Comcast is no longer a cable company, says Brian Roberts. It’s “a new products company”

Cable’s triple play is turning into a multi-dimensional effort designed to take advantage of its monopoly positions in cable TV and broadband (with mobile coming down the pike). Data collection and targeted advertising is on its agenda, as it is with phone company ISPs. Right now Comcast and other cable companies are working to build an interactive ad system— which raises all kinds of privacy, data collection, interactive marketing and consumer protection, and antitrust issues. This is no slow cable boat adrift on the digital sea, but a well-funded effort that–in part–is connected to Project Canoe. So we were not surprised when we saw this quote from Mr. Roberts during a February 2008 call with analysts: “Over the last few years we have successfully transformed Comcast from a cable company into a new products company that utilizes one infrastructure to deliver a growing number of products.”

Google “Platinum Sponsor” at Ad Research Event

excerpt: “At the Advertising Research Foundation measurement conference… Google’s designs on establishing a leadership position in advertising research were evident… It was the event’s “platinum sponsor,” and the stage, halls and registration area were festooned with Google signage and promotions that made other dominant industry players such as Nielsen Co. look circumspect by comparison…

a Google executive gave a presentation about the capabilities of the TV Ads service–which provides a detailed next-day report on where an ad ran, how many impressions it received, and viewer tune-in levels over the course of a particular spot via second-by-second data.”

ARF Talk: Google Stalks Research Walk, May Balk On Accreditation. David Goetzl. Media Daily News. June 26, 2008

NebuAd’s CEO Discusses Online Targeting

“The latest in behavioral and contextual advertising technology enable marketers to personalize their messages to consumers by serving hyper-targeted and varied ad formats at every stage of the purchase cycle — ensuring that the right offer is reaching the consumer at the right time. New tools that measure engagement by the degree to which the user is engaged throughout the conversion cycle lets advertisers know what messages work. Rating systems that assign value to each consumer action throughout the funnel give advertisers a more accurate measurement of real engagement.”

Bob Dykes. NebuAd CEO. Imediaconnection. May 28, 2008

Bravo to Reps. Markey & Barton for Raising Alarm on Charter Communication’s ISP eavesdropping plans

Today, Rep. Ed Markey and Rep. Joe Barton sent a letter to the CEO of Charter Cable. They have acted quickly to help protect the privacy of Internet users and, in this case, Charter’s customers.  Preventing ISPs from monitoring our online behaviors is important to fight for.  More will be coming.

Charter Cable to Spy on its Broadband Users to Serve Targeted Ads via NebuAd

We have long pointed out that deep-packed inspection can be used by ISPs to both eavesdrop on users and undermine the neutrality of the Internet. Via Wired and other sources we learn that “Charter Communications, one of the nation’s largest ISPs, plans to begin eavesdropping on the web surfing of its customers, in order to help web advertisers deliver targeted ads. In letters being sent to some of its 2.7 million high-speed internet customers, Charter is billing its new web tracking program as an “enhancement” for customers’ web surfing experience. The letters were first reported by a user on Sunday. The pilot program is set to begin next month.”Charter, using language straight out of Orwell’s 1984, claims it’s offering an “enhanced” service. Demonstrating its monopoly clout, Charter is imposing this service on an opt-out basis. Charter will be using, notes Wired, NebuAd. Here’s what NebuAd says it does (our emphasis): “NebuAd delivers the most actionable consumer intelligence by extending its reach dynamically to encompass the ever-growing network of sites that consumers visit. NebuAd combines this web-wide view of pages navigated, searches performed, ads clicked, etc., with the industry’s most accurate targeting capabilities, matching consumer interests across more than 1,000 categories…The result is behavioral advertising on a vast scale with a level of relevance that drives significantly improved response and engagement rates across all categories of advertisements.”

Here’s what NebuAd told Behavioral Insider magazine last November (excerpt, our emphasis): “The kind of data we do aggregate includes Web search terms, page views, page and ad clicks, time spent on specific sites, zip code, browser info and connection speed…within this vast universe of information we create a map of interest categories, beginning with the widest definitions, auto, finance, education, what have you. But within those we can provide far greater granularity. So if you’re talking about auto, we can drill down into particular interest segments, say SUVs, luxury cars, minivans, and then even to particular brands or models. Within the interest category of travel, we can identify consumers interested in learning about Martinique, the south of France or Las Vegas.”…“ISPs have been a neglected aspect of online’s evolution over the past several years. But the fact is the depth of aggregated data they have to offer, anonymous data, is an untapped source of incredible power… The conventional approach to behavioral targeting has been to place cookies on specific Web sites or pages. We’ve gone about it in a very different way. We place an appliance in the ISP itself. Therefore we’re able to get a 360-degree, multidimensional view over a long period of time of all the pages users visit. So what we’re really talking about for the first time is a truly user-focused, though still anonymous, targeting, taking the totality of anonymous behaviors rather than just a subset of sites on a network.” Here’s what NebuAd said in a November 2007 release: “NebuAd’s rich insight into consumer interests surpasses any other behavioral targeting solution and enables NebuAd to deliver precisely targeted ads that drive substantially increased value per impression…NebuAd’s deep insight into anonymous consumer commercial interests across the Internet, combined with its ability to micro-target the most relevant ad placements, brings a new level of value for advertisers, publishers and ISPs:..ISPs, who have up to now facilitated but barely participated in online advertising opportunities, can open new revenue streams that complement advertiser and publisher objectives to maximize revenue and generate higher revenue-per-subscriber.”

Both the FTC and FCC must investigate Charter’s plan (and other ISP’s permit snopping schemes. Congress needs to hold oversight hearings as well). ISPs should not be in the business of letting online marketers have access to the rich informational personal data streams of their customers. Broadband providers such as Charter get paid handsomely already by their subscribers for connectivity (and also benefit from their monopoly status to secure lucrative `bundle’ packages from consumers). Charter, which has a checkered financial history, should not be allowed to weaken the privacy rights of U.S. consumers. Paul Allen, Charter’s chairman and the co-founder of Microsoft, should do better than this.

Google, AOL, Yahoo, Facebook and Comcast Fear NY State bill protecting online privacy

Oh, what a tangled web when you build a business mode based on the collection and unfettered use of microtargeting data. New York state Assemblyman Richard Brodsky has proposed some modest safeguards–but has scared the supposedly privacy-respectful companies such as Google with it. Google, AOL, Yahoo and others sent the letter below to Brodsky. Yesterday, we are told, AOL and News Corp lobbyists met with Brodsky’s office and claimed that the online ad industry would have to flee New York if consumers are protected in that state. Perhaps they plan to relocate Madison Avenue to a digital green zone outside the U.S.! Btw, note the addition of Comcast, which also wants to protect its TV version of behavioral targeting via its Spotlight service.

The letter:

State Privacy and Security Coalition, Inc.

April 7, 2008

The Honorable Richard Brodsky
New York General Assembly
Legislative Office Building
Room 422
Albany, NY 12248

Re: Opposition to A. 9275

Dear Assemblyman Brodsky:

We are writing to express our strong opposition to A. 9275, which is
unnecessary, most likely unconstitutional, and would have profound
implications for the future of Internet advertising and the availability of free
content on the Internet.

A. 9275 would subject advertising networks to an extremely
detailed, unprecedented array of notice, consent, and access obligations
relating to “personally identifiable information” and “non-personally
identifiable information ” that is used for “online preference marketing.”
Every website that an advertising network contracts with would be subject
to detailed notice requirements.

This bill is unnecessary because advertising networks have already
agreed to self-regulation commitments relating to most of the components
of this bill. If they fail to live up to these commitments, then the Federal
Trade Commission and the New York Attorney General’s office would
have enforcement authority. Moreover, the bill appears to be based on
Network Advertising Initiative principles that will soon be outdated, as new
principles are expected to be released in the near future.

This self-regulatory system is continuing to advance. The Federal
Trade Commission has issued further self-regulatory principles relating to
behavioral advertising on which it will receive extensive comments later
this week, and several major network advertisers have announced new self-
regulatory initiatives. New York does not need to, and should not, jump
into this process.

This is particularly true because the Dormant Commerce Clause of
the U.S. Constitution prevents any State from dictating activity across the
Internet. Yet network advertisers and websites across the country and
operating in other countries would have to attempt to change their practices
to conform to the very specific notice, consent and access requirements in A. 9275. It is simply not feasible to comply with Internet advertising regulations that vary from state-to-state. Time after time, state laws that have attempted to impose this sort of broad Internet regulation have been struck down by the courts, doing nothing more than making taxpayers bear the expense both of defending the lawsuit and paying the successful plaintiffs’ attorneys fees.

For all these reasons, we urge you to oppose A. 9275 and allow self-regulation and federal initiatives to address online behavioral advertising.


Jim Halpert


eBay Inc.
Internet Alliance
Monster Worldwide
Reed Elsevier, Inc.
500 8th Street, NW
Washington, DC 20004
202.799.4000 Tel
202.799.5000 Fax

Comcast works with Miller Beer, Kraft Foods, Mars, Publicis to expand cable TV ad targeting. Baltimore new location for its micro-targeting–and consumer privacy threatening–trials

Here’s the excerpt from the 4/4/08 Comcast and Starcom (a division of Publicis ad giant) release. See too the role of outside databases in the targeting, including from Experian, Acxiom, List USA and Equifax. We hope Comcast watchers, privacy and consumer advocates, and Maryland state officials, take notice:

“Comcast Cable, and leading media agency network Starcom MediaVest Group (SMG) announced today the expansion of their agreement to test addressable TV advertising with a trial scheduled to launch in the third quarter of 2008 in the Baltimore, MD area. The companies also shared findings of a recently completed groundbreaking trial of addressable advertising technology…

The initial technical trial, which began in December 2006, took place in Huntsville, AL… Comcast has been offering zone-based advertising, but this was the industry’s first significant effort to deliver different ads within the same commercial break to different household groupings, based on demographics and advertiser segments…

“Addressable advertising gets us closer to the power of mass personalization by delivering highly relevant brand messages to engaged consumers, and this is the ideal connection in a world of scarce consumer attention,” said Laura Desmond, CEO-The Americas at Starcom MediaVest Group.

Major marketers active in the trial, all SMG agency clients, included General Motors, Discover Card, Hallmark, Kraft Foods, Mars, Miller Brewing Company and Procter & Gamble. One of the unprecedented capabilities demonstrated in this trial was advertisers were able to segment the market into audiences based on demographic data, and Comcast was able to deliver relevant ads for the advertisers’ products and services to each segment.

Comcast’s data services partner, Experian(R) Marketing Services, assisted Comcast in segmenting the market and matching relevant messages to groupings of households. Addressable advertisements were delivered with the support of OpenTV’s SpotOn(TM) advanced advertising solution, which allows for seamless switching of video ads to aggregated groups of set-top boxes…
The trial revealed that viewers who saw ads directed to households within a particular group were less likely to change channels… The Huntsville market was selected to pave the way for a larger scale deployment in 2008. The next Comcast Cable market slated to receive an expanded trial of addressable advertising is Baltimore, MD using Invidi’s Advatar(TM) technology.”

Comcast, in its release, claims that privacy will be honored. We think that’s a claim that requires to be challenged. Here are excerpts from Invidi, the technology company Comcast is using for this micro-targeting and data collection trial:
” For operators, ADVATAR provides the ability to address every subscriber on an individual basis. Marketing messages can be fine tuned and matched to the diverse interests of viewers and to the rapidly changing marketing needs of operators…
Viewer Present Classifier
Learning the demographic make-up of the household is critical to targeted impressions delivery
Age Classifier
Behavioral cues, viewer patterns and remote control click-stream data create gender IDs that are accurate and reliable
Gender Classifier
Converging industry data and program category information with remote control usage generates superior gender identification
Income Classifier
Cross-tabulating US Census data and zip code+4 information creates dynamic blocks of median household income
Geography Classifier
Periodically published tables correlate unique DSTB IP addresses with zip code + 4 data for dynamically generated targeting zones
Additionally, INVIDI is expanding its classifier set to include a Multicultural Classifier and a Contextual Search Classifier…
With Spot Optimization advertising inventory on the most popular cable programs is expanded by segmenting the audience to enable either a single advertiser to deliver multiple ads or multiple advertisers to advertise to different demographic targets all within a single time-specific break – generating substantial additional revenue by creating more quality targeted inventory to sell…
Geo Targeting
Every advertiser and marketer has the ability to create their own unique geo targeting mapping criteria. ADVATAR’s Geo Targeting used in combination with addressable, demographic and behavioral processes creates a new and powerful television advertising and marketing landscape…

For advertisers, ADVATAR is the ultimate impressions delivery system – making “Prime Time” whenever viewers are watching television. For the first time ever on any television platform media planners can precisely execute their advertising campaign with reach, frequency and separation – guaranteed impressions delivery to true demographic targets.
For media buyers ADVATAR provides unprecedented access, prevue, purchase, verification, real-time campaign management and dynamic reporting of television delivered impressions.”

PS: From Invidi’s December 2007 deal with Nielsen [excerpt. our emphasis]:
“The Nielsen Company and INVIDI Technologies Corporation today announced a multi-year agreement to share data and explore ways to measure personalized television ads targeted at specific viewers. As part of the non-exclusive agreement, Nielsen will provide INVIDI with demographic data that will enable INVIDI to refine and improve its advanced software engine – called Advatarâ„¢ — to track “addressable” advertising. Addressable or “targeted” advertising allows digital television providers to simultaneously deliver different ads to specific groups or even individuals based on their demographics, buying habits or personal preferences.”
PPS:  A video report on Comcast & Invidi (note mention of privacy concerns). via YouTube.


TV advertising, as we discussed in our book, is going interactive. The same privacy problems we now have with online–and will also have with mobile–are being migrated to television. Here’s an excerpt from a trade story on a meeting just held by the advertising industry to discuss interactive and highly targeted TV commercials [our emphasis]:

…Google executive Dan Gertsacov demonstrated the latest iteration of the search giant’s so-called “Goolge TV Ads” program, which is [sic] marries an online, auction-based system for buying TV advertising with Google’s methods for analyzing the clickstream data produced by TV digital set-top devices to give advertisers and agencies the ability to buy and evaluate TV the way they would online search.

The first iteration of the system enabled advertisers to buy TV time based on networks and dayparts. The iteration shown at Carat Wednesday revealed that advertisers and media buyers can now procure TV advertising time based on key words or terms, much the way they would buy online search.

A computer laptop marketer, for example, can now type in the word “laptop” and find a schedule of TV shows referencing computer laptops that they might place ads into.”

source: Carat Meeting Reveals Addressable TV Roll Out, Google ‘Key Word’ TV Buying System. Joe Mandese. Media Daily News. March 27, 2008. reg required.

PS:  Here’s another addition.  Google will track and analyze targeting done via TV and its impact online [excerpt]:

Both [Michael] Steib and [Dan]Gertsacov spoke about Google TV Ads’ ability to offer insight into how a campaign functions simultaneously on TV and online. Steib mentioned the potential for gauging what transpires online–with site visits and transactions–soon after a TV spot runs.”

source: Google Crawls Stations, Tells Broadcasters ‘TV Ads’ Makes Good AdSense.  David Goetzl.  Media Daily News.  March 28, 2008
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David Cohen and Brian Roberts need to be sent to reform school. That’s public interest and media reform, although Comcast’s arrogant behavior regarding bandwidth throttling and seat-grabbing at public hearings suggests that Cohen and Roberts deserve to be sent up the lack of corporate responsibility river. But Pennsylvania Governor Ed Rendell, long a Comcast favorite and Cohen’s former boss, would probably pardon them.

Comcast shareholders should be alarmed. At a time when cable’s future growth has never faced more challenges, the company’s leaders are engaged in a reckless attempt to shore up market share and suppress free speech. Such behavior discredits the company, including its board (Rockefeller Foundation head Judith Rodin serves on the board, btw). Comcast owes the country an apology for its actions. If it engages in a `we’re a big powerful monopoly and can do what we want’ attitude, it will become the poster child of a media company that most users, especially youth, will loath. Shareholders, the press, and advocates need to bring real reform to Comcast, before it becomes the brand we love to hate–and bypass.

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Is John Malone behind Discovery Channel censorship of Alex

We heard via Democracy Now that the Discovery Channel is refusing to air the Academy-nominated documentary, Taxi to the Dark Side. It’s likely that this censorious decision involves conservative cable TV titan John Malone and his Liberty Media. Malone, once called the Darth Vader of the cable TV biz because of his anti-public interest slash and burn policies, is in the process of taking over Rupert Murdoch’s DirecTV (with an FCC decision soon about the transfer). He is the chair of the Discovery Holding Co.  Malone has long had a financial relationship with both News Corp. and Barry Dillers IAC.

Discovery Channel’s advertisers should be targeted for this decision, which is politically motivated. Pension funds and other investors who hold Liberty shares should protest. The Discovery Channel, never an ally of serious documentary, should be held in scorn by filmmakers and other media groups. Meanwhile, it should also serve as a wake-up call to create several new independent broadband video channels for news, public affairs, and POV programming. Btw, Malone helped block NBC from creating a news channel competitor to CNN years ago; his TCI was also opposed to meaningful support for public access programming, and also undermined plans by the BBC in the early 1990’s to have a news channel in the U.S.

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