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Washington Internet Daily quoted Venable partner Stu Ingis in an article on February, 15, 2013, on NITA's newest mobile privacy draft, which provides updated rules requiring apps to disclose to users what information they collect and with which entities they share the information.

Ingis said the draft "still needs a lot of work" and that it mistakenly concentrates on which third parties receive the data rather than how it is used. He noted that despite the fact that consumers are concerned about how their data is used, discussion of use is "absent from the draft, which I find surprising." The same problem extends to the information-broker term in the list of third parties that receive user data, he said. Ingis explained that "the vast majority of companies are either receiving data from or providing data to other companies," making it difficult to define what makes a broker.

Regarding short-form notices, Ingis said they ought to inform the users of what non-obvious data is being collected. It is more important to tell consumers when apps are collecting data that consumers might not expect will be collected.

In the past, Ingis explained, the code's drafters have decided that short-form notices should include all data elements that consumers might want to be made aware of, even the obvious ones, because it is challenging for app developers to accurately predict which data elements users expect to be collected. He said it is also "premature" for the drafters to decide that icons cannot replace text in short-form notices: "A well-understood icon is a lot more powerful and easier to use" than a long list of text.

Commenting on the draft's preamble, Ingis said it has "a bunch of unsubstantiated assertions that I don't think are particularly useful in this context." He concluded, saying although the stakeholder discussions have focused mostly on the text of the code itself rather than the text of the preamble, the preamble is something he hopes to discuss with stakeholders in the near future.