Comcast – Page 3 – Digital Destiny

Time for National Policy Providing Basic & Free Broadband for All: Metering and Ad-Supported Access Not the Answer

As Time Warner and the other broadband monopolists craft schemes to begin imposing pricing plans for broadband which limit and meter our online use, it’s time to push for a meaningful public interest “universal service” digital age policy. A 21st Century democracy should provide a reasonable amount of free access to every citizen in their home (along with more plentiful free access in schools, libraries, and community sites). Today’s New York Times has an non-analytical article on the Time Warner broadband metering trial [“Putting a Meter on the Computer for Internet Use.” Reg may be required].

Under Michael Powell’s FCC, the Bush Administration gave a broadband monopoly to the phone and cable giants–ending the hope for any serious competition. By rewarding the old monopolists (cable TV & phone) with a new digital domain to lord over, the Powell FCC ensured that consumers and citizens would eventually have to confront threats to both affordable service and content diversity online [that’s the network neutrality part of the story]. The plan by Google and others to free up extra spectrum isn’t a complete answer either. More bandwidth governed by an advertising-centric business model will foreground some kinds of content over others–leaving, we believe, digital content that illuminates democratic expression a hostage to commercial forces.

That’s why everyone must be guaranteed some form of free basic bandwidth so they can access news, information, and even entertainment without fear of running afoul of a cut-off (or huge bill) by their local cable or phone ISP. What that free access amount should be needs to be debated; but it should be generous enough so individuals can consume mighty multi-media amounts of educational, civic, and political content.

It will be a true test for the groups working on communications policies–as well as the leaders of our major political parties–to see if they have the vision and courage to call for what is right. If they merely confine themselves to be a part of the safe and narrow dimensions of what are the usual U.S. media policy debates, they will fail to address one of the critical public interest issues of our time.

Privacy Issues for Interactive TV and Personalized Targeting Should Be on Congress Agenda

Deep packet inspection and other online marketing techniques are not the only privacy concerns with digital media. So are, in my opinion, the evolving world of more precisely targeted and viewer tracking television ads. Here’s an excerpt from today’s MediaDailyNews on advances in interactive television:

“… a leading developer has created an open standard that will enable advertisers and agencies to easily and seamlessly integrate any method they use to target TV viewers, and then have those ads served to specific dayparts, programming genres, geographic zones, or even individual households. The breakthrough…allows advertisers to utilize any source of data they use to define their consumer targets, and then have those ads served to any platform capable of delivering targeted TV advertising, including…broadband, as well as household-specific addressable television outlets…

…Visible World is disclosing deals with both Acxiom and Experian, two of the leading sources of data used by agencies to target consumers across media, but… the system will easily port data from virtually any source…and… is capable of serving TV ads to as “granular” a target as an advertiser can define…”

source: Addressable TV Ad Developer Hits Target, Creates Open Standard For Advertisers. Joe Mandese. MediaDailyNews. Aug 21, 2008.

Letters to Hill on Online Advertising and Privacy: A Failure to Communicate

The two headlines coming from the responses sent to the House Energy and Commerce Committee so far are that trials of deep packet inspection ad tracking/targeting were launched without meaningfully informing subscribers, and that the companies really failed to fully disclose all the data collection and targeting they routinely do.

On the second point, a strategy by several companies was to gloss over what they collect from behavioral targeting. You would never know reading AOL’s letter, for example, that it acquired behavioral targeting leader Tacoda last year [which is now integrated into AOL’s “Platform A” system]. AOL’s letter to the Hill is a fairy tale version of the targeting it can do. To see a video produced for AOL’s Advertising.com that is more honest about its ability to collect and target, see its “Holy Grail of Online Advertising” animated promo.

Charter Cable, which was working with NebuAd until advocates and Congress raised the alarm, suggests for whatever online ad services it does on its website, it relies “on third-parties, such as Yahoo and Google to perform these functions.” But it promotes its vehix.com site saying that: “More leads. Better leads. Precise geographic and demographic targeting. Unparralled branding power. Vehix.com isn’t just another dot.com vehicle site. Vehix.com is a powerful new way to combine the targeting precision of Cable TV and the internet to create a powerful sales building program.” Comcast answers the Congress by repeatedly claiming that it doesn’t target individuals online. It could have included in its letter what it says to potential advertisers, that: “On a monthly basis, Comcast.net receives over 3 billion page views, 15 million unique users, average visit length of over 14.9 minutes and over 60 million video streams. Comcast.net Mail Center has over 20 million registered accounts, 7 million logins per day and over 2 billion page views a month.â€ None of the cable companies, of course, said a word about their coordinated moves into personalized interactive television ad targeting (Project Canoe). Insight cable could have included in its letter a section from its privacy policy, which says that:“Our Website may post banner ads or other forms of advertisements and/or links from third party advertisers that are not owned or operated by Insight or Insight Entities. These third party advertisers may independently solicit and collect personal information, or send their own tracking devices to our visitors. Other third party Internet programs or applications may also cause additional advertisements or banner ads to appear on top of our web pages. Insight does not have control over the placement of such advertisements or the tracking devices utilized through these applications. When you visit a third party advertiser’s Website, you will be subject to the privacy policy and terms of usage agreement of that Website operator.”

Of course, the tests by CableOne, CenturyTel, and Knology reveal the failure of the current disclosure process. Customers shouldn’t be required to read complex and confusing legal updates about privacy policy. The lack of candor from Google, Yahoo, Verizon, Comcast, etc. should be addressed by the companies quickly supplying new information to Congress about their complete data collection and targeting practices and plans.

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.”

Opposition to Google/Yahoo! (or other mergers) Should be Based on Principle: Digital Pawns in Play?

Yesterday, we were contacted by a reporter asking our position on the possible Google/Yahoo! search advertising deal (we are opposed to such an arrangement, on both competition and privacy grounds). When we read the story online, we learned that one of the groups sending a letter to the DoJ was the Black Leadership Forum. That raised our concern, since we know that the Black Leadership Forum has had relationships with phone and cable companies. It has also, in the past at least, worked with Issue Dynamics (a company which helps phone, cable and other interests “organize” support from not-for-profit groups. I cite Issue Dynamic’s role with the Black Leadership Forum on page 75 of my book.).

We have not read the letter to the DoJ. Nor do we know of any financial or other relationship between the Forum and any of the many interests who are fighting Google (phone and cable companies, for example, are opposed to Google’s positions on network neutrality). But we believe that all financial relationships, even from the recent past, need to be identified. I know this is Washington, where too many people “lease out,” as we say around my office. But there are important issues at stake with the new media marketplace. Reporters will need to do more to identify whether there are financial and other relationships with groups from Google, Microsoft, phone and cable, etc. But the real focus should be to examine the state of competition in the online ad market–and what it means for the future of communications in the digital democratic era.

IAB’s Response to Calls for Consumer Privacy Rules: Hire More Lobbyists to Protect the “Wild West” of Data Collection & Ad Targeting

Granted, the IAB’s Washington, D.C. lobbying shop, opened last year, is a small operation. Now the IAB is in the process of hiring a second person for the office. No doubt IAB wants to protect the data collection and micro-targeting digital turf of its members. Former Tacoda and Time Warner exec. Dave Morgan perhaps revealed why the political stakes are so high for IAB members such as Google, AT&T, Comcast, Time Warner, Disney, CBS, NY Times, Washington Post, etc. in Media Post. As Morgan explained, “.. Everybody now knows that data is the fuel for growth. Everyone is starting to mine it and make it available to third parties…The big four (Google, Microsoft, Yahoo and AOLâ€™s Platform A) are all opening up their networks and systems to leverage third-party data; so are the ad servers like WPPâ€™s 24/7 Real Media; and so are the ad networks…Weâ€™re moving into a wild, wild west in monetizing real-time marketing data, and weâ€™re going to need many more people that know how to do this…As we see this data take on more value and play a bigger role in our industry, the public policy implications are going to become much more pronounced.”

Google, Comcast, Verizon, AT&T and Time Warner in coalition to fight state-based public interest and consumer protection issues

Scratch a media conglomerate–old or new–and you reveal a political agenda that is all about the aggrandizement of power–consumer and data privacy be damned. Here’s are excerpts from a Kate Kaye story on the roll-out of the state-based coalition designed to protect the interests of the online advertising industry.

“From California to Utah to New York, state legislators regularly propose laws with major implications for the online ad industry. A once-loose collective of companies including Google, Yahoo, AOL and eBay finally incorporated officially this year after four years of collaborating to influence state policy.

The most recent target of the State Privacy and Security Coalition’s efforts is New York Assemblyman Richard Brodsky, sponsor of a bill preventing third parties from using sensitive personally identifiable information for behavioral ad targeting.

The coalition doesn’t like it. A missive sent to the legislator April 7 by the coalition’s lead counsel calls the bill “unnecessary,” and “most likely unconstitutional.”…Jim Halpert, partner in the communications, e-commerce and privacy practice at law firm DLA Piper, penned that letter. As head counsel for the coalition, he also recently facilitated its incorporation.

“There’s much more state activity than federal activity,” said Halpert. Not only does that create more laws or proposed laws to deal with; the state process moves much faster.

According to Halpert, the coalition also includes Verizon, AT&T, Comcast, and organizations such as the Internet Alliance and tech trade association AeA, formerly the American Electronics Association. With Halpert at the helm, coalition members conduct weekly phone calls, and sometimes meet in-person with other members or with state lawmakers to influence legislation involving online privacy and data security, Internet advertising, online child safety, content liability, spam, spyware, and taxation…

“We see the coalition’s role as helping state legislatures understand the technology policy area. I think we all recognize the technology environment can be complicated,” said Adam Kovacevich, Google’s senior manager, global communications and public affairs. Google Director of State Public Policy John Burchett is the firm’s primary liaison to the coalition.”

source: Google, AOL and others make state policy coalition official. Kate Kaye. clickz.com. April 14, 2008

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 â€œpersonally identifiable informationâ€ and â€œnon-personally
identifiable information â€ that is used for â€œonline preference marketing.â€
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 Generalâ€™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 plaintiffsâ€™ 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.

Sincerely,

Jim Halpert
Counsel

[Members]

AOL, LLC
Comcast
eBay Inc.
EDS
Facebook
Google
Internet Alliance
Monster Worldwide
NAi
NetChoice
Reed Elsevier, Inc.
Yahoo!
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 operatorsâ€¦
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 Classifierâ€¦
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 sellâ€¦
Geo Targeting
Every advertiser and marketer has the ability to create their own unique geo targeting mapping criteria. ADVATARâ€™s Geo Targeting used in combination with addressable, demographic and behavioral processes creates a new and powerful television advertising and marketing landscapeâ€¦

For advertisers, ADVATAR is the ultimate impressions delivery system – making â€œPrime Timeâ€ 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 â€“ called Advatarâ„¢ — to track â€œaddressableâ€ advertising. Addressable or â€œtargetedâ€ 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:Â 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:Â Here’s another addition.Â 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.Â David Goetzl.Â Media Daily News.Â March 28, 2008

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