Category: FTC

No More Doubletalk from Doubleclick. A Public Challenge

Doubleclick is claiming it doesn’t really know anything about us, and that its data is controlled by its clients.

Let’s get to the truth. Doubleclick should immediately make public the entire range of data, including behavioral and profiling information, that it now holds on its own (versus what it claims is owned by clients). This should include what it collects from DART and every other product available in the U.S. and abroad. Doubleclick should also fully disclose its complete data-related plans for its new Media Exchange. Let’s find out what information about all of us is available to Doubleclick from its servers. Doubleclick should turn over this information to the FTC, the European Commission and an independent panel of academic computer experts who have no affiliation with the online ad industry. Ask the panel and the FTC/EC to conduct an intensive review of its data holdings and capabilities from a personal privacy perspective. Arrange for these experts to conduct inspections at the Doubleclick Technology Group’s facilities in “New York, Colorado, Chicago, San Francisco and Europe.” Make all of the findings public as soon as possible.

This is something Google should insist on, as part of its own public interest due diligence.

Doubleclick’s Data “Boomerang”–Behavioral Targeting Power

excerpt from “Boomerang for Advertisers and Agencies”–“You are in a continual search for that desirable, yet elusive audience: the interested consumer. Boomerang, DoubleClick’s one-to-one targeting solution, empowers you to identify and re-target across your media buy customized segments of prospects and customers based on actions they’ve taken on your site and other marketing messages they’ve received. The result is a dramatic increase in customer acquisition, conversion, and retention metrics.

“Leverage the Power of Behavioral Targeting
Behavioral targeting is the most effective form of targeting available. It allows you to re-target to the most desirable audience of all: browsers who have already shown an interest in your product or service. With Boomerang, you can now engage that audience in a dialogue, providing timely and relevant messages triggered by their online actions. Boomerang delivers true behavior-driven advertising, so you can reach pre-qualified prospects and customers quickly and easily…

Use Boomerang to Get Better Results
Smart marketers have used Boomerang to:
• Re-target customers who have already browsed their site to bring them back
• Re-target site visitors that have “dropped off” of the purchase process with a related message to drive them back to the site
• Upsell and cross-sell customers that have already purchased core products
• Reach customers who have not visited or purchased recently to reactivate them
• Show specific advertising messages based on expressed interests, such as delivering an ad for a new car model to a browser that downloaded a brochure on last year’s model
• Test different offers and price points to determine the most effective for converting browsers into buyers”

product overview available via here:[pdf to download]

From a Doubleclick job announcement for “senior statistician” (excerpt): “DoubleClick is an application service provider, handling a staggering 12 billion transactions per day, and managing up to 160,000 hits per second on its global network. Our suite of products is driven by the DoubleClick Technology Group (DTG), comprised of over 300 IT professionals, located in New York, Colorado, Chicago, San Francisco and Europe.”

and an excerpt from: “Schmidt Defends DoubleClick Buy, Net Neutrality.” WebProNews
Schmidt said DoubleClick’s ad technology was what made the company attractive. “Advertising is really about relevance,” he [Google’s Eric Schmidt] said. It’s really about efficiency; it’s really about measurability. There’s not been a lot of technology applied to advertising over the past 10 or 20 years except for a few companies, DoubleClick being one of them.”

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excerpts from product overview of Doubleclick’s Dart Motif:


“audience interaction metrics: Motif’s exclusive Audience Interaction Metrics Package lets you gather data on more than 100 unique interactions in every creative unit including multiple exit links, counters, timers and video metrics. You’ll automatically get metrics on how long each ad was displayed or how the viewer interacted with the ad. Plus, you can customize additional events to track based on your creative concept….
* Ad Interaction Time: Tracks the average amount of time a user interacts with your ad, so you know what works best.
* Interactive Impressions: Shows how many Motif ad impressions generated user interaction for better understanding of audience response.
* Ad Display Time: Tracks the average amount of time each Motif ad is displayed to help measure brand exposure and optimize site placements.

track more than 100 metrics

* Exit Links: Let you track multiple click-throughs within a single rich media ad. Essential for when you’re promoting more than one offer in an ad. Motif makes tracking multiple exit links easy and eliminates click commands.
* Event Counters: See exactly what your audience is interacting with by tracking customizable events like rollovers, mouse-overs and drags.
* Timer Events: See how much time a user spent viewing or interacting with specific elements in your ad, like an interactive game or video.
* Motif Streaming Video Metrics: Motif provides the same in-depth reports for your video ads as it does for other rich media features. You can track audience video plays, completions, pauses, stops, restarts, mutes, average view time, and custom video interaction metrics.”

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U.S. Search Market is Consolidated. Google to Have 75% Share

eMarketer’s release on its new report that: “There are two giants in the space, and they are getting bigger! Saying that search engine marketing is a highly concentrated industry is an understatement… [my bold]


“Google and Yahoo!’s share of U.S. Paid Search Advertising Spending”
2007 (estimates)
Google: 75.6%
Yahoo!: 16.3%
Total Market Share of the two: 91.9%


“… according to comScore, US Internet users performed 75.8% of their January 2007 searches on Google or Yahoo!, and Nielsen//NetRatings put the combined total at 76.4%… “In fact, over 90% of US paid search ad spending will go to the two search giants in 2007…”
“US spending on search advertising will rise by more than $3.2 billion from 2006 to 2008 alone… Paid search is currently the key driver of US online advertising, and spending on paid search in 2008 will exceed the $9.6 billion that was spent on all online advertising in 2004.”

from: “The Unstoppable Surge of Search Advertising.” April 20, 2007

FTC Filing today on GoogleClick First in a Series of Steps

Today, the Center for Digital Democracy joins with the Electronic Privacy Information Center (EPIC) and the U.S. Public Interest Research Group (PIRG) in a complaint to the U.S. Federal Trade Commission about new threats to privacy arising from the proposed takeover of Doubleclick by Google. A copy of the filing can be be found here.

It is critical that both U.S. and E.U. antitrust authorities investigate the impact of this deal on the growing consolidated online advertising marketplace. My group and allies are working on the competition and market structure issues, in addition to concerns about privacy (in the case of the online advertising market, of course, issues related to personal privacy are almost totally intertwined).

The merger between Google and Doubleclick, along with other interactive ad industry consolidation, has greater implications beyond concerns over advertising competition and privacy. Whomever controls the online ad market will determine the range and diversity of content creation and distribution online (through their ability to invest in content sources and services). Antitrust regulators must intervene to protect civil society, including ensuring the funding and availability of news and civic discourse for the digital realm.

Faster Than You Can Say Doubleclick: Google’s YouTube to Collect More Data

From Advertising Age:

excerpt: “Coming this fall from YouTube: richer demographic information.

“We’ll never have had that much data about that much content,” said Suzie Reider, chief marketing officer at YouTube. She was speaking to a group of advertising research executives in New York at the Advertising Research Foundation’s Rethink conference.

“By Q3 we’ll have a tremendous amount of metrics and data around every video,” she said. “There’s lots you can glean from looking at who’s looking at what. It’s a real-time focus group that happens all day, every day.”

“At ARF: YouTube to Get Richer Demo Data.” Abbey Klaassen. Advertising Age. April 17, 2007 [sub required]

Industry Insider Describes

“DoubleClick serves more display ads for more advertisers and more agencies and more publishers than any other company in the world. With this deal, Google now controls more display advertising than any other company, which nicely complements their other businesses where they control more search and contextual advertising than any other company in the world… DoubleClick currently processes more online ad campaigns and more ad transactions than any other company in the world, by far, particularly at the high end of the market. This data is a treasure trove. If Google wanted to, it could know exactly how much money its AdSense distribution partners make from other ad distributors, be they Yahoo! or Advertising.com or MSN. This is very powerful data.

Even if they don’t ever access the data itself, the metadata (the data about the data) is incredibly valuable. It is as if the world’s biggest stock broker just bought the world largest stock exchange. Plus, DoubleClick probably sets more cookies on more consumer browsers than any other company in the world as well.

Just the analysis of this data could yield for Google the keys to dramatically improving the targeting of all of their ads.”

From: “Google/DoubleClick: It’s About Display, Data And Defense.” Curt Viebranz, Online Media Daily. April 16, 2007.

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From Doubleclicks’ March 2007 study on what it collects via broadband video (my italics):
“DoubleClick…announced the results of its recent research of online video ad placements, illustrating that video is a highly effective format for online advertising. Findings show that audiences have high interaction rates with video ads, users click the “Play” button more than they click on image ads, video ads are typically played two-thirds of the way through and video ad click rates are far higher than those of image format ads.

DoubleClick conducted its analysis of more than 300 online video ad campaigns that were placed by more than 130 advertisers over a four-month period in 2006… The interaction rate is the “all in” metric, including the sum total of all interactions that people have with the video ad units. Those include mouseovers, expansions, interactions with the video control buttons, clicks and other events…. “The best standard data you get on audience measurement of TV commercials is limited to reach and frequency or specialized brand studies. However, online video metrics available today, like interaction rate, play rate, video completion rate and so on, give advertisers much greater insight into how consumers are actually engaging with the ads and their brands,” said Marianne Caponnetto, Chief Sales and Marketing Officer for DoubleClick.”

And from Doubleclick’s Dart Motif product:

“Deliver an emotional brand experience with video.
Convey your brand message with believability and emotion by adding Video to your Motif rich media ads. Ads including Video deliver nearly three times higher brand awareness and message association, and more than 100 percent higher purchase intent and online ad awareness than non-rich media ads.”

“Audience Interaction Metrics: Motif’s exclusive Audience Interaction Metrics Package lets you gather data on more than 100 unique interactions in every creative unit including multiple exit links, counters, timers and video metrics. You’ll automatically get metrics on how long each ad was displayed or how the viewer interacted with the ad. Plus, you can customize additional events to track based on your creative concept.”

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We Need FTC to Protect Privacy. Privacy Groups Should Be Calling for Real Action–not Industry Friendly “Workshops”

My organization and the U.S. Public Interest Research Group have asked the Federal Trade Commission to swiftly act and protect our privacy online. Last November, we filed a lengthy complaint asking for an intervention to stop behavioral targeting [pdf from Doubleclick] and associated spyware. But it seems that some groups aren’t that interested in action. They want the industry bigshots (who may be their funders) to come into the FTC and agree on “best practices.” That will likely mean no real privacy protection. Here’s the excerpt from a CNET story:

“The CDT has urged the FTC to hold a workshop on behavioral targeting to set best practices in the industry and get players like Microsoft, Google and Yahoo to agree on them. The organization wants to ensure that people have control in the event that these companies begin to merge consumer information from search and Web-surfing records to personalize ads.”

Privacy groups need to demand that the FTC finish its investigation (it launched one last November as a result of our complaint). We have provided the FTC with so much additional information, they should be able to act by now. Workshops are a delaying tactic designed to help out the special interests. If you want to see just a small fraction of what we’ve sent the FTC investigative team, go to adwatch.

PS: Here’s the blog post from the Center for Democracy and Technology on its request for a FTC workshop. Read its letter to the FTC. Then ask yourself. Shouldn’t public interest groups identify in such a letter the companies which fund them and engage in behavioral targeting? Shouldn’t they acknowledge that one of their key supporters, Microsoft, is the subject of a related complaint now before the FTC? Follow the money and the data mining it helps bring.