Month: December 2007

FTC to Online Ad Biz: We Really

That’s the message I get from reading the commission’s majority report on the merger. Despite their protestation that they read a lot and interviewed people, it’s evident the FTC staff–and more troubling a majority of the commissioners–don’t have a clue about the online ad business they are supposed to be overseeing. Frankly, until CDD and USPIRG came in and brought the commission up to date, they didn’t have much of an understanding about behavioral targeting. We tried to help the commission since the proceeding began to get up to speed, sending them the data and offering contacts. Here, by the way, is an excerpt from a letter we sent the commission last week (December 10), recapping in writing what we had supplied them electronically over the months:

“Point 3: The combination of the metrics derived from the combination of the Google’s and DoubleClick’s “database of intentions” will trigger an unfortunate, anti-competitive, and economically harmful online advertising market structure. As the “Global Ad-Serving Leader,” DoubleClick explained in a 2006 presentation, its “Ad-impressions” have increased by 70 percent since 2005 (that year it served 1,346,149,954,854 such impressions). Each day, the company serves “8 billion Search, Display and Rich Media Ads.” Among the benefits of DART for Advertisers (“the number one choice for a 3rd Party Ad Serving Solution”), aside from the “Centralized Online Ad Management” system, was the “ROI Reporting” utilizing “Spotlight Tags [which] track consumer actions from impression to sale/action.” Certainly such data acquisition added to Google’s already-extensive wealth of market metrics and analysis tools (let alone user IP and search history) will help further broaden the already-impassable distance between Google and its closest competitor. Indeed, DoubleClick’s recent expansion of its cross-industry data-collection and tracking services will be a formidable anti-competitive advantage for the company. It’s new “Floodlight” system “combines the functionality of a spotlight tag with the ability to act as a universal tag for all other tracking tags, regardless of ad network.” If such a merger is approved, the Floodlight services will also reward Google with a way to track “post-click conversion…on a real-time basis across multiple ad networks with whom DoubleClick have no direction affiliation. The data advantages from DoubleClick’s operations, including such acquisitions as Falk, will provide Google a treasure trove of metrics that will only add to the anti-competitive network effects. If the FTC has not examined the IP-related analysis performed for DoubleClick by such clients as Digital Envoy and Quova, it should do so. How Google plans to incorporate this system, we would argue, is something that must be addressed.

The integration of the Google and DoubleClick data centers will also provide a far-reaching advantage (and, once again, raise the consumer privacy protection issue). In 2006, DoubleClick touted to clients its “Massive…Technical Infrastructure, featuring

• 640 Terabytes of storage
• 964 Gigabytes of log files processed each day
• Serving approximately 8 billion ads daily
• 17 Data Centers Strategically Placed Around the Globe

By the third quarter of 2006, DoubleClick had 30 Media Servers based in Chicago; 62 AdServers and 15 Media Servers in New Jersey; 62 AdServers and 30 Media Servers in New York City; 124 AdServers and 45 Media Servers in Ashburn, VA; 15 Media Servers in San Jose, CA, and a company-operated “backend system” in the Thornton, CO area. The company also had 118 Ad Servers through its International Data Center operation, including Sweden, United Kingdom, Germany, France, Japan, Taiwan, China (Hong Kong), and Australia. DoubleClick’s control over the database “log files” on its adservers that it collects and maintains for its clients provide it with a first-hand understanding of how the individual bits and patterns of data work most effectively for their clients, the vertical and cross platform content business, and finely-focused consumer sets. This is “cookie-level” information that DoubleClick—and potentially Google—can operationalize for their own anti-competitive activities.

We admit we are not experts about the range of Google’s clearly impressive data-storage and -analysis operation. But the melding of the two systems will clearly pose even greater challenges for competitors who will require the scope and range of such processing services. Google has, according to one recent published study, “anywhere from 100,000 to 165,000 or more servers…. Google data centers—now numbering about two dozen… come online and automatically, under the direction of the Google File System, start getting work from other data centers. These facilities, sometimes filled with 10,000 or more Google computers… are concentrated in North America with other data centers located in Switzerland, the Pacific Rim, and Beijing.” While Google shouldn’t be penalized for its cutting-edge development of servers and data centers, the manner in which they are combined with DoubleClick’s existing system must be part of the antitrust analysis.”

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FTC Fails to Protect Consumers, Competition, Citizens and Privacy: Google takeover of DoubleClick

“The Federal Trade Commission (FTC) sidestepped its responsibility today when it approved the merger of two companies whose new, extended data-collection reach will give it unprecedented access to track our every move throughout the digital landscape. By permitting Google to combine the personal details, gleaned from our searches online and YouTube downloads, with the vast repository of information collected by DoubleClick, the FTC has sanctioned the creation of a new digital data colossus. The FTC is supposed to protect the privacy of Americans in the digital age. The excuse offered by the majority of the commission–that consumer privacy can’t be addressed by current antitrust law–reveals a lack of leadership and determination to protect U.S. consumers. It’s clear that this merger—and the ones that follow—will be about companies creating the twenty-first-century’s equivalent of railroad, steel, and oil monopolies in the past. Monopolistic control over consumer data is both anti-competitive and a threat to privacy.

“Despite the FTC’s claims, privacy is most certainly an anti-trust issue. A key component of the online market dominance that companies such as Google have achieved is the aggregation and analysis of consumer profiles, including the merger of far-flung data sets and vast data warehouses that only a handful of companies now have at their disposal.

“Since the merger was announced, CDD has provided abundant evidence to the FTC that Google will now be able to extend still further its market dominance over online advertising. But several commissioners mistakenly believe that we are still living back in the dot-com boom of the 1990s, when barriers to market entry were low. Its analysis of the market is flawed. With today’s decision, the FTC is helping ensure that U.S. consumers will have to live under the shadow of an even bigger digital giant, with a privacy time bomb ticking in the background.”

“Having side-stepped its responsibility to protect both competition and privacy, advocates will press the European Commission to impose the necessary safeguards on the proposed Google acquisition of DoubleClick. Congress too will need to conduct oversight hearings into how the FTC conducted this merger review. Staff privacy principles put out for comment iare not a substitution for adopting specific safeguards for this merger.

“CDD especially commends Commissioner Pamela Harbour, who dissented today, for her insightful and independent critique. Commissioner Jon Leibowitz also raised the critical privacy issues in his thoughtful separate statement.

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

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Even Online Ad Trades See the Google/DoubleClick Privacy Threat!

excerpt: “…If the deal is passed without any restrictions, the combined Google/DoubleClick would have access to the vast majority of online data and could build profiles of users by mining data from them as they use web services and applications, track users across websites with behavioural targeting, and use ad tracking and ad serving data. The fear is that the currently two separate pots of data would be largely complementary and would make Google the Big Brother of the internet, with access to a massive pool of consumer data.”

from: Is Google becoming an online big brother? [sidebar] to:

“Privacy Issues.” Greg Brooks. NMA magazine | Published: 13.12.07 [sub required]

Google is an advertising giant, and is now in the process of using its tremendous resources to expand how it serves the marketing needs of the largest companies, their products and brands. The online medium will undergo a subtle change as the financial interests of marketers help shape how search engines, social networks, mobile services and broadband video platforms serve us. Google’s push to become a more important must-buy for global advertisers is one reason why it’s buying DoubleClick (think about all of DoubleClick’s data collecting and ad serving system of global data centers merging with Google’s sophisticated technology so it can deliver more precision targeted ads wherever we are. That’s one principal reason Google opposes any privacy safeguards related to its proposed DoubleClick takeover).

Google’s now presenting advertisers with research it sponsored, notes Brandweek, that “measured the effectiveness of identical advertising creative for three leading CPG [consumer package goods] brands in the food, beverage and personal care industries across three separate platforms: traditional TV, the YouTube online video environment and ad-embedded click-to-play video. The study found that YouTube (which is owned by Google) and embedded video ads performed just as well as TV spots to aid brand affinity and drive purchase intent. A case study using a campaign for Dove’s Ultimate Clear deodorant showed that ads on 271 of Google’s network Web sites and 121 groupings of sites geared toward the 18-34-year-old female target drove brick-and-mortar sales an incremental 25%. Of particular interest, 96% of that extra traffic represented new customers for the brand.”

As we’ve always said about the new media industry, as a way to warn the public that it would (like broadcasting and cable) be transformed by powerful economic forces into a system that undermined its democratic potential, it’s really about show business and advertising. Unless we proactively act during this transformation period to ensure we have the global democratic digital media system we require.
Source: Google’s Latest Search: More CPG Advertisers. Brandweek. December 17, 2007.

Why We Need Real Privacy Protections for Online: Read this “Risk Factor” from new SEC filing

ExactTarget is an email marketing company, working with such companies as “Careerbuilder.com, Expedia.com, Florida Power and Light, Gannett Co., Inc./USA TODAY, the Indianapolis Colts, The Leukemia & Lymphoma Society, Liberty Mutual Group, Papa John’s and Wellpoint, Inc.” They just filed for an IPO (known as S-1). Here’s a important excerpt:

“The ability of our clients to solicit, collect, process and use data derived from their customers may be restricted by existing and future privacy laws and regulations. In turn, we may be restricted from providing certain services, required to implement additional procedures and security systems and be exposed to the costs and liability associated with complying with or violating those regulations, all of which could harm our business.

Existing laws regulate the solicitation, collection, processing, transfer, use and other exploitation of consumers’ personal information and other types of information. Such laws and regulations may require companies to implement privacy and security policies, permit users to access, correct and delete personal information stored or maintained by such companies, inform individuals of security breaches that affect their personal information, and, in some cases, obtain individuals’ consent to use personal information for certain purposes. Additional privacy laws and regulations are possible and they could, if enacted, prohibit the use of certain technologies that track individuals’ activities on web pages or that record when individuals click through to an Internet address contained in an email message. Such laws and regulations could restrict our clients’ ability to collect and use email addresses, page viewing data and personal information, which may reduce demand for our products and services. Some regulations may cause our clients to insist that we adopt or implement certain security and privacy policies and procedures, or to implement certain security measures. The cost to comply with such demands or regulations could be significant and would increase our operating expenses, and we may be unable to pass along those increased costs to our clients.”

Microsoft Digital Advertising Sales exec: Facebook is social media testing ground for brands

One of the best ways to track what’s in store for us with interactive advertising and digital marketing is to follow what companies are doing in Asia or the United Kingdom. Here’s some insight via Asia Media Journal about Microsoft’s expanded relationship with Facebook. Excerpt follows [and registration is required for the entire article]:

Microsoft (MSFT) set tongues wagging after paying US$240 million for a 1.6% stake in Facebook. The move prompted the same question from a lot of people: why?

The short answer is to see what happens next, explained Erik Johnson, Greater China general manager for Microsoft Digital Advertising Solutions… The multi-million dollar outlay has bought Microsoft an invaluable vantage point from which it can both observe the ongoing development of Facebook, and test out theories about the potential of it and other forms of social media for brands.

“You’ve got to cover all your bases on this,” Johnson says. “… We have a lot of respect for the work they do in building out this social audience, but we also believe that the Facebook experience is still a little too flat, doesn’t have depth. The brand doesn’t stand for enough to provide huge differentiation for advertiser and marketer…The investment we made gives an option for Microsoft, at some point in the future, to work tighter with Facebook, or maybe we’ll just work with them on the advertising side.”

… “If there’s any phenomenon that we may think challenges that, it’s the social networking space. It is an experimentation phase, but we’re going to focus in on social networking versus paid search, and how you differentiate that to the advertiser in such a way that they would pick one or the other….”

source: “Why Microsoft Teamed Up with Facebook.” December 14, 2007. Asiamediajournal.com

Joe Sims, the FTC & DoubleClick

A quick point, and we hope others will investigate. Mr. Sims is helping lead the Jones Day team on its DoubleClick merger work, since he is a “senior antitrust Partner” at Jones Day. Mr. Sims, of course, serves along with John Majoras in the firm’s “Antitrust and Competition Law” department. Mr. Sims co-authored an article with Chairman Majoras prior to her work at the FTC. As Mr. Sims wrote in March 2006: “Deborah Majoras, the current Chairman of the FTC, understands all these points about as well as anyone could. She has spent about 10 years in private practice, a lot of that time doing merger work from the defense side, and about five years in senior positions at the Antitrust Division and the FTC, doing merger work (among other things) from the agency side. When she was in private practice, she coauthored (along with the author of this Commentary) one of the most detailed critiques of the HSR second request process, which estimated the potential costs of what the authors viewed as overreaching by the agencies in the hundreds of millions or potentially billions of dollars…“

Understanding whether the FTC staff learned of the Jones Day role in the merger is important. The Chairman says she didn’t learn about it until Tuesday. We don’t really know what may have been communicated to the EC by Jones Day on the DoubleClick matter, and whether that was reported back to the FTC (via, for example its Office of International Affairs). But the public requires answers.

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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.

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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!

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