Different approaches have been taken by governments around the world to remove or facilitate electronic transactions over open networks. One approach is to enact facultative laws intended to make electronic records as legally effective as written records and electronically authenticated records as legally effective as manually signed records. A second approach is to pass laws that regulate particular authentication technologies and infrastructures. A third is to enact laws that extend or adapt existing regulation of transactions to cover electronic transactions.3 Unfortunately, the divergent approaches to removing barriers to electronic commerce create new uncertainties for businesses trying to do e-commerce in multiple jurisdictions, especially if such businesses do not comply with requirements in all jurisdictions.4