William Carleton

This is a letter to the FTC posted at its online page for public comment on the proposed settlement agreement with Facebook. Because no factual record has been established on which to base a settlement, the letter opposes it…more

Today the House Financial Services Committee approved Rep. McHenry's bill to establish a federal crowdfunding exemption from securities laws. Unfortunately, you have to piece various amendments together to get a look at the…more

Twitter announced changes on March 11, 2011, to the "rules of the road" for its community of independent developers. This announcement has been controversial. The purpose of this redline is to pin down precisely what has changed…more

This is a redline that shows the difference between Senator Leahy's "Combating Online Infringement and Counterfeits Act," as introduced in September 2010, and the same bill as reported on November 18, 2010. Unfortunately, the…more

This document is important in reading and construing the controversial Skype stock option plan…more

This redline shows changes Google proposes to make to its general privacy policy, to be effective in October. The changes are marked against the current privacy policy dated March 11, 2009…more

Foursquare made some subtle but significant changes to its privacy policy. I think this is a sign that social media platforms are figuring out how better to approach setting privacy expectations with users. I will blog on this…more

The US Senate acted last night to strip the financial regulatory reform bill of the provisions in it (Section 412 and 926) that would have devastated startup seed financing and angel investing in America. Hooray!!! The amendment…more

This is a redline comparison to show differences between Facebook's posted privacy policy, dated April 22, 2010, as against a prior version dated November 19, 2009. Some add'l context on this at my blog: http://bit.ly/9bxk8N…more

This is a critical amendment to Sen. Dodd's financial regulatory reform bill. This amendment would save angel investing in America and also preserve the ability of entrepreneurs to raise modest amounts of seed capital using a…more

Congress shouldn't let states define "disqualification" standards for availability of the federal exemption under Rule 506 of Reg D. What needs to happen is that the disqualification standards need to be uniform (i.e. set by the…more

This amendment to Section 926 of Sen. Dodd's financial regulatory reform bill, the Restoring American Financial Stability Act of 2010, would save angel financing for start up companies, while reforming Rule 506 of Regulation D…more

Skype filed its option plan -- it would appear to be the very one subject to the recent controversy over Skype employees whose stock, from the exercise of vested options, was subject to repurchase at cost -- with the SEC as part…more

This is a letter signed by 24 entrepreneurs, investors and attorneys who reside in Washington State and are concerned about the unintended consequences of a draft law being circulated in the U.S Senate that could have adverse…more

Liquidation preferences in venture capital investments have moved north of 1x lately. Is this trend wise, either for investors or early stage companies? This brief post discusses the point and links to other discussions on how…more