Category: Google

CDD & Consumer Watchdog ask FTC to Block Google/AdMob Deal and also Protect Mobile Consumer Privacy

News Release
Monday, Dec. 28, 2009

Two Consumer Groups Ask FTC To Block Google’s $750 million Purchase Of AdMob
Deal to Buy Mobile Advertising Company Is Anti-Competitive And Raises Privacy Concerns

WASHINGTON, DC — Two consumer groups today asked the Federal Trade Commission to block Google’s $750 million deal to buy AdMob, a mobile advertising company, on anti-trust grounds. In addition, the groups said, the proposed acquisition raises privacy concerns that the Commission must address.

In a joint letter to the FTC, Consumer Watchdog and the Center for Digital Democracy (CDD) said Google is simply buying its way to dominance in the mobile advertising market, diminishing competition to the detriment of consumers.

“The mobile sector is the next frontier of the digital revolution. Without vigorous competition and strong privacy guarantees this vital and growing segment of the online economy will be stifled,” wrote  John M. Simpson, consumer advocate at Consumer Watchdog  and CDD Executive Director Jeffery A. Chester. “Consumers will face higher prices, less innovation and fewer choices.  The FTC should conduct the appropriate investigation, block the proposed Google/AdMob deal, and also address the privacy issues.”

Last week Google said the FTC has made a so-called “second request” for additional information about the deal indicating the commission is scrutinizing the proposal in great detail.

Besides the anti-trust issues, the letter from the two non-partisan, non-profit groups said, a combined Google/AdMob raises substantial privacy concerns.  Both AdMob and Google gather tremendous amounts of data about consumers’ online behavior, including their location.  AdMob, for example, targets consumers using a wide range of methods, including behavioral, ethnicity, age and gender, and education. In addition to its extensive mobile ad apparatus, Google also provides mobile advertising and data driven analytical services through its DoubleClick subsidiary.  The consolidation of AdMob into Google would provide significant amounts of data for tracking, profiling and targeting U.S. mobile consumers.

Read the letter here: http://www.consumerwatchdog.org/resources/LtrFTCfinal.pdf

“Permitting the expansion of mobile advertising through the combination of these two market leaders without requiring privacy guarantees poses a serious threat to consumers,” the letter said.  It noted that earlier this year several consumer groups, including CDD, petitioned the FTC to specifically protect consumer privacy on mobile phones, especially involving mobile advertising.

Initially Google was able to obtain its dominance in online search advertising largely because of innovative efforts.  It then moved into display advertising through the acquisition of DoubleClick. When the FTC approved that acquisition, the Commission said it would watch developments in Internet advertising closely. Since that deal was approved, the online and mobile ad markets have evolved substantially, with Google becoming more dominant in the Internet ad market.

“The proposed Google/AdMob deal offers the FTC an opportunity to check Google’s increasingly anticompetitive behavior,” Simpson said. “This deal is yet one more example of Google attempting to eliminate a threat to its power.”   “The FTC must protect competition and personal privacy in the key mobile sector,” noted Chester.

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Consumer and Privacy Groups at FTC Roundtable to Call for Decisive Agency Action

Washington, DC, December 6, 2009 – On Monday December 7, 2009, consumer representatives and privacy experts speaking at the first of three Federal Trade Commission (FTC) Exploring Privacy Roundtable Series will call on the agency to adopt new policies to protect consumer privacy in today’s digitized world. Consumer and privacy groups, as well as academics and policymakers, have increasingly looked to the FTC to ensure that Americans have control over how their information is collected and used.

The groups have asked the Commission to issue a comprehensive set of Fair Information Principles for the digital era, and to abandon its previous notice and choice model, which is not effective for consumer privacy protection.

Specifically, at the Roundtable on Monday, consumer panelists and privacy experts will call on the FTC to stop relying on industry privacy self-regulation because of its long history of failure. Last September, a number of consumer groups provided Congressional leaders and the FTC a detailed blueprint of pro-active measures designed to protect privacy, available at: http://www.democraticmedia.org/release/privacy-release-20090901.

These measures include giving individuals the right to see, have a copy of, and delete any information about them; ensuring that the use of consumer data for any credit, employment, insurance, or governmental purpose or for redlining is prohibited; and ensuring that websites should only initially collect and use data from consumers for a 24-hour period, with the exception of information categorized as sensitive, which should not be collected at all. The groups have also requested that the FTC establish a Do Not Track registry.

Quotes from Monday’s panelists:

Marc Rotenberg, EPIC: “There is an urgent need for the Federal Trade Commission to address the growing threat to consumer privacy.  The Commission must hold accountable those companies that collect and use personal information. Self-regulation has clearly failed.”

Jeff Chester, Center for Digital Democracy: “Consumers increasingly confront a sophisticated and pervasive data collection apparatus that can profile, track and target them online. The Obama FTC must quickly act to protect the privacy of Americans,including information related to their finances, health, and ethnicity.”

Susan Grant, Consumer Federation of America: “It’s time to recognize privacy as a fundamental human right and create a public policy framework that requires that right to be respected,” said Susan Grant, Director of Consumer Protection at Consumer Federation of America. “Rather than stifling innovation, this will spur innovative ways to make the marketplace work better for consumers and businesses.”

Pam Dixon, World Privacy Forum: “Self-regulation of commercial data brokers has been utterly ineffective to protect consumers. It’s not just bad actors who sell personal information ranging from mental health information, medical status, income, religious and ethnic status, and the like. The sale of personal information is a routine business model for many in corporate America, and neither consumers nor policymakers are aware of the amount of trafficking in personal information. It’s time to tame the wild west with laws that incorporate the principles of the Fair Credit Reporting Act to ensure transparency, accountability, and consumer control.”

Written statements and other materials for the roundtable panelists are available at the following links:

CDD/USPIRG: http://www.democraticmedia.org/node/419

WPF: http://www.worldprivacyforum.org/pdf/WPF_Comments_FTC_110609fs.pdf

CFA: http://www.consumerfed.org/elements/www.consumerfed.org/File/5%20Myths%20about%20Online%20Behavioral%20Advertising%2011_12_09.pdf

EPIC: www.epic.org

Google’s Teracent Acquisition: Why so-called `Smart’ Ads are on the privacy agenda

Yahoo has its smart ad product; now with its acquisition of Teracent so does Google.  Smart ads learn about you and can dynamically change form so the display ad can better target you.  Here’s how Google explained what the technology can do:

Teracent’s technology can pick and choose from literally thousands of creative elements of a display ad in real-time — tweaking images, products, messages or colors. These elements can be optimized depending on factors like geographic location, language, the content of the website, the time of day or the past performance of different ads.

This technology can help advertisers get better results from their display ad campaigns. In turn, this enables publishers to make more money from their ad space and delivers web users better ads and more ad-funded web content.

We’re looking forward to welcoming the Teracent team to Google and to making this technology available to our display advertising clients — including those who run display ad campaigns on the Google Content Network and our DoubleClick clients.

A Google Online Ad Goal: “engage advertising agencies and brand marketers in programs that move the needle for their companies”

That phrase is part of a Google job ad for a “Display Account Manager” focused on the auto industry  (based in Detroit).  Here’s an excerpt:

You will drive the online video marketplace forward and engage advertising agencies and brand marketers in programs that move the needle for their companies. The primary responsibility of the Display Account Manager is to drive new business revenue for YouTube and other Google display services and products with Fortune 1000 advertisers across multiple industries. You’ll manage business relationships to ensure that your clients’ needs and requirements are met. Additionally, you will be involved in the operational execution of your clients’ campaigns. This role is not for the faint of heart…Identify and execute on new business with new clients and upsell opportunities for existing clients and prospect within accounts and agencies to uncover leads, new contacts, and revenue.

Google+AdMob=Mobile Privacy Issues for the FTC. Questions should be raised about mobile targeting via “ethnicity”

The Federal Trade Commission should examine the privacy issues connected to the Google/AdMob deal.  As we informed the FTC yesterday, AdMob says it can target via “age, gender, HHI, ethnicity, education & context.”

The CDD/USPIRG complaint on mobile advertising provides useful analysis. Here’s an excerpt on its discussion about AdMob:

AdMob: “Mining All the Data We’ve Captured”
AdMob is a “mobile advertising network” seeking to “target mobile users and monetize mobile traffic.” There is inadequate notice and little opportunity to opt-out of this data- gathering. Few mobile users realize that their communications and actions are monitored and recorded in order to create intimate profiles for marketing purposes.
AdMob also targets the youth demographic. It segments “market audiences” into several categories, including a “Digital Natives” category, which include boys and girls as young as 13.  AdMob also focuses on social networking sites, claiming it “enables developers to monetize Facebook mobile applications by integrating AdMob’s industry-leading mobile publishing solutions into any Facebook mobile application. Developers building mobile web applications for the Facebook community using the Facebook Platform for Mobile can easily integrate the AdMob code to start serving ads….”

And AdMob is continually seeking to mine and monetize the data gathered on unsuspecting youths and other mobile users. AdMob’s CEO Omar Hamoui admitted, “We are investing a fair amount of development resources into mining all the data we’ve captured over the last 12 months of ad serving and targeting.”

AdMob gathers this data (and targets youths) without adequate notice to the consumer, making it difficult for a mobile user to weigh the costs and benefits and choose whether to opt out of this profiling. This constitutes unfair and deceptive practices, and the Federal Trade Commission should scrutinize these actions.

“Cookie Wars, Real-Time Targeting, and Proprietary Self Learning Algorithms: Why the FTC Must Act Swiftly to Protect Consumer Privacy”

That’s the title of comments filed at the U.S. Federal Trade Commission by my Center for Digital Democracy and U.S. PIRG.  I also just gave a presentation with the same name at last week’s meeting of data protection commissioners in Madrid, Spain.   It’s available here.

Here’s an excerpt:   Today, consumers online face the rapid growth and ever-increasing sophistication of the various techniques advertisers employ for data collection, profiling, and targeting across all online platforms. The growth of ad and other optimization services for targeting, involving real-time bidding on ad exchanges; the expansion of data collection capabilities from the largest advertising agencies (with the participation of leading digital media content and marketing companies); the increasing capabilities of mobile marketers to target users via enhanced data collection; and a disturbing growth of social media surveillance practices for targeted marketing are just a few of the developments the commission must address. But despite technical innovation and what may appear to be dramatic changes in the online data collection/profiling/targeting market, the commission must recognize that the underlying paradigm threatening consumer privacy online has been constant since the early 1990’s. So-called “one-to-one marketing,” where advertisers collect as much as possible on individual consumers so they can be targeted online, remains the fundamental approach.

Huffington Post CEO Opposes Consumer Privacy Safeguards [HuffPost CEO Eric Hippeau Doesn’t Get Privacy]

File this under “we aren’t concerned about the public interest when it may affect our bottom line.”  At yesterday’s Web 2.0 Summit conference, a panel on the future of news included representatives from HuffPo, Google, the NYT and others.  When a question was asked from the audience about behavioral targeting, here’s what Huffington Post CEO Eric Hippeau said [according to the WSJ]:

“it’s much ado about nothing. “I’d much rather see an ad I’m interested in,” he says. Efforts at regulation are made by people who “don’t get it.”

Shame on Mr. Hippeau.   Perhaps he opposes protecting consumer privacy because it would be inconvenient while his company expands its online ad targeting business.  HuffPost uses a range of online data collection and targeting tools, including Pubmatic for ad optimization, and Admeld. It uses Time Warner’s behavioral targeting subsidiary Tacoda [advertising.com] and also Google’s DoubleClick service.  Here’s an excerpt from HuffPost’s privacy policy:

“The more we know about you, the better we are able to customize our web site to suit your personal preferences and interests… We may also from time to time send you messages about our marketing partners’ products. To maintain a site that is free of charge and does not require registration, we display advertisements on our web site. We also use the information you give us to help our advertisers target the audience they want to reach…the ads appearing on HuffingtonPost.com are delivered to you by DoubleClick, our Web advertising serving partner. Information about your visit to this site, such as number of times you have viewed an ad (but not your name, address, or other personal information), is used to serve ads to you on this site. And, in the course of serving advertisements to this site, third party advertisers may place or recognize a unique cookie on your browser.”
As we have said, we can both protect privacy and also foster the growth of the online ad market.  Mr. Hippeau revealed a starkly uninformed–and crass–dimension to the HuffPo’s corporate leadership.



The “Hidden Persuaders” returns with the growing role of Neuromarketing: “Your message or materials will be absorbed directly into the consumer’s subsconscious” [Annals of Mass Micro-Persuasion]

As we have explained to policymakers in the US and EU, the growing use of neuroscience techniques requires government scrutiny and regulatory safeguards. Even political campaigns appear to be using such methods.  No one should be permitted, in my opinion, to devise any public effort that is designed to deliberately influence the unconscious part of our brain.

Here’s an except from a research paper by a Nielsen backed neuromarketing firm called Neurofocus.   The paper is “Absorption:  How Messages Morph into Meaning And Value in The Mind,” and was written by Dr. A. K. Pradeep.  [published September 2008]

Engagement brings you to the threshold. Absorption carries you beyond, to the state where your message or other material has been fully taken in by the consumer’s brain... Full absorption is also when your message or materials or retail environment, etc. return the highest rate of impact and value for your investment. But neuroscientific research demonstrates that you cannot, and will not, reach that goal consistently and most effectively unless and until you understand how the brain actually functions, and you shape your messages/material /environment accordingly.

For example, as I cited above, we have identified 67 specific ‘best practices’ that should be implemented when words and images are presented on a screen (any screen, from a TV or PC to a mobile phone or movie theater). They are the result of advanced neurological research into various brain functions, and especially research that has delved into the mysteries of diseases like Alzheimer’s, and brain conditions like ADD/ADHD, obsessive/compulsive behavior, and bipolar disorder.

Follow these best practices, give the brain what it wants and likes most, and you stand the best chance of success for your brand and your investment. Your message or materials will be absorbed directly into the consumer’s subconscious, where we can measure them for their effectiveness at the level devoid of any ‘outside’ contaminating influences like education, language, cultural ethnicity or other factors.





What unites Google & Microsoft?—Advancing Behavioral Targeting!

via New Media Age [excerpt]:

AOL, Microsoft and Yahoo are among six industry players to come together for an event to educate the market about behavioural targeting.  The invite-only event on 29 September at Microsoft’s offices is targeted at decision-makers within agencies and clients.

Google, Specific Media and AudienceScience are also involved.

Zuzanna Gierlinska, Microsoft Advertising’s head of Microsoft Media Network… who helped steer the initiative, said the group wanted to help brands feel more confident about behavioural targeting.

“We wanted to get these providers together and take what’s currently been talked about broadly in the industry to the next level,” she said…

The event will cover subjects such as the benefits of behavioural targeting to users and the role of creative agencies.

Online giants unite to offer behavioural targeting tips.  Suzanne Bearne.  New Media Age.  27 August 2009.  sub required

Google & ad giant WPP search for scholars who can help them better target teens, mobile users, and promote pharmaceutical brands

For the second year, Google and global ad conglomerate WPP are searching for academics who will apply for their Marketing Research grants.  A look at some of the topics that are listed as “of interest” should help provide you with a better picture of the `brought to you by interactive advertising’ digital world to come:

excerpt:  Google and the WPP Group have launched the 2nd round of the research program they jointly created to improve understanding and practices in online marketing, and to better understand the relationship between online and offline media…

Topics of interest include, but are not limited to, the following:

Online and offline media interaction

  • How does a brand establish a framework for assessing how much should be spent online? How much advertising should be directed at brand development versus specific click generation?
  • How does offline media affect search and vice versa?
  • What are the best models for mobile advertising?…
  • What are good guidelines for moving traditional video spots from broadcast to broadband?…
  • What is the causal relationship between brand health and search success? And what is the link between search and sales? How does search contribute to word of mouth recommendation?…
  • How do you model the consumer response to digital advertising in social networks or mobile media?…
  • How can advertisers be welcome in social networks?
  • How should online audiences and online marketing tactics be measured in emerging markets – Asia, Eastern Europe, Latin America? Does mobile hold the upper hand over online in some markets?…
  • How do teens interact with digital media and what are the implications?
  • Should heavy internet users be given different treatment than light users?
  • How influential are online influencers and what categories of consumers/behaviors are most affected by them?…
  • How can pharmaceutical brands engage more effectively online? How should marketers approach creative development given the full/risk disclosure requirements?
  • What are the unique marketing and targeting opportunities for other verticals: financial services, insurance, entertainment, consumer goods, retail, etc?
  • How do consumers interact with the mobile web and what are the opportunities for retail (coupons, QR codes, etc) within mobile?…
  • What is inhibiting mobile advertising and how can it be overcome? What is the role of mobile advertising in a new marketing communication strategy?