IAB creates new post: "SVP, Thought Leadership and Marketing."

As the IAB ramps up its political operation to defend the interactive marketing industry from consumer-friendly privacy safeguards, it has created a new senior position. The SVP for Thought Leadership and Marketing is… “to help drive the growth of interactive advertising through enhanced communications with marketers, agencies, and others about the power of interactive media to reach and influence consumers.” In another words, a seasoned PR hand. David Doty is now in that position; he came from Booz Allen Hamilton where he was Director of Corporate Branding and Creative Services.”

But what IAB requires is “thought leadership” that recognizes that interactive marketing can’t run a-muck. Consumer protections are required, as well as a socially responsible approach to digital advertising in a global environment.

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Cable’s 70/70 Rule & the Public Interest: Programming diversity is what should matter

Our friends and colleagues have worked for years to ensure that the monopolistic-run cable television industry be required to operate in a more competitive and–dare I say–democratic manner. So Bravo! to Media Access Project, Consumers Union, Consumer Federation of America, and everyone else. But the focus of any FCC rules changes should be on how to ensure real programmatic diversity, including shows and channels owned and managed by women and people of color. If all we get is an a la carte system where one can merely pick and choose from the narrow content choices now offered us, then we will not be making real progress. How one should measure success of any cable TV regulatory change should be on what we see on the screen. That’s more important, in my opinion, than a focus on lowering cable rates (or offering new options for cable consumers to block programs and channels they find undesirable).

So as advocates and others consider policy changes, here’s what I suggest we consider. What rules are required so that there are new, unaffiliated, international, national, and local news channels available on cable systems? How can we foster independent programs and channels owned and operated by African-Americans, Hispanics/Latinos, and other groups? What needs to be done to ensure that five to seven years from now, there’s channels reflecting the rich cultural and artistic experience of the country? And, finally, what rules can be enacted that will aid these new media outlets to become sustainable, cross-platform (online, mobile, TV) services? That will require they have access to the full-functionality of cable–and not be placed in some digital backwater.

American Antitrust Institute warns FTC about Google and Doubleclick merger

The AAI sent a report entitled “Google Acquisition of Doubleclick: Antitrust Implications” to the FTC today (November 6, 2007). They noted that “[P]ublicly available information suggests that Google’s acquisition of DoubleClick, which is presently being considered by the Federal Trade Commission and European Commission, raises serious competitive issues under several different antitrust theories. In this white paper, we present some background and brief analysis of the principal competitive considerations under U.S. antitrust law.”

Here’s are some key excerpts (our italics):


“The integration of search, contextual, and display advertising, even if it offers efficiency benefits, may have exclusionary effects if advertisers using rival search engines or advertiser tools cannot replicate the benefits of such integration. For example, post-merger, advertisers using DART for Advertisers or other DART advertiser tools may be unable to get the same quality of access to data and reporting on their search or other campaigns with non-Google search engines or ad networks as they can with Google search or AdSense. Moreover, advertisers that use non-DART advertiser tools may be unable to get the same quality of access to data and reporting on their Google search or AdSense campaigns that is available to advertisers using DART’s advertiser tools. In these cases, Google’s dominant position in search (and contextual) advertising will be further entrenched, and DoubleClick’s leading position in advertiser tools will be cemented. As a result, the lessening of competition in the search market and advertiser tools market may outweigh whatever efficiency benefit may result from integration…Based on the information presented here, AAI believes there is a good argument that Google and DoubleClick are horizontal competitors in two relevant markets. The first is the market for distributing online advertising space of third party (non-search) web sites, where Google’s AdSense is the market leader. The second is the market for publisher ad serving tools, where DoubleClick’s DART for Publishers is the dominant product. While the competition between Google and DoubleClick in these markets may be more potential than actual, the two companies are perhaps uniquely positioned to capture significant market share in each other’s markets. If the evidence confirms that these markets are concentrated and that entry is otherwise difficult, as appears to be the case, then the merger presents a relatively straightforward case for challenge under the horizontal and non-horizontal merger guidelines. We see little in the way of merger specific efficiencies that would offset the loss of competition…If foreclosure were the only issue, it might be resolved by placing conditions on the merger, even though there are costs involved in enforcing a regulatory decree. But unless the horizontal concerns are rebutted, AAI believes that the prudent course is for the FTC to block the merger.”

UK trade magazine reports on Google’s “sheer dominance.”

key excerpts from New Media Age, 11/1/07. “NMA Report – Competition.” Greg Brooks. Sub. required:
“One of the biggest problems facing search engines is Google’s sheer dominance of the sector. How have the latest moves from Yahoo! and Microsoft affected this?

Google’s domination of the UK paid-search market has gone unbroken since AdWords burst onto the scene in 2000. Advertisers would like nothing better than to see some healthy competition for their search budgets. But six months since Yahoo! introduced Panama, and over a year since Microsoft launched AdCenter in the UK, Google’s grip is tighter than ever…
“Google’s lead in terms of volume continues to grow, as the latest statistics from Hitwise show (see graph). Agencies say it’s the only must-have for clients…

The emergence of Panama is a strong indication that a competitive market is driving improvements to relevancy and forecasting. But it remains to be seen if anyone can challenge Google’s position,” says Michael Stroud, head of online marketing at Lloyds TSB…

Daniel Kerzner, regional director for north-west Europe at Starwood Hotels, adds, “Google remains a solid, reliable volume driver for us. Its dominance is a potential threat to business, however, if it continues to exploit its lone position in the marketplace”…

…the figures don’t make a pretty picture for Google’s rivals. Hitwise data for September 2007 shows that Google handled 85.2% of all searches in the month, with Yahoo! on 4.91% combined, Microsoft own-brand search commanding 3.95% of search, and Ask.com down to 3.55%…

“AdCenter has tried to leapfrog Google with more targeting features to drive efficiency, but has left basics like attracting more customers behind,” says Paul Bongers, head of paid search at BT, which uses Zed to plan and buy its search campaigns. “You can have the greatest search engine in the world, but if the customers aren’t there it won’t matter…
So far the new features haven’t enabled Yahoo! and MSN to gain on Google, which has actually increased its dominance of UK searches

Google Becomes a member of the Nielsen "family." Threats to our Privacy as we watch TV

Few readers may recall when Norman Lear’s “Mary Hartman” realized that she and her fellow patients at a psychiatric facility watched a Nielsen ratings-connected TV set. Lear’s critique that the TV rating system that has determined success for the TV business is deeply flawed and–frankly, crazy– is still true. But Google (and Doubleclick’s) move to monitor and analyze our viewing on TV and other platforms is just as insane–if we want to protect our privacy. “Google has been reporting millions of second-by-second data points to its TV Ads clients,” explains MediaDaily News. “Ultimately, Google expects TV’s interactive capabilities to improve to the point that it is generating the same kind of immediacy and backchannel as the Internet.” [from an interview with Mike Steib, director of Google TV Ads].

We doubt cable and DBS subscribers recognize that they are now involuntary members of the Nielsen/Google data tracking combine. Here’s how Multichannel News reports on the deal: “By combining Nielsen demographic data with aggregated set-top box data, Google plans to provide advertisers and agencies with comprehensive information…We have millions of set-top boxes that belong to EchoStar from which EchoStar is pulling data and is providing it to us for the Google TV Ad system: It’s a lot of data points,” Steib said…Advertisers can better understand exactly how their ad is performing and make near real-time changes to their TV advertising campaigns to deliver better ads to viewers, according to Google.

“One of the things we haven’t been able to provide to our advertisers to date, when we report back the very next day the impressions that they’ve received from the set-top boxes, we have not yet reported demographics and audience composition,” he said. “We are now going to be able to make that information available to our advertisers”…Google and Nielsen claim that as a result of their new partnership, this is the first time that advertisers and agencies will have such a level of detailed measurement available in a single place and at such a large scale.”

We hope Congress and the FTC will step in to prevent the entire TV viewing population from becoming involuntary drafted into the Nielsen/Google data collection, profiling, and targeting system.

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Google & DoubleClick Mobile [plus Jaiku]=a Dart to Privacy

DoubleClick is promoting, via full-page ads in the U.K. trades, its new DoubleClick Mobile service “Introducing a new way to serve ads on small screens,” touts the copy. It goes on to say that online marketers can “[U]se Doubleclick Mobile to sell and managage mobile advertising with the same team and tools you use for your display and rich media business.” Here’s what DC’s “Mobile Overview” tells marketers [excerpt]: “As you engage your audience on the mobile platform you have the opportunity to take control of your revenue and operations with DoubleClick Mobile. You can capture more dollars from your mobile content by adding dynamically served mobile display ads and destination offers…Just as online banners are uploaded into DART, mobile banners and mobile companion jump pages are uploaded into and served by DART. Mobile specific targeting criteria can be set within the DART interface, including content, device and capability targeting…DoubleClick Mobile helps you deliver ads to mobile devices worry-free through our database of over 3,000 handsets indetifying each device’s unique screen size and capabilities…”

On its website, DC says that its Mobile service allows marketers to “[S]et mobile-specific targeting criteria for dynamically served mobile display ads, including content, device and capability targeting.” In the UK, DC explains that: “DoubleClick Mobile tracks impressions, third party impressions, clicks and jump page conversions. Tracking mechanisms meet the unique requirements for mobile delivery, and care has been taken to ensure compliance with network operators.”

Pixelating Privacy: Here’s what ClickZ said about the new DC mobile service: “DoubleClick Mobile aims to bring “a lot of heavy iron” [said DC VP Ari Paparo] to the developing marketplace for ads on handsets. The product is capable of pairing ads with content…In addition to standard mobile display ads, it supports ad formats such as combination ads and roadblocks. Through pixel-based ad tracking, agencies and other third parties can access campaign performance data through their own campaign reporting systems.”

Finally, we think Google’s new acquisitions (such as Zingku] in the mobile area bear examining, esp. for privacy implications. Google also just bought Jaiku, a Finnish company. Here’s how Jaiku describes its service: “Jaiku’s main goal is to bring people closer together by enabling them to share their activity streams. An activity stream is a log of everyday things as they happen: your status messages, recommendations, events you’re attending, photos you’ve taken – anything you post directly to Jaiku or add using Web feeds. We offer a way to connect with the people you care about by sharing your activities with them on the Web, IM, and SMS – as well as through a slew of cool third-party applications built by other developers using our API.

The most powerful instrument of social peripheral vision is your mobile phone. We’ve put in a special effort to create Jaiku Mobile, a live phonebook that displays the activity streams, availability, and location of your Jaiku contacts right in your phone contact list. We modestly believe it is the best solution out there for seeing what your friends are up to.”

The future is now calling. Will we act to protect our privacy?

Yahoo! No Competitor for Google (and neither is MSN!)

excerpt from: “Yahoo Worth More Divided Or Sold: Analyst”

YAHOO’S VALUE WILL NOT BE unleashed until it is broken up or sold, Sanford C. Bernstein & Co. analyst Jeffrey Lindsay said in a research report last week. “To stop the inevitable slide into irrelevance, the management team must consider more radical actions and strategies,” Lindsay wrote. “Incremental changes to rebuild revenues simply won’t cut it this time.”…
Yahoo could be broken into ad and subscription businesses to reach his $39-a-share estimate, Lindsay wrote.”

article by Laurie Petersen, executive editor, MediaPost.

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Reading the Google merger tea leaves in the trade press

Just for the record, here are 3 excerpts from trade articles we believe are relevant to the merger review.

1. “Ad networks given last chance to question Google-DoubleClick deal” [NMA Magazine (UK). 13.09.07]

British ad networks have expressed strong concerns to the EU over the $3.1bn (£1.53bn) Google buyout of ad serving giant DoubleClick. As the deadline for responding to the European Commission’s Directorate on Competition draws near, the industry warned that there would be problems with the merger…Networks have responded to consultation from the Commission about any problems they have with the merger deal, announced in April. This is the last formal way for companies to express their concerns with the merger, although some remain cynical as to whether it will make any difference.

Phil Nott, sales director at Adrevenue, said networks should still send through their objections. “People have accepted this is going through too easily. If they knew they could send in their views and get a chance to block it, then maybe more would speak up about their concerns.”

2. Do Home Pages Have a Place in Web 2.0’s Future? Advertising Age. Oct 1, 2007.

“The report, out today, will serve as a “sanity check” for some early Web 2.0 adopters and technophiles. And, he said, “for more traditional marketers, there’s a whole new world we have to introduce them to.” One of the most surprising things the team found was how many people are starting their online shopping with search — more than 54% of the study’s panel, in fact. The idea that more consumers are coming to brand sites through the side door of search means search engines are starting to circumvent brands when it comes to online shopping. While a consumer looking for a pizza stone offline might drive to her nearest Williams-Sonoma, in the online world she’s more likely to just type the product name into Google and see what comes up.”

3. “Out of the Box: More Than Nine Billion Videos Served.” Brandweek. October 01, 2007
In July, Americans viewed more than 9 billion videos online, according to comScore’s Video Metrix report. Nearly 75% of U.S. Internet users watched an average of three hours of online video during the month.

Google Sites topped the July rankings with the most unique viewers and most videos viewed. Nearly 2.5 billion videos were viewed there (a 27% share of videos)—a full 2.4 billion at YouTube.com. Yahoo! Sites ranked second with 390 million (4.3%), followed by Fox Interactive Media with 298 million (3.3%) and Viacom Digital with 281 million (3.1%).

Doubleclick Does Mobile Ad Collection/Targeting. Waiting for GooglePhone?

excerpt: “DoubleClick Mobile will integrate with DART for Publishers to provide ad trafficking and yield optimization for campaigns designed to appear on phones. Additionally, the company plans to release a mobile ad management product for advertisers sometime in 2008, according to Ari Paparo, DoubleClick’s VP of rich media and emerging technologies…DoubleClick Mobile aims to bring “a lot of heavy iron” to the developing marketplace for ads on handsets. The product is capable of pairing ads with content according to the screen size and capabilities of the device being used to view them, and supports device-specific previews for each ad position and execution. In addition to standard mobile display ads, it supports ad formats such as combination ads and roadblocks. Through pixel-based ad tracking, agencies and other third parties can access campaign performance data through their own campaign reporting systems..

DoubleClick Mobile is launching simultaneously in the U.S. and Europe… Next year, the company plans to release a more comprehensive mobile ad management suite that includes tools for agencies to plan and track their mobile campaigns…

DoubleClick Mobile comes just a week after Google, its probable soon-to-be parent, opened publisher enrollment for its AdSense for Mobile program.”

from: “Doubleclick Launches Site-Side Mobile Ad Management, Advertiser Version in Development.” Zachary Rodgers. ClickZ. September 24, 2007

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Canadian Privacy Group Raises Key Concerns on Google, Doubleclick and Threat to our Privacy

We urge everyone to read the CIPPIC petition filed yesterday in Canada asking for a investigation of Google and Doubleclick. Among the key questions raised is whether the two companies are violating Canadian privacy law (Personal Information Protection and Electronic Documents Act-PIPEDA). The full document is on the Canadian Internet Policy and Public Interest Clinic website. But here are some key excerpts raising very important issues. Bravo! (and Merci) CIPPIC.

“37. Google’s servers automatically record information when the user visits Google’s website or uses Google products. Google server logs record the search request, URL, Internet Protocol (IP) address, browser type and language, and the date and time of the request, and one or more cookies that may uniquely identify the user’s browser. Google stores server logs indefinitely, but “anonymizes” them after 18 months.

38. The act of collecting user search queries and IP addresses invokes PIPEDA, requiring Google to provide adequate notice to users of any collection, retention, use, or disclosure of personal information other than that which can be reasonably implied (in this case, collection, retention and use necessary to deliver search results to the individual user). Without such notice, Google cannot be said to be obtaining meaningful consent from users to any other information practices, including retention and use for targeted marketing purposes.

39. The fact that Google’s search service is entirely dependent upon targeted marketing to users is not evident to the ordinary computer user. It cannot therefore be said that users implicitly consent to the use of their data for marketing purposes, even if such use is central to Google’s business model. Indeed, most users likely do not reasonably expect Google to retain their search queries in connection to their IP address for much longer than necessary to deliver the requested search results.

62. Google collects a variety of personal information about its users and uses that information to, among other things, improve its target marketing services. Online advertising services are constantly being improved, sometimes in ways that involve greater collection and use of personal data. This raises the question of what level of data collection and analysis is necessary for the purpose of target marketing; at what point is Google collecting more personal data than necessary for advertising purposes? No doubt Google is limiting its collection of data to that which is relevant for the marketing purposes, but the test in Canada is necessity, not relevance.

63. CIPPIC submits that a determination of what is necessary under Principle 4.4 should be driven not by what is possible or desirable from an advertising perspective, but rather what is actually necessary for Google to provide the service. The same test should be applied to all online advertisers, not just Google.”

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