Category: interactive advertising

Two years after CDD & USPIRG warn about online advertising & media consolidation, a call to “monitor the state of competition”

Yesterday, Sen. Herb Kohl, the chair of the Senate Antitrust Committee, sent a letter to the Department of Justice about the proposed Google/Yahoo alliance. Two years ago next month, in its initial complaint filed at the Federal Trade Commission calling for an investigation into behavioral online ad targeting, CDD and USPIRG also petitioned the agency to open up an antitrust investigation. It was clear two years ago–as one surveyed the dizzying global shopping spree by Google, Yahoo, Microsoft, Time Warner/AOL–that a tiny handful would soon dominate the online ad market. Given that online ad revenues are the key to the funding of almost all interactive and online content, we were disturbed by the trend then towards consolidation. Of course, fewer companies controlling all that consumer data also raised fundamental privacy concerns.

Two years later, of course, we have even fewer independent companies left standing. Google swallowed DoubleClick (and is poised to partially operate Yahoo); Yahoo acquired Blue Lithium and Right Media; Microsoft acquired giant aQuantive; Time Warner bought Tacoda and Third Screen Media. Etc.

Regulators on both sides of the Atlantic have been asleep at the digital switch. They have failed to both protect competition and privacy. However, there is a growing awareness that there are serious problems looming. As we know, the same deregulatory philosophy which helped wreck our economy is also the foundation for communications and media policy. It is accompanied, of course, by a `golden’ revolving door between government and private industry that has left consumers and citizens vulnerable to a wholesale set of unfair practices. Addressing these issues will be the focus of much work over the next several years.

Network Advertising Initiative Continues to Protect Online Marketers Interests Instead of Consumer Privacy

The Network Advertising Initiative’s (NAI) real role is to protect the ability of its members (Google, Yahoo!, AOL, etc.) to collect huge amounts of profiling and targeting data from each of us. NAI claims it’s promoting self-regulation on data privacy through its principles and guidelines. But NAI has long been a toothless group, and is basically a public relations vehicle helping to cover the data crime and more-than-misdemeanors of the industry.

So it’s not surprising that last week, the NAI announced that while it supported an “opt-in” for the kind of behavioral targeting planned by the phone and cable companies, it didn’t believe such a safeguard was required for its data-collected membership. In a statement, NAI Executive Director Trevor Hughes said that his group “believes that opt-out continues to be an appropriate choice mechanism for traditional web-based behavioral advertising and this is part of our sliding scale framework.” That’s the political position taken, of course, by his members. They are the biggest behavioral targeters on the planet.

The NAI is a weak group which reflects the cynical view of the online ad industry.  NAI members hope that they can fool policymakers into believing consumer privacy can be safeguarded by the data wolves running the privacy hen house. The battle lines for the next Congress, the FTC and FCC are being drawn. Opt-out is a feckless approach to digital ad privacy. Responsible companies should be in the lead calling for meaningful opt-in. Note to NAI members:  Deregulation and industry self-governance–how shall I put it–doesn’t seem to have worked that well so far!

Interactive Ad Bureau to Congress and Public: If Your Privacy is Protected, The Internet Will Fail Like Wall Street!

It’s too disquieting a time in the U.S. to dismiss what a lobbyist for the Interactive Advertising Bureau said as merely silly. The IAB lobbyist is quoted in today’s Washington Post saying: “If Congress required ‘opt in’ today, Congress would be back in tomorrow writing an Internet bailout bill. Every advertising platform and business model would be put at risk.” [reg. required]

Why is the IAB afraid of honest consumer disclosure and consumer control? If online ad leaders can’t imagine a world where the industry still makes lots of money–while simultaneously respecting consumer privacy–perhaps they should choose another profession (say investment banking!).

Seriously, online ad leaders need to acknowledge that reasonable federal rules are required that safeguard consumers (with meaningful policies especially protecting children and adolescents, as well as adult financial, health, and political data). The industry doesn’t need a bail-out. But its leaders should `opt-in’ to a responsible position for online consumer privacy protection.

Google Policy Blog Fails to Address Yahoo! Deal & Threat to Competition & Privacy

Google’s post today by Tim Armstrong on why its proposed deal with Yahoo! isn’t a competition problem attempts to weave and spin this critical issue. It’s very revealing as well about Google’s own failure to develop into a company which honestly engages in self-examination and reflection. As one can see from the current melt-down of the financial markets, making money shouldn’t be the sole motivation for behavior. Google should have been able to acknowledge that a major deal with its leading search competitor raises serious questions worthy of broad debate and critical analysis.

The failure of Google to respond to the concerns raised by the World Association of Newspapers this week is reflective of this. Newspapers and content publishers are rightly worried about ensuring a diversity of funding sources for the production of news and other information necessary for a democratic society. It’s not as simple as Google’s Tim Armstrong (who wrote today’s post) suggests, that this deal with give consumers “relevant ads” and help keep Yahoo afloat as a robust competitor. In fact, Armstrong and Google, we believe, aren’t being candid here. When an online ad company dismantles (or turns over) a core part of its search function to its leading competitor, it becomes fatally wounded. As Google knows all well, search and display (and online content) are all intertwined. Yahoo’s future, in my opinion, as a full service online ad company is endangered, as more businesses realize that its search ad business relies increasingly on Google.

There are many troubling privacy issues with this deal, something Mr. Armstrong tries to dismiss by saying that [our emphasis]: “[W]e have taken steps in the Yahoo! agreement to make sure that neither company has access to personally identifiable user information from the other company.” But that leaves open an array of personal data collection points, such as cookies, IP addresses, and other statistical analysis online related data. (The failure, by the way, for the privacy issues of the proposed deal to be investigated by the FTC and Congress, is also disturbing).

Mr. Armstrong is Google’s “President, Advertising and Commerce, North America.” He directs their online ad sales. In responding to concerns about competition in the online advertising market–given its links to broader societal concerns–more than just assurances from the sales department is required.

Behavioral Targeters Use Our Online Data to Track Our Actions and, They Say, to “Automate Serendipity.” Attention: FTC, Congress, EU, State AG’s, and Everyone Else Who Cares About Consumer Welfare (let alone issues related to public health and ethics!)

NPR’s On the Media co-host and Ad Age columnist Bob Garfield provides policymakers and advocates with an arsenal of new material that support the passage of digital age consumer protection laws. In his Ad Age essay [“Your Data With Destiny.” sub required], Garfield has this incredibly revealing–and disturbing–quote from behavioral targeting industry leader Dave Morgan (Tacoda) [our emphasis]:

“Now we have the ability to automate serendipity,” says Dave Morgan, founder of Tacoda, the behavioral-marketing firm sold to AOL in 2007 for a reported $275 million. “Consumers may know things they think they want, but they don’t know for sure what they might want.”

Garfield writes that “In 2006 Tacoda did a project for Panasonic in which it scrutinized the online behavior of millions of internet users — not a sample of 1,200 subjects to project a result against the whole population within a statistical margin of error; this was actual millions. Then it broke down that population’s surfing behavior according to 400-some criteria: media choices, last site visited, search terms, etc. It then ranked all of those behaviors according to correlation with flat-screen-TV purchase…“We no longer have to rely on old cultural prophecies as to who is the right consumer for the right message,” Morgan says. “It no longer has to be microsample-based [à la Nielsen or Simmons]. We now have [total-population] data, and that changes everything. With [those] data, you can know essentially everything. You can find out all the things that are nonintuitive or counterintuitive that are excellent predictors. … There’s a lot of power in that.”

There’s more in the piece, including what eBay is doing. As the annual Advertising Week fest begins in New York, we hope the leaders of the ad industry will take time to reflect on what they are creating. You cannot have a largely invisible system which tracks and analyzes our online and interactive behaviors and relationships, and then engages in all manner of stealth efforts to get individuals (including adolescents and kids) to act, think or feel in some desired way. Such a system requires rules which make the transaction entirely transparent and controlled by the individual. The ad industry must show some responsibility here.

World Association of Newspapers Tells DoJ What CDD Has Been Saying: Google/Yahoo Combo Deal Threat to Newspapers and Online Content Diversity

Last July, my CDD wrote to the Department of Justice Antitrust Division raising a number of concerns about the proposed consolidation between Google and Yahoo! In particular, we were concerned about the impact the deal melding together the two leading online ad companies for newspapers would have on that imperiled business. Now, the World Association of Newspapers has issued a statement opposing the deal, citing many of the same issues. Here’s a link and the first few graphs of their important communique:

For over 60 years, the World Association of Newspapers [W.A.N.] has vigorously defended the freedom of the press. From its beginning, W.A.N. has recognized that newspaper journalism can be truly free only if newspaper publishers are economically independent. This means having the freedom to decide what news to publish, where to publish it, and the ability to build sustainably profitable businesses around it. As newspaper publishers endeavor to adapt to the Internet, their independence increasingly hinges on their ability to monetize news through online advertising.

  

In this pursuit, one company – Google – has emerged as the significant market power in online advertising. Google has built a very impressive business in 10 years, generating billions of dollars by indexing and linking to online content, then profiting from it through Google’s own ads. However, of the very impressive $48 billion in online advertising revenue that Google has amassed since 2001, less than one third of that has been returned to online publishers (1), and a much tinier fraction has benefitted the news and content generation industries. As such, most publishers are acutely aware that Google’s ever-tightening grip on internet traffic, its unbridled use of online content, and its dominance in online advertising poses a very real threat to the continued viability of the independent content generation industry.

It should be pointed out that most of W.A.N.’s 18,000 newspaper title members are, in fact, regular customers of Google (and to a lesser extent, Yahoo). These publishers depend on Google (and Yahoo) for a significant portion of their online advertising revenue and rely on each company’s respective search engines (both their paid search ads and their natural search results) to drive traffic to their websites. To date, competition between both these two search companies has provided a necessary check to any potential market abuses, and has helped to ensure that publishers and content generators are capable of earning an equitable and fair return on their content.

It is in that context that W.A.N. believes that the competition that currently exists between Google and Yahoo is absolutely essential to ensuring that our member titles receive competitive returns for online advertising on their sites, and for obtaining competitive prices when they purchase paid search advertising. In our view, the proposed advertising deal between Google and Yahoo would seriously weaken that competition, resulting in less revenues and higher prices for our members. W.A.N. is also concerned that this deal would give Google unwarranted market power over important segments of online advertising.

While Google and Yahoo have stated that their proposed agreement is limited in scope to North America, W.A.N. believes it will have a significant and adverse effect on all newspaper publishers worldwide, as it could have the potential of reducing the incentive for Yahoo to vigorously compete against Google across the globe.

More Google Ad Tag Targeting & Data Collection via DoubleClick’s new “DART Natural Search”

Google now does the hiring and firing over at DoubleClick. It’s also responsible, of course, for its business activities and privacy policies. Here’s an excerpt from a 2008 “beta programme” called DART Natural Search. We think the growing role of user tracking across a myriad of online content, which other companies are also doing, is a very disturbing practice:

“By working with DART Natural Search, the impact of the entire search experience and click history can provide directional and prescriptive insight for your business’ search strategies. The DART Natural Search solution empowers businesses to better understand consumer search activities, through a robust tool that leverages existing spotlight tags used in paid search management and a simple tag on landing pages. DART Natural Search reports on where your traffic originates via the following search engines properties. [they list Google, MSN, Yahoo, Windows Live, ASK & AOL]…Conversion data from both Paid Search and Display is de-duplicated. And you get full exposure-to-conversion pathway reporting, giving you a snapshot into what influences a customer purchase decision… DoubleClick implements a state-of-the-art, single tracking tag and system for both Paid Search and Natural Search… By understanding the complete picture of the online media mix, you gain insight into the visits and conversions attributable to natural searches. Specifically for Natural Search, you’ll be able to understand what country people search from, and the search engine property they use (images, video, news, etc). Lastly, learn what search terms and landing pages are most valuable to your business.”

source: “Gain Insight into Your Customers’ Natural Searches.” DoubleClick [UK]. 2008.

Behavioral Targeting: A “Guide” from Yahoo!

Here’s an excerpt from a Yahoo! description of its behavioural targeting capabilities,via its UK site:

“What is behavioural targeting? Online has always been able to offer varied targeting opportunities, such as demographic, geographic and interest targeting, based on a user’s claimed interest and activity at one specific point in time. However behaviourial targeting goes one step further. Behaviourial targeting is different in that it allows advertisers to deliver specific targeted ads to consumers interested in a product, when they are close to the point of purchase, by leveraging actual online user behaviour. Even better, because the ad is served to a person based upon relevancy, it can be on a page that’s not directly related to the product…

Behavioural targeting anonymously follows someone’s interests, patterns and behaviours so you can speak to them knowing they want to be spoken to, which means less campaign wastage. This can be done by monitoring a number of consumer actions including:

> Search terms entered
> Editorial content viewed
> Ads clicked on
> Channels or micro sites
…Yahoo! behavioural targeting gives each category a unique “product purchase cycle” to ensure it reaches consumers for the correct duration while they are in market for that product. These cycles are based on a rigorous investigation of a consumer’s actions in the buying process. The frequency and intensity of these actions change the closer the consumer gets towards the point of purchase, allowing distinct periods of brand consolidation and purchase intent to be identified. Behavioural targeting allows ads to be strategically delivered to these exact points of the process…

Yahoo! tracks historical behaviour – who clicked on ads in this category in the past and what actions led to this click? Each user is then scored on how likely they are to respond to ads in this category. The ads are then delivered through behavioural targeting, which will only reach those judged to be in market and ready to respond to that specific product category.

How does it work? Behavioural targeting anonymously follows someone’s interests, patterns and behaviours so you can speak to
them knowing they want to be spoken to, which means less campaign wastage. This can be done by monitoring
a number of consumer actions including:> Search terms entered
> Editorial content viewed
> Ads clicked on
> Channels or micro sites visitedYou can then weight each person according to their relevancy to a particular industry category and their exact position within the buying process. This can be worked out by the frequency and how recently they have shown an interest in a specific product. For example, if someone visits Yahoo! Travel and searches for flights or travel insurance this will increase their rating for the travel category. Naturally they will also fall into the finance and insurance category and their subsequent actions will determine how relevant they are to

Faster than the CBS Blinking Eye: CNET now offers behavioral targeting for its advertisers

We know the folks at Viacom and CBS know a great deal about digital marketing. The new overhaul of the CNET site, which CBS acquired last June, includes behavioral targeting in the redesign. CNET now–“[B]ased on what users are searching for, manufacturers will be able to connect with them… within the comparison shopping process. In addition to its traditional focus on tech products, CNET is adding appliance and kitchen gadget reviews, covering such products as built-in ovens, dishwashers, microwaves, refrigerators, small appliances, stoves and ranges, and washers and dryers.”

Of course, we hardly don’t know any media outlet that isn’t using some form of behavioral targeting and other interactive marketing techniques. But what’s generally missing is real disclosure to users and their ability to determine what is collected and by what methods. And while online advertising is the key business model for the future of online publishing, the rush to embrace of behavioral targeting by news organizations raises a number of disturbing questions. It’s an issue we will cover.

source: CNET.com undergoes major revamp. btobonline.com. August 28, 2008

Annals of Digital Product Placement: Brand Integration Deals & Online Video

Eventually, both the FTC and FCC–and Congress–will need to address this (as will the EU, etc). As “brand integration” increasingly becomes a key business model for online video publishing, more than disclosure should be required. Here’s an excerpt from TV Week:

“Some market research firms forecasting the size of the online video ad economy aren’t counting money spent on brand integration and product placements…

That suggests the size of the Web video economy is being underestimated by the amount of ad dollars flowing into high-profile Web shows such as NBC-backed “Gemini Division,” EQAL-owned “LG15: The Resistance” and Revision3’s “Diggnation.”

That’s a problem because they generate most of their ad revenue from brand integration and host shoutouts, as do many Web studios including Next New Networks, Revision3, ManiaTV and For Your Imagination.

“The vast majority of revenue we derive for our shows are from brand integration,” said Greg Goodfried, one of the executive producers of “LonelyGirl15” and its spinoffs, which have inked deals with MSN, Disney, Paramount and Procter & Gamble…“Brand integration is one of the biggest segments of the online video ad market, maybe bigger than pre-rolls,” said Raj Amin, CEO of HealthiNation, the online video health information network…There are no current estimates on the size of product placement deals in Web video. But Web TV networks such as Revision3 and For Your Imagination said they charge $60 to $80 on a cost-per-thousand basis for such buys.”

source: “Problems Emerge Measuring Web Video Ads: Product Placements Left Out of Estimates.” Daisy Whitney. TV Week. August 31, 2008.