Category: Doubleclick

EC’s Questionnaire 1 on Google/DoubleClick merger

Following press reports of a new questionnaire sent by the European Commission Competition Directorate, we thought we should place here what we believe was the initial survey sent. Eventually, Congress and others will need to investigate how well the FTC conducted its own review of the deal. Frankly, several parties–including commissioners–spoke of their concern that the agency’s loss in Whole Foods and other cases made it more difficult to confront the Google takeover of DoubleClick case. This is an ongoing story. But for now, here’s the questionnaire:

Case COMP/M.4731 – Google/DoubleClick

Questionnaire to Customers 1
Deadline for Reply: 18/10/2007

Google Inc. (“Google”) notified to the European Commission its intention to acquire control of DoubleClick Inc. (“DoubleClick”) by way of purchase of shares. The two parties to the merger Google and DoubleClick are hereinafter collectively referred to as “the parties”. Both are active in the online advertising industry.
Pursuant to the Merger Regulation , the Commission is required to assess the operation’s possible effects on competition within the common market. To this end, the Commission needs to gather relevant information from the parties to the operation as well as from other market operators, such as competitors and customers.
Therefore, your replies to the following questions as well as any other opinion on the effects of the operation you might consider relevant, are of key importance to the investigation. We should also be grateful for any additional remarks you may wish to make relating to the proposed concentration. If you consider that a particular question is not relevant, please indicate this and explain why. Please reply to this questionnaire on behalf of all companies belonging to your group.
When you reply to this questionnaire, please provide TWO versions of your reply: (i) a CONFIDENTIAL version; and (ii) a NON CONFIDENTIAL version which excludes business secrets or other confidential information.

In accordance with the Merger Regulation and in the light of the deadlines which the Commission must respect following the notification of the case, the Commission wishes to have your reply by 18/10/2007.
If you have questions of administrative nature or wish to receive this questionnaire in electronic format, please contact Ms Györgyi Nyiregyhazi (Tel.: +32 2 29 85327, e-mail: gyorgyi.nyiregyhazi@ec.europa.eu) clearly indicating the reference: M.4731 Googkle/DoubleClick – Questionnaire to Publishers.

If you have any further questions on the substance of this request, please contact Mr Bertrand Jéhanno (Tel.: +32 2 29 91048, e-mail: bertrand.jehanno@ec.europa.eu), Mr Carl-Christian Buhr (Tel: +32 2 29 86 033, e-mail: carl-christian.buhr@ec.europa.eu), Mr Flavien Christ (Tel: +32 2 29 90931, e-mail: flavien.christ@ec.europa.eu,), Mr. Peter Eberl (Tel: +32 2 29 60783, e-mail peter.eberl@ec.europa.eu), Ms Vera Pozzato (Tel: +32 2 29 93012, e-mail: vera.pozzato@ec.europa.eu).

Thank you for your help and co-operation.

A. General questions

Please give the contact details of the person responsible for replying to this questionnaire
Company:
Contact person: Phone:
Position: Fax:
E-mail:
Address:
Country:
Company web-site:

Please give a brief description of your organisation, of its size and of your activities. If your company is a subsidiary please indicate the group to which it belongs to.
Description of your organisation:

Please indicate the countries within the EEA in which you are active as online publisher (website owner):

B. The provision of display ad serving, management and reporting infrastructure technology
The provision of display ad serving, management and reporting infrastructure technology could be distinguished according to whether services are provided to advertisers (and agencies) or to publishers (including self-provisioning).
The Commission understands that advertisers create advertisements and upload them onto the advertiser-side ad server. Once a website publisher has agreed with the advertiser (directly or through an ad network or ad exchange) to run the ads on its website, the publisher enters the campaign terms of the ad (location, price, targeting criteria) into the publisher-side ad server. There is then a relationship between the publisher-side ad server – which records the “impression” generated by the user’s visit of the web site and determines the advertiser to call – and the advertiser-side ad server – which chooses the appropriate ad to deliver on the web page. The relationship between the two servers also enables the advertiser to obtain information relating to the user’s online behaviour in the context of the placed ad via browser cookie technology.
1. What is the value of the online advertising revenues generated by your website(s) in Europe?

2. Through which channels do you sell advertising space on your website/s?
Direct sales: YES/NO
And/or
Brokers, intermediaries, ad networks, ad exchanges: YES/NO

3. If you use both the direct channel and the indirect channel (ad network/ad exchange), please indicate (broadly) what % of your online revenues originate from the direct channel.

4. Do you foresee that direct sales of online advertising will decrease in the future in favour of intermediation through ad networks and ad exchanges?

5. Do you foresee that numerous ad networks and ad exchanges will be able to survive in the near future (2-3 years)? Please briefly elaborate.

6. If you use a 3rd party ad serving supplier (e.g. DoubleClick, OpenAdstream, AdManager…): if the price of 3rd ad serving services was to raise by 5-10% (all else equal) would you switch part of your inventory to an integrated network like Google AdSense?

7. Do you consider the cost of switching ad serving technology supplier to be high / moderate / low?

8. If you use more than one supplier of such technology/services, please describe briefly the advantages and disadvantages of such a solution compared to a situation in which only one supplier is used. Please also indicate why your company chose to use more than one supplier for this technology/services.

9. If you only have one supplier for this particular product/service, do you consider it possible/usefull using another supplier for a comparable product/service at the same time? If yes, please name these other possible suppliers. If not, please explain the reason why you choose single homing (e.g. exclusivity clauses, cost saving, quality of service …).

10. Please name other providers of display ad serving, management and reporting infrastructure technology that you consider as competitors of your provider/s at EEA level.

If you sell advertising space through direct sales

11. Which provider/s of display ad serving, management and reporting infrastructure technology is directly supplying your company?

12. Have you ever experienced a switch of supplier for this particular product/service? YES/NO
If yes, please:
explain the reason why you made such experience:
provide the name of your former supplier:
the name of the replacing supplier:
the cost caused by the switch:
the time it took to complete the switch

13. What is the % represented by the cost of ad serving in the total revenue generated by your advertising space? Please provide broad estimates.

If you sell advertising space through brokers/intermediaries/ad networks/ad exchanges
14. Which provider/s of display ad serving, management and reporting infrastructure technology is/are indirectly supplying your company?

15. Have you ever experienced a switch of supplier for this particular product/service? YES/NO
If yes, please:
Explain the reason why you had to switch:
provide the name of your former supplier:
the name of the replacing supplier:
the cost caused by the switch:
the time it took to complete the switch:

16. If you use the indirect channel, what is (a) the % represented by the cost of ad serving in the total revenue generated by your advertising space; (b) the % represented by intermediation fees in the total revenue generated by your advertising space? Please provide broad estimates.

17. If you multi-home, why have you become member of several ad networks?

C. Effects of the merger

18. According to you, is DoubleClick’s large publisher customer base an advantage for the quality of services offered by DoubleClick to publishers? In other words, is there a direct benefit to a publisher to use an ad serving supplier with a larger publisher base? If so, please briefly describe the benefit(s) (e.g. does the ad serving service improves the monetization of inventory if the ad server processes the data on user behaviour accross numerous publishers?).

19. If Google and DoubleClick were to merge, do you consider that integrated networks like Yahoo! (with RightMedia) and Microsoft (with aQuantive) would be able to provide strong competition to Google/DoubleClick? Please briefly elaborate.

20. Would you consider open source ad serving software as a viable alternative to commercial ad serving software? If so would you consider it suitable, in conjunction with a standalone ad network, as an alternative to Google’s AdSense? Please explain.

21. What are, in your view, the main effects of the proposed operation on:
a) your company?
b) the markets for (display and text) ad serving, management and reporting services for publishers?
c) the prices of (display and text) ad serving, management and reporting services for publishers?
Please give reasons for your answers.

22. Do you have any other comments that you wish to bring to the Commission’s attention?

Thank you for your assistance!
Please do not forget to add a non-confidential version to your response.

As a brief companion piece to Ken Auletta’s article on Google in the current issue of The New Yorker magazine (The Search Party), this may be of interest. Google’s goal is ultimately to be of service to advertisers and marketers; that’s how it makes 99% of its revenue. There’s a disturbing lack of candor from Google about the conflicts they have. One the one hand, they are (getting PR for) promoting responsible practices such as energy sustainability. But on the other hand, they are using all the company’s incredible resources to push the interactive marketing and selling envelope, including the sales of automobiles. Here’s excerpts from Google advertising sales job openings related to the car and truck industry:

1. The role: Industry Head, Automotive – London

As a Google Automotive Industry Head, you’ll be working with those who produce, market or sell products or services related to cars, trucks, boats or other transportation vehicles. This includes original equipment manufactures, third-party websites, dealers and after-market parts and accessories companies. This is a highly consultative position that reports directly to the Automotive Industry Leader. You’ll be responsible for presenting the team’s strategy and managing a team of experts to increase sales on a national level. Focusing on building strong relationships at the highest possible level, your goal is to help your automotive clients get as many of their marketable assets online in an affordable and measurable way. You’ll combine exceptional Automotive knowledge, deep industry and marketing agency relationships, compelling communication/presentation skills and inspired prospecting/analytical abilities to develop and close new business as well as grow existing business.

Responsibilities:

  • Develop the vision and manage the sales/account strategies that will fully unlock the potential in the Automotive sector.
  • Build and maintain relationships with senior-level clients, industry-specific direct advertisers and relevant agency contacts.
  • Educate the Automotive industry and evangelise Google, particularly at targeted events, conferences and media opportunities.
  • Understand the roles of and manage a team consisting of Industry Managers, Account Managers, Account Strategists and Sales Planners – providing team development, guidance, feedback and motivation.
  • Develop a deep understanding of the business needs of Automotive advertisers and insights into consumer behaviour.

Requirements:

  • High-calibre BA/BSc degree (MBA preferred).
  • Proven record of strategic development of major Automotive manufacturers.
  • Substantial experience in advertising sales/marketing and sales management.
  • Established relationships and presence within the Automotive industry.
  • Broad knowledge of sales and management, and proven team management experience.
  • Ability to influence product development through interaction with relevant colleagues, peers and direct reports.
  • A deep understanding of the industry’s issues, a vision for its growth, and a commitment to advance Google’s forward-looking strategies within the marketplace..

    • 2. The role: Account Strategist, Automotive Vertical (Detroit)

    As a Google Automotive Account Strategist, you’ll work primarily with large automotive clients and agencies. Most of these companies operate multiple sales channels, work with several manufacturing partners and always look to increase sales volume and efficiency. This is a creative position that calls for a strong affinity for the craft of language and a fondness for consulting closely with the auto clients. You’ll distill the essence of our clients’ products and services into targeted keyword lists and text advertisements that connect our advertisers with customers. You will also collaborate with our Sales and Operations team to work closely with clients to maximize the performance of these highly targeted ads.

    3. [based in Santa Monica, CA]  The role: Account Strategist, Automotive Vertical.   As a Google Automotive Account Strategist, you’ll work primarily with large automotive clients and agencies. Most of these companies operate multiple sales channels, work with several manufacturing partners and always look to increase sales volume and efficiency. This is a creative position that calls for a strong affinity for the craft of language and a fondness for consulting closely with the auto clients. You’ll distill the essence of our clients’ products and services into targeted keyword lists and text advertisements that connect our advertisers with customers. You will also collaborate with our Sales and Operations team to work closely with clients to maximize the performance of these highly targeted ads…

loans 321500 loans cashloan payday 500loan 500 day paypayday 10 best loan 7 companyfast loan cash advance 20loan 6 payday cash link advanceservice cash payday advance 20 loan Map

DoubleClick tracks 50 different consumer data metrics now; what happens after Google merger?

Something to think about, here and in the EU. From a 2006 Businessweek story [excerpt, our italics]:

“The race is on to find new ways to track customer behavior. Advertisers and agencies are progressing far beyond the standard arithmetic of counting clicks and page views. They’re tracking the to-and-froing of the mouse on Web pages, and they’re finding new ways to group shoppers by age, Zip Code, and reading habits. CEO David S. Rosenblatt of DoubleClick Inc., which serves up some 200 billion ads a month for customers, says that every campaign now allows for 50 different types of metrics.”

source: “Wiser about the web.” Businessweek. March 27, 2006

movie long sexteens for auditions movierental prop moviewomen movies nakedpooping moviesporn movie blooperscartoon demented the movietrish movie porn stratus Map

To Cache a Thief: In their own words…Jones Day work in both U.S. and EU on behalf of DoubleClick:

This is G o o g l e‘s cache of http://www.jonesday.com/experience/experience_detail.aspx?exID=S11555 as retrieved on Nov 9, 2007 17:05:06 GMT.
G o o g l e‘s cache is the snapshot that we took of the page as we crawled the web.
The page may have changed since that time….

Client(s): DoubleClick Inc.

Representation: Acquisition by DoubleClick

Principal Professional(s): Joe Sims, Thomas Jestaedt, Alexandre G. Verheyden, Michael S. McFalls, Chris Ahern

Lead Practice(s): Antitrust Mergers/Joint Ventures

Industry(s): Media

Summary: Jones Day is advising DoubleClick Inc., the digital marketing technology provider, on the international and U.S. antitrust and competition law aspects of its planned $3.1 billion acquisition by Google Inc. The proposed acquisition will combine DoubleClick’s expertise in ad management technology with Google’s internet search and content platform. The transaction is currently under review by the U.S. Federal Trade Commission (FTC) and European Commission.

Related Services
Professional Representation

The Jones Day, Google/DoubleClick & FTC conflict of interest: a higher standard is required by the agency

Our lawyers are advising my organization on this matter, but I want to remind readers of one point. John Majoras of Jones Day is listed on its web site as the “Partner-in-Charge of business development in the Washington, D.C. Office and is a member of the Firmwide Business Development Committee.” [better read it now before Jones Day removes it!]

In that position, his role raises conflicts of interest with cases involving the FTC, in my opinion. With an issue involving the future of the Internet and the fate of digital media in a democracy, the highest standards are required. Chairman Majoras should have recused herself in this case. Jones Day should not have taken on DoubleClick as a client. Jones Day’s removal of the web pages discussing its role as advising DoubleClick in both the U.S. and EU raises serious questions about the firm’s activities in this merger case. There are so many key questions that must be publicly resolved. When did Jones Day begin representing DoubleClick? When did it announce, via its website, internal communications system, and through its representation with clients, regulators, and other outside parties, that it was representing DoubleClick? Did the FTC staff learn of the relationship between their boss’s husband’s law firm and the merger? (Please don’t tell me that such a relationship, even if spread informally, doesn’t have an impact on the proceeding.)

The public requires the highest standards of conduct from its public officials and leading law firms. This incident illustrates that more must be done to make such institutions accountable. Yesterday’s FOIA request by EPIC asking that the FTC provide it with all records related to its communications with Jones Day in this merger case (and related privacy issues) is a step in the direction of obtaining some sunshine.

Over the last six months, we have been focused on the business and privacy issues related to the Google and DoubleClick merger. We knew a huge lobbying operation was in effect, with Google having added significant political capacity in D.C., and various competitors (Microsoft, the phone companies, Yahoo!) jockeying for position. Our job at CDD was to provide some honest analysis about the realities of the online advertising business–its market structure, goals, and privacy threats. We didn’t have the time–nor the resources–to dig into the political aspects of the issue. Sadly, there was little serious journalism on the deal as well. But last Monday we decided to examine what role Jones Day was playing in the Google merger and learned–via its website–that it represented DoubleClick.

This case illustrates something we all know. That the big money and special interest nature of Washington politics is at odds with the concerns and needs of the average American. As I said, a higher standard is required–for public service, disclosure and intellectual rigor (something we believe the FTC has failed to do in this case and related privacy matters). It’s a story that not going away. That’s why we are writing about it–and keeping a watch as well!

sexploitation moviesshakeela uncensored moviesmovies silk pantywhite movie single femalexxx smokin moviessoundtrack movie philadelphiain spankings moviestgp squirt movies Map

The Future of Behavioral Targeting Regulation–First in a [very long] series

Now that the EU’s Article 29 Working Group has announced plans to investigate behavioral targeting as part of its 2008 workplan, advocates and regulators from both sides of the Atlantic can build the case for meaningful safeguards. The goal should be maximum privacy protection. It’s interesting to see the response coming from European-based behavioral targeting firms, such as nugg.ad.ag. In an article for the UK-based imediaconnection trade report, nugg.ad’s co-founder removes the use of IP addresses from the targeters arsenal, writing that “… even IP addresses has no place in targeting.” That will come to a surprise to many in the online marketing industry!

Nugg.ad is engaged in a range of targeting efforts that require the scrutiny of data regulators. But just in case you thought their rejection of IP address targeting made them a worthy of a privacy prize, you would be mistaken. In the same article, the nugg.ad executive describes the new generation of data that can be mined by marketers [our emphasis]: “Web 2.0 offers a better option — user-generated content, be it through word, sound or image, which is fitted with ‘tags’. These community recommendations lift contact management to a new level. By using targeting technology that can be applied flexibly, you can develop completely novel approaches and exploit untapped potential.”

The Article 29 group will surely be working.

8 loan pay day loan paydayprocessor account mortgage loan processor managerstudent loans and achievepersonals site adult loan personalsunsecured credit online secured loan adversestudent loan money aid federal directfinancial student loan aid directgrant loan aid student financial Map

The evolution of targeting users online (or, "Oh where oh where has our privacy gone")

An excerpt from a recent trade piece that should encourage reflection and concern (our emphasis):

“Today, we can not only target by the sites we think our customers frequent, we can follow them around the Web and target them based upon the other sites they actually visit. We can also target them based upon the words typed into a box, and from where those words are typed through search geo-targeting. We can also retarget searchers elsewhere on the Web. Facebook’s recent announcements take targeting to a whole new level, based upon age, location, interests, and other online activity.”

Source: “Search And Online Advertising: A Continual Evolution.” Ellen Siminoff. Search Insider. November 16, 2007

ringtone 7100i blackberryringtone uesers 100 mtn free tonokia ringtone 6061acdc ringtone mp3free polyphonic 3560 nokia ringtones 100a perfect lie ringtone2006 index mmf ringtoneringtone nextel 24 for i730 Map

ringtone 1260 nokiaringtones 3390 nokiaringtones nokia free 3595free polyphonic ringtone 6600 nokiaverizon absolutely free ringtonesmusic free ringtones no 100 chargeget ringtone know 50 wanna centnokia 3595 ringtone downloadable Map

Google & the Public Interest Policy Pod People

They’re coming. The “Google Policy Fellows” to help staff an array of public interest groups and policy think-tanks. “As lawmakers around the world become more engaged on Internet policy,” says Google, “a robust and intelligent public debate around these issues becomes increasingly important…The Google Policy Fellowship program offers undergraduate, graduate, and law students interested in Internet and technology policy the opportunity to spend the summer contributing to the public dialogue on these issues…Fellows will… work at public interest organizations at the forefront of debates on broadband and access policy, content regulation, copyright and trademark reform, consumer privacy, open government, and more. Participating organizations… include: American Library Association, Cato Institute, Center for Democracy and Technology, Competitive Enterprise Institute, Electronic Frontier Foundation, Internet Education Foundation, Media Access Project, New America Foundation, and Public Knowledge.”

It’s wrong for public interest and consumer organizations to take Google’s money and especially provide a “Fellowship” in its name. We need to build more consumer advocacy capacity to address Google’s growing power, especially its threat to privacy. No matter what these groups say (and some already take money from Google; others receive broad media industry support), there are digital strings attached, as subtle as they may be. The Fellowship program is just another lobbying and PR effort coming from a company that has a broad policy agenda. Many of the groups above should be training people to represent the public versus companies such as Google, and other big online advertisers and new media conglomerates. Giving Google a say on the training of policy advocates, let alone a funding role, undermines the public interest movement.

The image “http://blowyourheadoff.files.wordpress.com/2007/03/invasion-of-the-body-snatchers.jpeg” cannot be displayed, because it contains errors.

EC Second Phase Investigation of Google & DoubleClick: Good for Consumers, Competition and Privacy

Today’s announcement by the Directorate for Competition (DG Comp) underscores that the EC recognizes the serious consequences of the proposed Google takeover of DoubleClick. Competitors, consumer groups, and privacy advocates have provided sufficient information to the commission to warrant this relatively rare phase two inquiry. Google is quickly becoming the key digital gatekeeper for the online publishing and advertising marketplace. At stake here is more than just the skyrocketing Google share price, the convenience of our online searches, or even the current state of online advertising competition. The online marketing system is at the core of the dramatic changes transforming global communications–from broadband PC, to mobile, eventually even to television. If we are to have a more democratic and diverse digital marketplace of ideas and commerce, there must be meaningful competition and consumer protection in the online ad sector. This means Google should be prohibited from buying DoubleClick. Or, that at least meaningful safeguards are imposed that limit Google’s ability to leverage DoubleClick’s vast treasure trove of consumer data and its business relationships with many of the world’s largest companies.

Consumers need to be assured that they won’t be unfairly treated in terms of pricing and choice when buying online; advertisers will need protections to ensure that online marketing remains both affordable and competitive, especially when using Google. Privacy must be considered as well, with appropriate safeguards enacted

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.

consolidaton loans charege americancollege american loan corporationservices american online loan payment educationloan $3,000 cashapr 0 auto loanadvance california 14 payday loan 10loan day pay dollar 1000personal bad credit 10000 loan Map

3 5 loans bankday 2nd pay loanhome advantage loansacceptance loansadvance cash cost loan100 loan landfree loan payday 1sta payday loan Map