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Expanding the Wireless Frontier

September 18, 2012

Chairman Julius GenachowskiCommissioner Mignon ClyburnCommissioner Robert McDowellCommissioner Ajit PaiCommissioner Jessica RosenworcelFederal Communications Commission445 12th Street SWWashington, D.C. 20554

Re: Wireless Telecommunications Bureau Seeks Comment on the State of Mobile Wireless Competition, WT Docket No. 11-186

Chairman Genachowski, Commissioners Clyburn, McDowell, Pai, and Rosenworcel:

CTIA is pleased to submit the attached paper, Mobile Commerce: Leveraging Ubiquitous Wireless Connectivity to Put Main Street in the Palm of Your Hand, which highlights the innovation taking place in the mobile wireless ecosystem, and particularly in the rapidly growing segment known as “mobile commerce.” The transformative power of mobile broadband communications has been widely recognized, with the Council of Economic Advisors recently observing that “wireless broadband has the potential to transform many different areas of the American economy, as new wireless technologies give new capabilities to consumers, businesses, and the public sector.” This is unquestionably true in the case of mobile commerce, where mobile broadband is creating new opportunities for commercial activity and enhancing the efficiency of transactions to the benefit of both consumers and businesses alike.

With mobile commerce, consumers have access to the goods and services that they demand wherever and whenever they want them. As the attached paper describes, “[w]ith the opportunity to consolidate what they have to carry, the option of using an already ever-present, ever-connected wireless device to make payments, use coupons, compare prices, and organize payment cards is appealing for consumers.” And businesses are enjoying previously-unimagined opportunities to make available products and to tailor offerings to the needs of their customers. CTIA provides this update on the burgeoning field of mobile commerce to inform policymakers of the innovation and the investments that are being made into the mobile ecosystem by network providers, applications developers, and manufacturers alike and to again highlight the importance of bringing to market additional spectrum, which is the lifeblood of the mobile ecosystem.

The world of mobile commerce has grown exponentially in recent years, and all signs indicate that it will continue to do so. Among the significant developments discussed in this letter, CTIA highlights the following facts:

• Experts predict that mobile commerce in the U.S. alone will reach $11.6 billion in 2012, and may reach $31 billion by 2015.

• The use of mobile devices for purchases during the holiday season increased by 552 percent from 2010 to 2011.

• Over 80 percent of the top 100 U.S. retailers have developed some sort of mobile commerce application.

• All four of the major wireless carriers have partnered with third parties to create mobile wallets using the handsets and devices.

• Mobile commerce applications and services have been used by presidential campaigns, the Olympic Committee, charitable organizations, small businesses and countless others.

As these statistics and the attached paper demonstrate, improving the stream of commerce is yet another way that the competitive mobile wireless industry is enhancing the economy, creating jobs, and delivering value for consumers.

In the last two weeks alone, three publications, The Wall Street Journal, USA Today, and Travel and Leisure each presented robust reports on mobile commerce. The 8-page piece in the Journal was entitled “How to Do Almost Anything on Your Mobile Devices.” The six-page Travel and Leisure piece was entitled “The 60 Best Apps and Websites for Travelers.” And, the USA Today article, entitled “Retailers Introduce Apps for In-Store Navigation,” identified Walmart, Wallgreens, and Home Depot, among others, as companies launching in-store mobile applications. These are just some examples of the attention that these new mobile commerce efforts are receiving from consumers and reporters alike.

This paper details many of the innovations that are making the adoption of mobile commerce possible, including the development of Near Field Communications (“NFC”) technology, credit card readers that attach to smartphones, new payment systems, mobile commerce applications, location based services, and Quick Response (“QR”) codes. Indeed, readers of this letter can access the full paper by scanning the QR code to the right.

Of course, none of this would be possible without robust mobile broadband networks and spectrum. To continue this development of a mobile economy, it is imperative that policymakers redouble their efforts to make available much-needed spectrum. Additional spectrum will be required both to meet rapidly expanding consumer demand and to ensure the robust features and security that U.S. businesses and consumers will require. This paper also reinforces the importance of allowing carriers, manufacturers, and third parties to continue to collaborate, invest, and innovate, providing American consumers and businesses with the wireless services they demand. We look forward to working with you on those efforts, and to advancing our common goal of continued global leadership by the U.S. wireless industry.

Thank you for your consideration, and please let us know if you have any questions.

Sincerely,

Christopher Guttman-McCabe

Vice President, Regulatory Affairs

CTIA–The Wireless Association®

Mobile CommerceLeveraging Ubiquitous Wireless Connectivity to Put Main Street in the Palm of Your Hand

Mobile CommerceLeveraging Ubiquitous Wireless Connectivity to Put Main Street in the Palm of Your Hand

Mobile commerce presents the opportunity to take full advantage

of our nation’s wireless resources to enhance the U.S. economy,

create additional jobs, and deliver value for consumers. Whether

used to access information about products, purchase, or sell,

mobile commerce offerings facilitate and encourage the sort of robust and innovative

economic activity that has become the hallmark of the U.S. wireless industry.

This paper details the rapid growth of mobile commerce, including the following highlights:

Experts predict that mobile commerce in the U.S. alone will reach $11.6 billion in 2012, and may reach $31 billion by 2015.

The use of mobile devices for purchases during the holiday season increased by 552 percent from 2010 to 2011.

Over 80 percent of the top 100 U.S. retailers have developed some sort of mobile commerce application.

All four of the major wireless carriers have partnered with third parties to create mobile wallets using the handsets and devices.

Mobile commerce applications and services have been used by presidential campaigns, the Olympic Committee, charitable organizations, and countless others.

In the last two weeks alone, three publications, The Wall Street Journal, USA Today, and Travel

and Leisure each presented robust reports on mobile commerce. The 8-page piece in the Journal

was entitled “How to Do Almost Anything on Your Mobile Devices.”1 The six-page Travel and

Leisure piece was entitled “The 60 Best Apps and Websites for Travelers.”2 And, the USA

Today article, entitled “Retailers Introduce Apps for In-Store Navigation,”3 identified Walmart,

Walgreens, and Home Depot, among others, as companies launching

in-store mobile applications. These are just some examples of the

attention that these new mobile commerce efforts are receiving from

consumers and reporters alike.

This paper details many of the innovations that are making the adoption

of mobile commerce possible, including the development of Near Field

Communications (“NFC”) technology, credit card readers that attach to

smartphones, new payment systems, mobile commerce applications,

location based services, and Quick Response (“QR”) codes.

Indeed, this paper describes just some of the many ways that the

competitive mobile wireless industry is improving the stream of

commerce, accelerating the U.S. economy, increasing productivity,

creating jobs, and providing a platform for innovation not merely

across the wireless ecosystem, but across the U.S. business and

charitable sectors.

I. Mobile Commerce Has Arrived on Main Street and is Open for Business

Mobile commerce is the “use of wireless handheld

devices such as cellular phones and laptops to

conduct commercial transactions online… The term

includes the purchase and sale of a wide range

of goods and services, online banking, bill payment, information

delivery, and so on.”4 The adoption of mobile commerce has

increased dramatically over a short period of time. The use of

mobile devices for purchases during the holiday season increased

by 552 percent from 2010 to 2011.5 One survey found that 48% of

those surveyed had used their mobile phone to make a purchase,6

and worldwide, mobile payments were expected to total $86.1

billion in 2011, up 75.9 percent from 2010.7 In the United States

alone, sales were projected to top $31 billion by 2015.

Mobile Commerce

Mobile commerce is

the “use of wireless

handheld devices

such as cellular

phones and laptops to

conduct commercial

transactions online…”

Source: eMarketer, Nov. 2011 (*indicates projected value)

Mobile commerce encapsulates several different types of

transactions and interactions, which generally fall into

four major categories: payments, shopping, advertising

and marketing, and commerce apps. Mobile payments involve

a consumer shopping in a traditional brick-and-mortar store, but

paying for their purchases using their mobile devices. This can be

done through direct carrier billing, credit cards, direct access to a

bank account, or a plug-in for the device. Mobile shopping entails a

consumer conducting the entire transaction via a mobile device, from

the browsing to the purchasing and payment. Included in this category

are price comparisons and purchases from retailers’ online sites.

Mobile advertising and marketing leverage the mobile technology for

advertising purposes, through tools such as coupons, geographically

targeted offers, and group deals. Last, mobile commerce apps facilitate

commerce through mobile-friendly interfaces and applications. ABI

Research has estimated that 36 billion apps, which are typically

downloaded as software to a consumer’s mobile device,8 will be

downloaded world-wide this year, and mobile commerce apps are an

increasingly important part of this new economy.

In a 2011 survey, consumers reported using their mobile devices

for a wide variety of mobile commerce activities. The range of uses

demonstrates how pervasive and valued mobile commerce has

become.

Source: Deloitte’s 2011 Annual Holiday Survey

II. Wireless Carriers Are Driving Mobile Commerce Forward

Perhaps the primary catalyst behind the mobile commerce

explosion has been the initiative taken by wireless carriers

and handset developers. Through partnerships with other

carriers, developers, or third parties, CTIA members are

enabling consumers to take advantage of the opportunities and

benefits of mobile commerce.

One such innovative partnership has been the creation of Isis, a

joint venture between AT&T, T-Mobile, and Verizon Wireless that

uses Near Field Communications (“NFC”) technology to facilitate

payments through mobile devices.9 The mobile payment platform

Mobile Commerce

allows consumers to make payments, as well as organize their

payment cards, loyalty cards, and special offers. The program is

anticipated to launch in 2012, with initial roll-out in Austin, TX and

Salt Lake City, UT.10 The technology will be available on devices

manufactured by HTC, LG, Motorola Mobility, RIM, Samsung

Mobile, and Sony Ericsson,11 with point-of-sale terminals provided

by Verifone, ViVOtech, Ingenico, and Equinox.12 Isis will be

compatible with several payment cards, as well as an independent

“ISIS Card” that can be loaded using another form of payment.13

Google Wallet is a similar initiative.14 A joint project with Sprint that

also utilizes NFC technology to create a payment system, Google

Wallet is accepted by twenty-two of the nation’s largest retailers.15

There are currently eight phones that are Google Wallet enabled,16

and Sprint has announced plans to introduce ten new phones

this year that can support the program.17 The system has several

security measures in place to help protect consumers, including

encryption of sensitive information and pin-protected access to the

app and payment options.18

Contactless mobile payments using NFC technology, in which a

consumer simply holds their device over a reader, were deployed

at the 2012 Summer Olympics in London, through a partnership

between Samsung and Visa.19 Using Visa PayWave, another NFC

technology, attendees were able to pay for food, beverages, and

souvenirs with their mobile devices at more than 3,000 terminals

set up throughout the venues.

Another industry initiative that uses mobile commerce to its full

advantage is the short code. Short codes are addresses to which an

SMS or text message can be sent. A short code uses fewer digits

than a traditional seven or ten digit telephone number.20 Common

uses of the short code in the mobile commerce context include

direct carrier billing purchases, and charitable giving campaigns.

Short codes can be used to purchase ringtones, games, or other

services. They have also been used as a way to make donating to a

charitable cause simpler, with great success- in the aftermath of the

2010 earthquake in Haiti, approximately $43 million was donated to

various relief efforts via short code replies.21

The mobile payment

platform allows

consumers to make

payments, as well as

organize their payment

cards, loyalty cards, and

special offers.

Mobile Commerce

Carriers are also working to make mobile commerce easier

for both retailers and consumers. AT&T has partnered with

Digby Mobile to launch Digby Localpoint, designed to aid retailers

in making the mobile commerce experience more successful.22

Digby Localpoint helps retailers to attract buyers to stores, engage

in-store customers, and better understand the behavior of mobile

consumers. By working with retailers, Digby Localpoint aims to

create an effective and interactive experience.

Verizon has teamed up with American Express to create Serve,

a payment system similar to PayPal.23 Serve links your mobile

number to an existing bank account, credit card, or other payment

source. The program also allows a transfer of funds directly

between Serve users. The system can be used at any merchant that

accepts American Express Cards.

These initiatives are just a sample of what the wireless industry has

been working on to fully embrace the mobile commerce concept.

Consumer interest and technological advances are sure to increase

interest in such programs and systems, and wireless carriers and

handset manufacturers are poised to meet that demand.

III. Mobile Commerce Applications

Among the millions of mobile apps available on the

various operating systems, mobile commerce apps

are a burgeoning area where wireless technology is

enabling users to simplify their lives. Indeed, mobile

commerce is one of the areas where apps are used most effectively

and efficiently to create an optimal experience for consumers.

Among the top 100 U.S. retailers, over 80 percent have developed

some sort of mobile commerce application,24 and there are

thousands of apps designed to make the consumer experience

more convenient and enjoyable.

As one recent observer noted in The Wall Street Journal, “[a]

wealth of mobile apps are helping shoppers find the merchandise

they want at the lowest prices available – whether in brick-and-

mortar stores or online – rack up redeemable points, find fleeting

Among the top

100 U.S. retailers,

over 80 percent

have developed

some sort of

mobile commerce

application.

special deals and collect coupons.”25 Just one example of mobile

apps being harnessed to improve consumers in-store experiences

is seen through the Walgreens’ Aisle411 app, which can not only

make shopping lists but then shows the selected items on the

store’s map.26 Consumers are also employing mobile commerce

apps on the road, using a host of new travel apps to calculate their

mileage histories, track loyalty accounts and potential upgrades,

locate flight and seat information, as well as comparing deals on

hotels, airlines, and car rentals.27

A. QR Codes

One of the most popular features in applications is the Quick

Response (“QR”) Code, a two dimensional bar code that contains

information accessible to mobile device users that scan the code.28

QR codes are a substitute to the traditional, one-dimensional bar

code and in comparison can hold a significantly larger amount

of data. The structure and configuration of the code creates

exponentially more capacity.29 The types of data that can be

stored by a QR code are also greater, ranging from text and phone

numbers to URLs and videos.30 The QR code to the right links to

the CTIA Blog when scanned by a mobile handset QR reader. When

combined with a retailer’s other app features, these can be an

excellent tool for enabling quick access.

The codes can be used as a way to direct consumers to the next

step in the transaction. A grocery store provided a demonstration

of the QR code as a gateway when it posted the codes on

advertisements in public transportation terminals.31 Consumers

waiting for their bus could scan the code for the specific groceries

they needed, and the code directs them to the store’s website

where they could make the purchase. The selected items would

then be delivered to the consumer’s home a short time later-

eliminating the step of actually going to the grocery store.

Starbucks has also taken advantage of the QR code, embedding a

unique code into each user’s app.32 By accessing the Starbucks app

and displaying the code within, baristas can scan the code at the

time of the transaction and the consumer’s card will be charged,

without the consumer ever needing to present it.

The types of data that

can be stored by a QR

code are also greater,

ranging from text and

phone numbers to

URLs and videos.

CTIA Blog

Mobile Commerce

B. Location Based Services

Using the location based services of a consumer’s handset, retailers

are able to specifically target offers and services to consumers based

on their geography. Retailers can focus on a geographically relevant

audience when marketing a deal or sale, thereby increasing the

likelihood that the recipient will have an interest in the offer.

One such example is Groupon NOW, a daily deal application for

smartphones that uses the consumer’s current location to offer

immediately usable deals within close proximity.33 A subscriber

can access Groupon NOW to see what deals are available nearby,

purchase the deal through their phone, and then use the deal to get a

discount on lunch, a haircut, or a variety of other goods and services.

IV. Hardware and Devices are Essential to Mobile Commerce

Hardware is an integral part of mobile commerce as

well, primarily by enabling the use of alternative

methods of payment. Near Field Communications

(“NFC”) technology, as mentioned above, is one of the

more prevalent methods, and the attachable credit card reader for

handsets is another commonly used device.

NFC is enabled through a chip embedded in the handset that

stores payment data.34 The chip can be read by NFC point-of-sale

terminals, and as the chip is scanned, the linked bank account or

credit card is charged. As discussed earlier, NFC technology is

becoming more frequently used and offers a convenient alternative

to the traditional payment methods.

The use of attachable credit card readers

has been another hardware initiative in

the mobile commerce space.

The card readers typically attach

to the seller’s smartphone handset

via the headphone jack, and

allow the customer to swipe their

credit card or debit card and make

Attachable Credit Card Reader from Square [https://squareup.com/news]

a payment to the seller.35 This technology allows for payments on

the go, and enables smaller retailers or individuals to accept credit

card payments without the purchase of an expensive point of sale

terminal.

One group that recently took advantage of the opportunities

presented by the use of the card reader was the Girl Scouts of

America.36 The Girl Scouts experimented with the card readers

during the 2012 cookie sale season, providing some troops with

the devices and the accompanying application, Sage, to test out.

The card readers gave customers the option of using a credit card

to purchase their Girl Scout cookies, and the troop leaders could

swipe the cards and even e-mail customers a digital receipt. The

convenience of the smartphone-credit card reader option produced

positive results, as Girl Scout troops that participated in the study

experienced an increase in sales, as much as 13 percent higher than

other non-participant troops in their areas.

Another use of the card readers has been soliciting credit card

donations for presidential campaigns. President Barack Obama

and Republican presidential candidate Mitt Romney are both using

mobile payments to encourage donors by making the process

quick and easy.37 Through the use of the card reader and the

application Square, campaign volunteers are able to collect credit

card donations on the spot. The app then sends the money directly

to the campaign fund. The option to make a donation immediately

appeals to supporters through its convenience, and eliminates the

burden of the traditional processing of donations by campaign

staffers.

Other mobile apps make use of consumers’ smartphone cameras

to improve the shopping experience and deliver greater value. For

example, apps like Barcode Scanner and The Find let consumers

use their smartphone’s camera to scan an item’s bar code and find

out whether the item is available more cheaply at nearby stores or

online.38

Spectrum is critical to

the continued success

of the U.S. mobile

ecosystem, and is

particularly important

for harnessing the

potential of mobile

commerce.

Conclusion

Though still in its relative infancy, mobile commerce

appears to be rapidly growing in adoption, particularly

as consumers value more and more the convenience

of the technology. With the opportunity to consolidate

what they have to carry, the option of using an already ever-

present, ever-connected wireless device to make payments, use

coupons, compare prices, and organize payment cards is appealing.

Experts predict that mobile commerce in the U.S. alone will reach

$11.6 billion in 2012, and may reach $31 billion by 2015.39

The continued growth of mobile commerce will rely on the platform

provided by the competitive and innovative wireless industry.

Carriers are working to build robust and reliable 4G networks. As

CTIA has previously highlighted, even though the United States

accounts for less than 5% of the global population and has less

than 6% of the world’s mobile wireless subscribers, it boasts about

65% of global LTE subscribers as of the third quarter of 2011. This

leadership will help ensure the growth of mobile commerce and is

critical to our continued leadership in the global economy.

Of course, another essential element necessary for the deployment

and use of mobile commerce is access to additional spectrum

resources. Spectrum is critical to the continued success of the U.S.

mobile ecosystem, and is particularly important for harnessing

the potential of mobile commerce. As the stream of commerce

increasingly flows through mobile networks it will be vital to

add spectrum to meet demand and ensure the robust features

and security that U.S. businesses and consumers will require.

The recently-passed legislation authorizing incentive auctions

and the reallocation of broadcast spectrum is an important step

toward meeting our nation’s spectrum needs, but Congress and

the Commission will need to continue to focus on the end goal of

providing more usable spectrum.

CTIA looks forward to working with policymakers to meet those

spectrum needs and to ensure that the U.S. remains a world leader

in the global economy through both mobile broadband networks

and mobile commerce.

Endnotes1 See The Best Way to Do Almost Anything on Your Mobile Devices, Wall Street Journal, Aug. 27, 2012.

2 The 60 Best Apps and Websites for Travelers, Tom Samiljan, Travel and Leisure, Sept. 2012

3 Retailers Introduce Apps for In-Store Navigation, Roger Yu, USA Today, Aug. 29, 2012.

4 Definition of Mobile Commerce, Investopedia, http://www.investopedia.com/terms/m/mobile-commerce.asp#axzz1p7W9OFFa.

5 PayPal: Global mobile payment increased 552 percent on Cyber Monday, Mobile Commerce Daily, Nov. 30, 2011, http://www.mobilecommercedaily.com/2011/11/30/paypal-global-mobile-payment-increased-552-percent-on-cyber-monday.

6 The Mobile Shopping Revolution, Lightspeed Research, Oct. 14, 2010, http://www.lightspeedresearch.com/press-releases/the-mobile-shopping-revolution/. (Survey conducted from August 26-30, 2010, and results based on 3,905 respondents using Lightspeed Research’s Mobile Phone Panel).

7 Gartner Says Worldwide Mobile Payment Users to Reach 141 Million in 2011, Gartner Newsroom, July 21, 2011, http://www.gartner.com/it/page.jsp?id=1749114.

8 See The Best Way to Do Almost Anything on Your Mobile Devices, Wall Street Journal, Aug. 27, 2012 (citing ABI Research estimates that that approximately 36 billion apps are expected to be downloaded worldwide this year).

9 What is Isis?, ISIS, http://www.paywithisis.com/whatis.xhtml (last visited March 28, 2012).

10 Mobile Wallet Isis to be Launched in September, http://www.dailydealmedia.com/789mobile-wallet-isis-to-be-launched-in-september/ (last visited Sept. 10, 2012).

11 HTC, LG, Motorola, RIM, Samsung and Sony Ericsson to Add Isis NFC Tech in Future Phones, Engadget, Sept. 27, 2011, http://www.engadget.com/2011/09/27/htc-lg-motorola-rim-samsung-and-sony-ericcsson-to-add-isis-n/.

12 Isis Scores Point-of-sale Terminal Support, PhoneScoop, March 5, 2012, http://www.phonescoop.com/articles/article.php?a=10011.

13 What Cards Can I Use?, Isis, http://www.paywithisis.com/what-cards.xhtml (last visited March 28, 2012).

14 What is Google Wallet?, Google Wallet, http://www.google.com/wallet/what-is-google-wallet.html (last visited March 28, 2012).

15 Google: Wallet expanding to 10 more Sprint devices this year, Fierce Mobile Content, March 1,2012, http://www.fiercemobilecontent.com/story/google-wallet-expanding-10-more-sprint-devices-year/2012-03-01.

16 Eligible Devices, http://support.google.com/wallet/bin/answer.py?hl=en&answer=1347934 (lasted visited Sept. 11, 2012).

17 Google: Wallet expanding to 10 more Sprint devices this year, Fierce Mobile Content, March 1,2012, http://www.fiercemobilecontent.com/story/google-wallet-expanding-10-more-sprint-devices-year/2012-03-01.

18 How it Works: Security, Google Wallet, http://www.google.com/wallet/how-it-works-security.html (last visited March 28, 2012).

19 Rimma Kats, Visa, Samsung to offer contactless payments during 2012 Olympics, Mobile Commerce Daily, Feb. 27, 2012, http://www.mobilecommercedaily.com/2012/02/27/visa-samsung-to-offer-contactless-payments-during-2012-olympics.

20 About CSCs, Common Short Code Administration, http://www.usshortcodes.com/csc_about.html (last visited April 4, 2012).

21 Elizabeth Woyke, Yes, You Can Still Donate Money to Haiti Via Your Cellphone, Forbes, Jan. 12, 2012, http://www.forbes.com/sites/elizabethwoyke/2011/01/12/yes-you-can-still-donate-money-to-haiti-via-your-cellphone/.

22 Digby Localpoint, AT&T, http://www.wireless.att.com/businesscenter/solutions/industry-solutions/ mobile-productivity-solutions/digby.jsp (last visited April 4, 2012).

23 What is Serve?, Serve.com, http://www.serve.com/about.html (last visited April 4, 2012).

24 Congnizant, The State of Retail Mobility, http://www.flickr.com/photos/fidelman/7299413538/sizes/o/in/photostream/ (last visited Sept. 11, 2012).

25 Find Shopping Deals, Greg Bensinger, Wall Street Journal, Aug. 27, 2012.

26 Retailers Introduce Apps for In-Store Navigation, Roger Yu, USA Today, Aug. 29, 2012.

27 The 60 Best Apps and Websites for Travelers, Tom Samiljan, Travel and Leisure, Sept. 2012.

28 About QR Code, Denso-Wave, http://www.denso-wave.com/qrcode/aboutqr-e.html (last visited April 4, 2012).

29 Id.

30 Jeff Korhan, How QR Codes Can Grow Your Business, Social Media Examiner, Feb. 7, 2012, http://www.socialmediaexaminer.com/how-qr-codes-can-grow-your-business/.

31 Chantal Tode, Peapod, P&G Tap Mobile To Simplify Grocery Shopping For Commuters, Mobile Commerce Daily, Feb. 2, 2012, http://www.mobilecommercedaily.com/2012/02/10/peapod-pg-tap-mobile-to-simplify-grocery-shopping-for-commuters.

32 Starbucks Card Mobile App for iPhone, Starbucks, http://www.starbucks.com/coffeehouse/mobile-apps/starbucks-card-mobile (last visited April 4, 2012).

33 Leslie Horn, ‘Groupon Now’ Provides Instant, Location-Based Deals, PC Mag, May 11, 2011, http://www.pcmag.com/article2/0,2817,2385210,00.asp.

34 NFC and Contactless Technology, NFC Forums, http://www.nfc-forum.org/aboutnfc/nfc_and_contactless/ (last visited April 4, 2012).

35 Zack Stern, Process Credit Cards Anywhere: 5 Smartphone Alternatives, PC World, Dec. 1, 2010, http://www.pcworld.com/businesscenter/article/211924/process_credit_cards_anywhere_5_smartphone_alternatives.html.

36 Chantal Tode, Girl Scouts Add Mobile Payments to Drive Cookie Sales, Mobile Commerce Daily, Feb. 7, 2012, http://www.mobilecommercedaily.com/2012/02/07/girl-scouts-adds-mobile-payments-to-drive-cookie-sales.

37 Nick Bilton, Obama and Romney Campaigns Adopt Square for Funding, New York Times, Jan. 30, 2012, http://bits.blogs.nytimes.com/2012/01/30/obama-and-romney-campaigns-adopt-square-for-funding/.

38 Find Shopping Deals, Greg Bensinger, Wall Street Journal, Aug. 27, 2012.

39 Press Release, US M-Commerce Sales to Grow 91% to $6.7 Billion in 2011, EMarketer, Dec. 1, 2011, http://www.emarketer.com/PressRelease.aspx?R=1008716.

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