   SMEs who cannot afford establishing overseas offices and
      strongholds can now increase their exposure to every corner
      of the world.
  ·   Businesses can gather information on products, buyers and
      competitors through Internet so as to increase their own
  ·   Businesses can maintain their competitive advantage by
      establishing close contact with their customers and
      consumers at anytime through Internet by providing the latest
      information on products and services round the clock. On
      the other hand, data can be updated at anytime, eliminating
      the problem of out-dated information.
  ·   Internet provides companies with many markets in the cyber
      world and numerous chances for product promotion. Besides,
      relationships with buyers can also be enhanced.
  ·   By the use of multi-media capabilities, corporate image,
      product and service brand names can be established
      effectively through the Internet.
  ·   Detailed and accurate sales data can help to reduce stock
      level and thus the operating cost.
  ·   Detailed client information such as mode of consumption,
      personal preferences and purchasing power, etc. can help
      businesses to set their marketing strategies more

Types of E-Commerce
  · Electronic network within the company: through Intranet,
     people can exchange and handle business information
  · Business-to-Business (B2B) E-Commerce: amongst all other
     types of E-Commerce, this way of doing business
     electronically through Internet or Electronic Data
     Interchange is the one deserves the most attention. As
     estimated by Forrester Research, B2B E-Commerce will grow
     at a rate three times that of Business-to-Consumer E-Commerce
     and thus has the greatest potential for growth.
  · Business-to-Consumer: businesses provide consumers with
     online shopping through Internet, allowing consumers to shop
     and pay their bills online. This type of offering saves time
     for both retailers and consumers.
  · Consumer-to-Consumer: consumers can post their own products
     online through some agent websites for other consumers to
  · Government-to-Citizen: among various kinds of services
     provided by governments, many of them can be done through
    electronic media. Providing public services electronically
    not only provides citizens time-saving and high-quality
    services, but also improves efficiency and cost
    effectiveness. Besides, the move can also promote the
    development of E-Commerce. The Government of the Hong Kong
    Special Administrative Region has launched the Electronic
    Service Delivery (ESD) Scheme on Internet in December 2000,
    providing more than 60 kinds of services round the clock.
    These services include payment of government bills, filing
    of tax return, voter registration, renewal of driving and
    vehicle license, change of personal address etc. For details,
    please visit http://www.esd.gov.hk.
  · Government-to-Business: this mode of trading often
    describes the way in which government purchases goods and
    services through electronic media such as Internet. The
    Government of the Hong Kong Special Administrative Region
    has launched the Electronic Tendering System (ETS) in April
    2000. This system is an infrastructure to provide online
    services such as registration of suppliers, tender
    notification, download facility for tender documents,
    enquiries handling, submission of tender proposals and
    announcement of tender results. For details, please visit

Preparation for setting up E-Commerce
Questions to ask before you go for E-Commerce
What is your objective of setting up E-Commerce?
The objective of setting up E-Commerce in your company directly
affects the scope and investment of developing an E-Commerce
solution. Normally, you want to setup E-Commerce in your company
for the following reasons:
  · To build up corporate image
  · To advertise and promote your products and services
  · To enhance your customer relationship by providing latest
     information and enquiries services
  · To receive orders in electronic form
  · To make online transactions through Internet
  · To establish electronic connection with your business
     partners in order to streamline the business flow
To what extent do you want your company to adopt E-Commerce?
  · Have e-mail accounts for your company and staff
  You can receive general enquiries and orders electronically.
  · Have a website for your company
  You can promote your company image and products through
  · Have a website and process online transactions and payments
  You should consider much more thoroughly on your E-Commerce
      solution, e.g. you should consider the payment method of
      online transactions, the security control mechanisms etc.
   · To establish electronic connections with your business
      partners by the use of Electronic Data Interchange (EDI)
   · You can employ electronic means for ordering, purchasing
      and administration using EDI with other companies.
How much you have to invest?
   · How much will you invest on E-Commerce initially
   Regardless on whether you do it in-house or outsource the project
      to an IT contractor, the initial investment will include
      purchasing hardware and software, leasing a communication
      line and building a computer network, applying for a domain
      name, development costs for designing your website,
      integration services etc.
   · Recurrent cost for your E-Commerce system
   Other than communication line cost and maintenance costs for
      hardware and software, you have to prepare for the cost
      involved in maintaining your website and computer systems.
      Besides, you need to prepare for paying your technical staff
      or outsourced IT contractor.
How to establish security control mechanisms?
The level of security is also a consideration. You should protect
your system against hacking and virus attack. Firewalls, intrusion
detection systems, virus scanning software can be used. Besides,
some security measures such as keeping your user IDs and passwords
secret, changing your password regularly, etc. should also be
adopted. Higher level of security is expected for payment
transactions. If you want to obtain customers' personal
information online, secure transfer and storage of data should
be ensured. A data privacy statement should also be published.
What kind of technical issue you have to consider?
   · The existing hardware in your company
   · The existing software in your company
   · Do you know the technology required for setting up
   · Does your company have sufficient technical staff to support
      the setting up and maintenance of E-Commerce?
   · If you don't have the necessary technical staff in your
      company, outsourcing the implementation to an IT contractor
      will be a good choice.
Setting up E-Commerce through Internet
Connecting to Internet
To get connected to Internet, you need to acquire the service
from an Internet Service Provider (ISP). You can choose an ISP
with service plan best suiting your needs. In terms of connection
method, you can choose either dial-up or broadband connection.
Dial-up connection is slower but costs you less money. In any
case, your ISP will provide the necessary facilities for you to
connect to Internet. ISPs will also provide you with a number
of e-mail accounts to enable you to communicate with your clients
and/or business partners through e-mail.
Where will you host your website?
If you need to setup a website to promote and/or run your business
on Internet, you can host your website in the following ways:
   · Choose a web hosting service provider: if you don't want
     to purchase, install, customise and take care of all the
     necessary hardware and software for running a website, you
     can outsource the task to web hosting companies. Other than
     the hosting services, some companies also provide a one-stop
     shop solution such as ISP service, web design and
     implementation, domain name application, etc.

  · You run your own web server: you can also host your website
     using your own server provided that you have the necessary
     technical staff to plan and take care of all the necessary
     hardware and software.
Apply for a domain name
A domain name is an easy-to-remember name through which your
company can be located easily on Internet. A good and easy to
remember domain name increases the exposure of your company on
Internet and thus has better promotional effect.
Design your website
  · Being informative is one of the successful factors for
     running a website. Besides, you have to organise your content
     in such a way that your potential customers can locate their
     favours easily. A site-map, a good search engine and
     personalization capability will help.
  · You have to keep your contents updated on a regular basis
     in order to retain visitors.
  · Interactive elements in your website will attract visitors
     and bring in more business for you.
  · It is advised that the website should provide a text version
     and/or incorporate accessibility considerations in order
     to cater for the needs of the visually impaired or those
     with slow connection to Internet.
  · You should also consider various means of promoting your
     website, e.g. registering your website with Search Engines
     and web directories, putting banners on popular websites,
     and other traditional advertisement means.
  · One final but important point: you have to respect the
     intellectual property rights of software. Infringement of
     intellectual property rights could be a criminal offense.
Related Information
Hong Kong Productivity Council (HKPC)
The Institute of Information and Media Industries has set up the
DigiHall 21 (website: http://www.digihall21.org) under which
there are several specialized centres. DigiHall 21 is designed
to serve the IT needs of various industries so as to enhance their
ability in adopting E-Commerce. Its content and objectives are
as follows:
   · E-Commerce Centre: the centre assists industries to promote
      their products through E-Commerce. In addition to providing
      chances for local industries to meet overseas buyers, it
      also provides the latest market and technology information.
      Besides, it has set up two websites, namely Hong Kong Product
      On-Line (HKPOL) and Hong Kong Industry On-Line (HKIOL). HKPOL
      provides businesses with secure electronic transactions and
      fast delivery service while HKIOL provides technological
      development on E-Commerce and information on market trends
      and trade laws.
   · Business Intelligence Centre: the centre demonstrates how
      to analyse vast and complicated business data and turn them
      into intelligence information for better decision making
      and productivity enhancement.
   · Enterprise Resource Planning Centre: enables SMEs who have
      joined the programme to use the computer facilities in the
      centre. It helps SMEs to save investment costs on computers,
      thus reaching the goals of cost saving and enhancement of
      operation efficiency.
   · New Media Centre: serves to promote compact disc usage and
      digital printing and publishing. It also helps companies
      to promote their business more effectively. Besides, this
      centre also utilises its Cyber Training Studio to conduct
      real-time interactive cyber training.
   · Software Industry Information Centre: provides software
      industry with support and market information.
   · E-Community Centre: promotes the understanding and
      knowledge on information technology.
Vocational Training Council (VTC)
The New Technology Training Scheme, administered by the Vocational
Training Council, provides assistance to companies that wish to
have their staff trained in a new technology that would be useful
to their business. These technologies include website design and
development, local and wide area network implementation, Chinese
search engine technology, etc. It is funded by interest income
generated from a New Technology Training Fund established for
the purpose.
Hong Kong Trade Development Council (HKTDC)
   · The objectives of HKTDC are to explore new markets for Hong
      Kong companies, to promote Hong Kong's products and services
      in the world market, to promote Hong Kong's leading role
     as an international business, services and information hub
     and to enhance Hong Kong's standing as a partner in global
     business and supporter of free trade. HKTDC also helps
     industries to use Internet to explore both local and overseas
  · HKTDC helps local companies by offering services and
     activities to increase sourcing and selling between Hong
     Kong and the world. One of its main offerings is to design
     services for small and medium-sized enterprises (SMEs) so
     as to help them to stay abreast of the latest business
     techniques, technologies and trends.
  · HKTDC launched its tdctrade.com (website:
     http://www.tdctrade.com) with a totally new interface in
     February 2000. It uses Internet and information technology
     to provide SMEs with market information, trade links,
     E-Commerce services, and online information on buyers and
     suppliers in the global market. It also enables users to
     find business links on web. Besides, it facilitates overseas
     companies to meet Hong Kong industries, to look for business
     opportunities to get into the markets in China and Asia.
     There are some 12,000 Hong Kong companies promoting their
     products and services through the online product catalog
     provided by TDC.
Small and Medium Enterprises (SME) Information Centre
  · This SME Information Centre is administered by the Small
     and Medium Enterprises Office (SMEO) of the Trade and
     Industry Department of the Government of the Hong Kong
     Special Administrative Region.
  · The establishment of this Centre is part of the ongoing
     efforts of the Government to support the SMEs in Hong Kong.
     SMEs are provided with useful business related information
     including the services and facilities offered by various
     government departments and major industry support
     organisations. The ultimate goal is to help SMEs improve
     in competitiveness and enable them to exploit fully the
     benefits of the wide range of supporting services.
Hongkong Post
  · Provide digital certificate for businesses and consumers
     to perform transactions online.
  · The use of Digital Certificates enables both parties of the
     transaction to identify one another.
  · Boost business and consumer's confidence on electronic
  · The HKSAR Government encourages business sector to set up
     its own Certification Authority and apply for voluntary
Hong Kong Article Numbering Association (HKANA)
HKANA provides professional support for Hong Kong industry in
the areas of global electronic identification of goods and
services and of open standard end-to-end supply chain
communication. It encourages all sectors of industry to adopt
and to benefit from E-Commerce technologies through the following
supporting services:
   · Barcode Quality Control Program: the program guarantees
      barcodes used by HKANA's members meet both international
      standards and the criteria of overseas buyers and importers.
   · EZ*TRADE Service: it is a one-stop-shop, standard-based
      electronic commerce service. It was initiated to offer a
      simple, low cost solution for EDI implementation
   · Supply Chain Management Resource Centre: the centre provides
      library facilities, solutions seminars, etc.
Useful links related to E-Commerce:
Doing Business in Hong Kong - http://www.business.gov.hk
Digital 21 - http://www.digital21.gov.hk/
Hong Kong Article Numbering Association (HKANA) -
Hong Kong Industry Internet - http://www.hkindustry.org
Hong Kong Industry On-Line - http://www.hkiol.org
Hong Kong Productivity Council (HKPC) - http://www.hkpc.org/
Hongkong Post - http://www.hongkongpost.gov.hk/
Small & Medium Enterprises (SME) Information Centre -
Hong Kong Trade Development Council (HKTDC) -
Vocational Training Council (VTC) - http://www.vtc.edu.hk/
APEC E-commerce Readiness Assessment Guide -
A Self-assessment on Hong Kong's Readiness for E-commerce
This paper summaries the results of a self-assessment on Hong
Kong's readiness in developing e-commerce by using the Asia
Pacific Economic Co-operation (APEC) E-commerce Readiness
Assessment Guide.
2. The APEC E-commerce Readiness Assessment Guide is a private
sector led initiative. It is a self-assessment tool that can be
used by economies, cities or communities to assess their readiness
to participate in the digital economy. The assessment results
will not only help governments identify actions that may need
to be taken to improve their environment for e-commerce. It will
also facilitate the dialogue between governments and businesses
on the relevant e-commerce policies.
3. The APEC E-commerce Steering Group, which is a standing
committee responsible for the implementation of the APEC Blueprint
for Action on E-commerce, strongly supports this self-assessment
initiative. It actively encourages its member economies to make
use of the Guide on a voluntary basis to carry out the
4. It should be noted that the Guide provides a general framework for analysis within the
economies which utilise the Guide. Its purpose is not for comparison between economies and
that the results are not intended to be scored.
Readiness Assessment
5. Readiness is assessed by determining the standing of the economy in the areas that are most
critical for e-commerce development. The Guide contains six broad indicators of readiness for
e-commerce. They are -
(a) basic infrastructure and technology;
(b) access to necessary services;
(c) current level and type of use of the Internet;
(d) promotion and facilitation activities;
(e) skill and human resources; and
(f) positioning for the digital economy.
In the Guide, these indicators are developed into a series of questions that provide direction as to
desirable policies that will promote e-commerce and remove barriers to electronic trade.
Assessment Results of Hong Kong
6. Hong Kong has conducted a self-assessment on the basis of the Guide. The assessment results
are set out in the Annex

(a) Basic Infrastructure and Technology
7. The results in respect of basic infrastructure and technology confirmed that Hong Kong has an
advanced telecommunications infrastructure. With the progressive liberalisation in the last few
years, our telecommunications market is now characterised by open and effective competition,
voluntary and industry led standards and wide consumer choices. In respect of basic
telecommunications infrastructure, our network has been fully digitised since 1995. The
teledensity in Hong Kong has already exceeded 55%, while over 50% of the population has
access to cable. Currently, about one third of the population in Hong Kong have access to the
8. In respect of the speed and functionality of our infrastructure, broadband access is widely
available. At present, our broadband network covers over 90% of the households and all
commercial buildings in Hong Kong. The maximum connection speed supported by our
infrastructure is 1 Gbps and the average connection speed available is 1.5 Mbps.
9. In terms of terminal equipment, our mobile phone penetration rate, currently at 69%, up from
54% a year earlier, is amongst the highest in the world. The number of personal computers at
home also increased significantly over the last two years, with the penetration rate increasing
from 34% in 1998 to 50% now. In addition, over 99% of our population have a television at
(b) Access to Necessary Services
10. Internet Service Providers (ISPs) play a critical role in the provision of access to the basic
infrastructure and services for content hosting. The affordability of their services has a direct
effect on the penetration of the Internet. In Hong Kong, the ISP market is very competitive.
There are now around 190 ISPs in operation in Hong Kong. Consumers here enjoy the choice of
a wide and sophisticated range of services at competitive prices.
11. A possible area for improvement, however, is related to customs clearance of shipments
entering and leaving Hong Kong. At present, the customs environment is not fully paperless. Only
air cargo can be pre-cleared by electronic data interchange (EDI) through the Customs' Air Cargo
Clearing System. To improve the efficiency of customs clearance of all cargo, the Customs and
Excise Department is examining the feasibility of expanding the use of EDI in pre-clearance of
sea and land cargo as well.
(c) Current Level and Type of Use of the Internet
12. The use of the Internet has become an integral part of our daily lives in Hong Kong over the
last few years. The number of Internet users has grown in leaps and bounds and the Internet is
also used for a wide variety of purposes. Nowadays, consumers in Hong Kong are making use of
the Internet to send e-mails, surf the cyberspace, carry out research and conduct low-value
transactions. We have yet to see many consumers making high-value purchases over the
Internet in Hong Kong. This may mean that consumers have not built up sufficient confidence to
conduct major transactions electronically. Businesses in Hong Kong, on the other hand, are
comparatively more aggressive in the use of the Internet. According to an industry study, over
35% of the companies in Hong Kong are using the Internet in their operation, from marketing,
providing online customer support, enhancing efficiency and conducting transactions
electronically. According to industry estimates, the total value of transactions (both
business-to-business and business-to-consumer) conducted via the Internet in Hong Kong
amounted to US$2 billion in 1999. That figure is expected to grow to over US$70 billion by 2004.
13. To encourage the wider use of the Internet and e-commerce, the Government is committed
to becoming a model user of information technology and to transforming itself into an electronic
Government. In addition to the provision of information through the various Government web
sites, we have launched the Electronic Tendering System in April 2000, to provide a secure
electronic means for handling tender and related matters to support Government electronic
procurement. We will also be launching the Electronic Service Delivery (ESD) Scheme shortly to
provide a wide range of public services to the community through the Internet and other
electronic means. Examples of these online services include the submission of tax return, renewal
of driving and vehicle licenses, payment of Government bills, and registration as a voter, etc. Our
long-term goal is to include all public services which are amenable to the electronic mode of
delivery under the Scheme.
(d) Promotion and Facilitation Activities
14. It is important to carry out promotion and facilitation activities so as to encourage the wide
adoption of e-commerce across the community. The Government has been implementing a
comprehensive programme to enhance public awareness in and understanding of e-commerce.
The major focus of our promotion programme is the local business community, especially the
small and medium sized enterprises (SMEs).
15. The Government works closely with industry support bodies (such as the Hong Kong Trade
Development Council, the Hong Kong Productivity Council and the Hong Kong Information
Technology Federation, etc.) and chambers of commerce in implementing our promotion
programme. Major initiatives under the programme include:-
(a) the organisation of seminars for SMEs to enhance their understanding of and awareness in
(b) the development of practical and readily affordable e-commerce solutions for use by SMEs;
(c) promoting e-commerce through large scale exhibitions (such as the Information
Infrastructure Expo held in Hong Kong each year) and roving shows at convenient public
(d) preparation of reference material on e-commerce, such as success stories and simulation
software, for distribution to SMEs;
(e) production of publicity material (e.g. Announcement of Public Interest on e-commerce) for
broadcast on television and radio to promote e-commerce to the general public; and
(f) establishment of a telephone enquiry hotline to answer questions from SMEs which are
interested in adopting e-commerce and to provide information on the various support services
available from the relevant industry support organisations.
(e) Skill and Human Resources
16. According to the IT manpower study commissioned by the Government, there are currently
44,000 IT practitioners in Hong Kong. However, by the year 2000 there will be a demand for
57,000 IT practitioners, which will further rise to 85,000 by 2005 and 130,000 by 2010. In order
to meet the projected demand and to ensure that we will have the necessary technical expertise
for the development of e-commerce applications and systems, the Government is committed to
strengthening education and professional training in information technology.
17. In respect of basic education, we launched the five-year strategy on "Information Technology
for Learning in a New Era" in November 1998. Under the strategy, we will use IT to turn our
schools into dynamic and innovative learning institutions to develop the capabilities of our
students in processing information effectively and efficiently.
18. Manpower training is another critical factor for the development of e-commerce. In terms of
professional training, our local tertiary institutions are offering around 19,000 full-time
degree-level places in IT-related fields annually. Over 30 new programmes at the diploma,
graduate or post-graduate levels on e-commerce and related subjects have been offered or
planned to be introduced shortly. In terms of vocational training and retraining, the Vocational
Training Council is offering around 17,000 sub-degree level IT places annually, while the
Employees Retraining Board is providing over 44,000 IT related training places each year.
(f) Positioning for the Digital Economy
19. The assessment results indicate that Hong Kong has positioned itself well for the digital
economy in a number of areas, including neutral tax system, support to the extension of the
World Trade Organisation standstill on e-commerce tariffs, the establishment of a clear legal
framework for electronic transactions and the policy in the use of encryption technology.
Although Hong Kong is not a signatory in respect of the World Intellectual Property Organisation
Treaties (WIPO) on copyright and related rights, we have already incorporated in our Copyright
Ordinance the essential provisions on the protection of copyright in the digital environment.
20. In respect of privacy, we are committed to promoting the development of industry
self-regulation in the forms of codes of practice and seal programmes.
21. The same is true for consumer protection. Hong Kong has started to develop self-regulatory
mechanisms such as the Web Trust programme of the Hong Kong Society of Accountants.
Consumer protection for e-commerce in Hong Kong can be further improved if such
self-regulatory mechanisms gain wide acceptance in the industry.
22. The Hong Kong Productivity Council, the Consumer Council and the Office of the Privacy
Commissioner for Personal Data recently jointly developed a guide on best practices for
consumer and privacy protection in web site operation. We have distributed the guide to all ISPs
in Hong Kong and have asked them to further distribute them to their clients, i.e. web site
operators, for reference.

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