Category: Google

Google

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A Closer Look at Google’s Advertisement Labels

Google's tiny 'Ads' labelGoogle’s tiny ‘Ads’ label

The FTC has called for “clear and conspicuous disclosures” in advertisement labels at search engines, and the FTC specifically emphasized the need for “terms and a format that are easy for consumers to understand.” Unfortunately, Google’s new advertisement labels fail this test: Google’s “Ads” label is the smallest text on the page, far too easily overlooked. (Indeed, as I show in the image at left, the “Ads” label substantially fits within an “o” in “Google.”) Meanwhile, Google now merges algorithmic and advertisement results merged within a single set of listings; Google’s “Help” explanations are inaccurate; and Google uses inconsistent labels mere inches apart within search results, as well as across services.

Details, including the shortfalls, screenshots, comparisons, and proposed alternatives:

A Closer Look at Google’s Advertisement Labels

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Labels and Disclosures in Search Advertising with Duncan Gilchrist

Disclosure: I serve as a consultant to various companies that compete with Google. But I write on my own — not at the suggestion or request of any client, without approval or payment from any client.

Search engines have long labeled their advertisements with labels like “Sponsored links”, “Sponsored results”, and “Sponsored sites.” Do users actually know that these labels are intended to convey that the listings are paid advertisements? In a draft paper we’re posting today, Duncan Gilchrist and I try to find out.

“Sponsored Links” or “Advertisements”?: Measuring Labeling Alternatives in Internet Search Engines

In an online experiment, we measure users’ interactions with search engines, both in standard configurations and in modified versions with improved labels identifying search engine advertisements. In particular, for a random subset of users, we change “sponsored link” labels to instead read “paid advertisement.” We find that users receiving the “paid advertisement” label click 25% to 33% fewer advertisements and correctly report that they click fewer advertisements, controlling for the number of advertisements they actually click. Results are most pronounced for commercial searches, and for users with low income, low education, and little online experience.

We consider our findings particularly timely in light of Google’s change, just last week, to label many of its advertisements as “Ads.” On one view, “Ads”” is an improvement – probably easier for unsophisticated consumers to understand. Yet it’s a strikingly tiny label – the smallest text anywhere in Google’s search results, and about a quarter as many pixels as the corresponding disclosure on other search engines. As our paper points out, FTC litigation has systematically sought the label “Paid Advertisement, and we still think that’s the better choice.

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Tying Google Affiliate Network

Disclosure: I serve as co-counsel in unrelated litigation against Google, Vulcan Golf et al. v. Google et al. I also serve as a consultant to various companies that compete with Google. But I write on my own — not at the suggestion or request of any client, without approval or payment from any client.

In one of the few areas of Internet advertising where Google is not dominant – where just three years ago Google had no offering at all – Google now uses tying to climb towards a position of dominance. In particular, using its control over web search, Google offers preferred search ad placement and superior search ad terms to the advertisers who agree to use Google Affiliate Network. Competing affiliate networks cannot match these benefits, and Google’s bundling strategy threatens to grant Google a position of power in yet another online advertising market.

Google shows algorithmic search results at the left side of users’ screens, while Google’s “AdWords” ads appear at the right and, often, top. Historically, Google has sold search ads on a cost-per-click basis: An advertiser is charged each time a user clicks its ad. With these offerings, Google has grown to a position of dominance in search and in search advertising — 77% share of U.S. web search in the US, with even higher levels in other countries.

While Google dominates online search, Google to date has made less headway in the area of affiliate marketing, an approach to online advertising wherein small to midsized sites (“affiliates”) receive payments paid if users click links and make purchases from the corresponding merchants. For example, Gap pays a 2% to 4% commission if a user clicks an affiliate link to Gap and goes on to make a purchase. While almost all of the web’s largest merchants run affiliate programs, as of the start of 2007 Google offered no affiliate marketing services. Only through its mid-2007 acquisition of DoubleClick did Google obtain an affiliate marketing program, then called Performics and now renamed Google Affiliate Network (GAN). But Google’s affiliate network began in third place in the US market — behind larger competitors Commission Junction and LinkShare.

Google now grants GAN advertisers preferred placement in search results. Notice that the three GAN ads appear with images, whereas ordinary AdWords ads show only text. And Google places all GAN image ads at the top of the right rail -- above all right-side AdWords ads. Beginning in November 2009, Google’s Product Listing Ads service gave GAN major advantages over competing affiliate networks. Within search ads, Google now includes listings not just to Google’s AdWords pay-per-click advertisers, but also to GAN advertisers. Through these placements, Google offers GAN advertisers four striking and valuable benefits:

  • Image ads. AdWords advertisements show only text. But GAN advertisements include an image — making GAN offers stand out in search results. See the three image ads highlighted in red in the screenshot at right.
  • Preferred placement. AdWords advertisements are ordered, Google says, based on how much each advertiser bids as well as Google’s assessment of ad relevance, click-through rate, and other factors known only to Google. But in my testing, all GAN ads appear at the top of the “right rail” of side listings — prominent, highly visible screen space that gets more attention than any AdWords listings below. Indeed, by pushing AdWords ads further down the page, GAN ads reduce the value of the AdWords slots. In the screenshot at right, notice that all three GAN image ads appear above all the right-rail AdWords ads.
  • Conversion-contingent payment. AdWords advertisers continue to pay on a per-click basis, incurring costs as soon as a user clicks a link. In contrast, GAN advertisers only have to pay if a user clicks a link and purchases a product.
  • Preferred payment terms. Because AdWords advertisers pay as soon as a user clicks, they must pay for users’ clicks even if servers malfunction, even if credit card processors reject users’ charges, and even if users return their orders or initiate chargebacks. In contrast, in all these circumstances, GAN advertisers incur no advertising costs at all.

I expect Google will argue that it is within its rights to package, bundle, and tie its products as it sees fit. I disagree. Here, Google ties its search offering to its affiliate network without an apparent pro-competitive purpose but with obvious anti-competitive effects. In particular, tying affiliate network services to preferred search ad format and placement gives GAN an advantage over competing affiliate networks, without efficiencies or other countervailing benefits to users or advertisers.

Furthermore, there is no plausible justification for providing image ads only to GAN advertisers or for granting all GAN ads positions above all right-side AdWords ads. To the contrary, Google could easily allow all AdWords ads to include images, and Google could instead intersperse GAN ads (and ads from other affiliate networks) among AdWords advertisements in whatever order auctions and algorithms fairly deem optimal. Those would be the natural product design decisions if Google genuinely sought to include images wherever useful and if Google genuinely sought to include affiliate ads whenever relevant. Because Google instead reserves these benefits for GAN advertisers, the natural inference is that Google reserves special rewards for advertisers choosing GAN — benefits that come at the expense of genuine competition in affiliate marketing services.

In the remainder of this piece, I discuss why the public should be concerned about Google’s tying tactics, then assess Google’s tying-based promotion of its various other products. I conclude with brief policy prescriptions.

Cause for Concern

I see four major reasons for concern in Google’s decision to tie GAN to preferred placements, format, and terms in sponsored search.

First, GAN’s tying threatens to extend Google’s dominance into yet another facet of online advertising. Google’s dominance in search and search advertising is well-known. But affiliate marketing is a rare area where, until recently, Google had little or no presence. By leveraging its dominance in search to take over yet another type of online advertising, Google will importantly limit advertisers’ options. Today, advertisers unhappy with Google’s AdWords prices or rules can consider working with independent web sites through affiliate programs not operated by Google. But if Google comes to dominate affiliate marketing, then even affiliate marketing will become unavailable to advertisers dissatisfied with Google. Indeed, knowing that it dominates multiple aspects of online advertising, Google will be in a position to raise prices that much further.

Second, GAN’s tying harms those AdWords advertisers who refuse GAN and buy only pay-per-click ads from Google. The more GAN ads Google puts above ordinary AdWords listings, the less visible AdWords advertisers become. AdWords advertisers are at a further disadvantage when Google gives image ads to GAN advertisers but not AdWords advertisers, and when Google offers preferred terms (e.g. refunds of advertising costs if a user returns a product) to GAN advertisers but not AdWords advertisers. Google promises that “the highest ranked ad is displayed in the most prominent position,” but when Google gives GAN ads the top positions, ordinary AdWords advertisers are left bidding on the leftovers. And as Google makes its left-side listings increasingly visual — inline maps, images, product pictures, video thumbnails, and more — advertisers need images to capture users’ attention. So AdWords-only advertisers, without image-based ads, end up at a significant disadvantage.

Third, for nearly a year Google has offered the Product Listing Ads benefits in “limited beta” available only to “a small number of participants” Google selects. In fact I’ve seen numerous advertisers, large and small, promoted in Product Listing Ads. But it is striking to see Google offer preferred listings only to those advertisers Google chooses to favor. Elsewhere Google argues that its auction-based ad sales are “equitable.” But when Google gives superior placement to its preferred advertisers, for nearly a year, Google’s rules seem the opposite of fair.

Finally, GAN’s tying is particularly worrisome in the context of other Google tactics. As detailed in the next section, Google uses and has used bundling and tying to enter and dominate numerous markets. If these tactics continue unchecked, we face a future where Google’s dominance stretches even further.

Google’s Tying Strategy More Broadly

Tying GAN to search is just one example of Google’s oft-repeated tactic of forcing customers who want one Google service to accept additional Google services too. This section presents a series of such examples.

Throughout, these tying examples fit the following form:

A [user type] who wants [desirable Google service] must also accept [unwanted Google service].

I now turn to specifics.

Tying to promote affiliate marketing services: An advertiser who wants top placement in Google search advertisements, image ads, and preferred payment terms must join Google Affiliate Network.

Details: See above.

Tying to promote low-quality syndicated search marketing services: An advertiser who wants placement through high-quality Google Search Network sites must also accept low-quality Google Search Network placements.

Details: Google’s Search Network includes some top-quality publishers such as AOL Search and New York Times. But if an advertiser contracts to advertise through Google Search Network, Google demands permission to also place the advertiser’s ads on whatever other sites Google selects, in whatever quantity Google chooses. Many of these placements are low-quality or worthless, including spyware popups, typosquatting sites, and deceptive toolbars. Many of these placements trick advertisers into believing they are receiving valuable traffic when in fact the traffic consists of users the advertisers had already reached or would receive anyway. Even if an advertiser learns about these problems, the advertiser must continue to pay for this traffic, on pain of losing access to Google’s high-quality search partners.

Tying to promote vertical search: A user who wants Google’s core algorithmic search results must also accept Google’s own vertical search results.

Details: Users relish Google’s highly-regarded algorithmic search results. But a user running search at Google also receives Google’s vertical search services: Whether the user prefers Bing Maps, Google Maps, Mapquest, or Yahoo Maps, Google Search always presents inline maps from Google, and so too for images, local businesses, products, scholarly articles, videos, and more. On one view, these vertical search services are an integral part of Google’s offering, but scores of competing vendors reflect a competing vision of users choosing core algorithmic search separately from vertical search services. By granting its special-purpose search services preferred placement, Google sharply reduces traffic to competing vertical search services.

Tying to promote ancillary mobile services : A mobile phone developer who wants Google’s Android certification and access to Android Market application store must also accept Google’s ancillary services, including geolocation.

Details: In a September 2010 complaint, Skyhook alleges that Google ordered Motorola not to ship a proposed device that would have included both Google Location Service and Skyhook’s XPS service, two distinct methods to determine a user’s geographic location. Skyhook claims that Google grounded its threat in Google’s Android Market application store: If Motorola shipped a device with software Google did not approve, Google would ban users of that device from accessing Android Market or running the apps available there. By requiring that Motorola omit Skyhook’s service in order to give users access to Google Market, Google denied users access to Skyhook.

Policy Prescriptions

Advertisers, consumers, policy-makers and the concerned public should give tying relationships a careful look. In principle, bundling previously-separate offerings can offer useful synergies and efficiencies. But bundling can also let a company expand from strength in one area into dominating numerous additional fields — limiting choice, raising prices, and reducing innovation.

In some instances, it may not be obvious how to separate bundled products. For example, there is currently no single clear mechanism whereby Google search results could embed maps, product feeds, or other structured or interactive information from other search services. Pending a compelling plan to unbundle vertical results from core search, my instinct is to save this problem for later — albeit perhaps requiring disclosure of favored treatment Google gives its own search services, or limiting the permissible extent of such favored treatment.

In other instances, market structure and product design yield a natural vision of products that could be separate, generally are separate, and should rightly remain separate. To my eye, these principles ring particularly true in the separation between search marketing and affiliate marketing. There is no logical reason why GAN advertisers should enjoy the only listings with images. Nor is there any logical reason why all GAN ads should appear above all right-side AdWords ads. When Google grants its GAN advertisers these special benefits, the best conclusion is that Google is using its dominance in search to establish dominance in affiliate marketing — seizing an unearned advantage over competing affiliate marketing services. These exclusionary tactics are unjustified and improper, and they ought not be permitted.

Google’s first step should be to cease tying Google Affiliate Network to preferred search placement, format, and terms: An advertiser seeking to include image ads should not have to sign up with GAN, nor should GAN ads arbitrarily appear above competitors. A recent post at Channel Dollars off-handedly reports that Product Listing Ads “has been taken out” GAN and “is being merged into” AdWords. That’s a fair start. But even temporary ties can impede competition, and Google has delivered these large benefits only to GAN advertisers for some ten months.

Meanwhile, Google’s preferred treatment of selected GAN advertisers foreshadows a worrisome future. If Google can give preferred treatment to advertisers who use GAN, what prevents preferred treatment of advertisers who support Google’s regulatory agenda, and inferior treatment of advertisers who complain to policy-makers? Indeed, I doubt that Google invited to Product Listing Ads any advertisers who have publicly criticized Google’s practices. Google’s ability to distribute valuable but opaque favors to preferred advertisers — and to withhold such favors from anyone Google dislikes — makes Google’s power that much stronger and, to my eye, that much more troubling.

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Google Inc. (teaching materials) with Thomas Eisenmann

Edelman, Benjamin, and Thomas R. Eisenmann. “Google Inc.” Harvard Business School Case 910-036, January 2010. (Revised April 2011.) (Winner of ECCH 2011 Award for Outstanding Contribution to the Case Method – Strategy and General Management.) (educator access at HBP.)

Describes Google’s history, business model, governance structure, corporate culture, and processes for managing innovation. Reviews Google’s recent strategic initiatives and the threats they pose to Yahoo, Microsoft, and others. Asks what Google should do next. One option is to stay focused on the company’s core competence, i.e., developing superior search solutions and monetizing them through targeted advertising. Another option is to branch into new arenas, for example, build Google into a portal like Yahoo or MSN; extend Google’s role in e-commerce beyond search, to encompass a more active role as an intermediary (like eBay) facilitating transactions; or challenge Microsoft’s position on the PC desktop by developing software to compete with Office and Windows.

Supplements:

Google Inc. (Abridged) – Case (HBP 910032)

Teaching Materials:

Google inc. and Google Inc. (Abridged) – Teaching Note (HBP 910050)

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Google Toolbar Tracks Browsing Even After Users Choose "Disable"

Disclosure: I serve as co-counsel in unrelated litigation against Google, Vulcan Golf et al. v. Google et al. I also serve as a consultant to various companies that compete with Google. But I write on my own — not at the suggestion or request of any client, without approval or payment from any client.

Run the Google Toolbar, and it’s strikingly easy to activate “Enhanced Features” — transmitting to Google the full URL of every page-view, including searches at competing search engines. Some critics find this a significant privacy intrusion (1, 2, 3). But in my testing, even Google’s bundled toolbar installations provides some modicum of notice before installing. And users who want to disable such transmissions can always turn them off – or so I thought until I recently retested.

In this article, I provide evidence calling into question the ability of users to disable Google Toolbar transmissions. I begin by reviewing the contents of Google’s "Enhanced Features" transmissions. I then offer screenshot and video proof showing that even when users specifically instruct that the Google Toolbar be “disable[d]”, and even when the Google Toolbar seems to be disabled (e.g., because it disappears from view), Google Toolbar continues tracking users’ browsing. I then revisit how Google Toolbar’s Enhanced Features get turned on in the first place – noting the striking ease of activating Enhanced Features, and the remarkable absence of a button or option to disable Enhanced Features once they are turned on. I criticize the fact that Google’s disclosures have worsened over time, and I conclude by identifying changes necessary to fulfill users’ expectations and protect users’ privacy.

"Enhanced Features" Transmissions Track Page-Views and Search Terms

Certain Google Toolbar features require transmitting to Google servers the full URLs users browse. For example, to tell users the PageRank of the pages they browse, the Google Toolbar must send Google servers the URL of each such page. Google Toolbar’s “Related Sites” and “Sidewiki” (user comments) features also require similar transmissions.

With a network monitor, I confirmed that these transmissions include the full URLs users visit – including domain names, directories, filenames, URL parameters, and search terms. For example, I observed the transmission below when I searched Yahoo (green highlighting) for "laptops" (yellow).

GET /search?client=navclient-auto&swwk=358&iqrn=zuk&orig=0gs08&ie=UTF-8&oe=UTF-8&querytime=kV&querytimec=kV &features=Rank:SW:&q=info:http%3a%2f%2frds.yahoo.com%2f_ylt%3dA0oGkl32p1tLT2EB8ohXNyoA%2fSIG%3d18045klhr%2f
EXP%3d1264384374%2f**http%253a%2f%2fsearch.yahoo.com%2fsearch%253fp%3dlaptops%2526fr%3dsfp%2526xargs%3d12KP
jg1itSroGmmvmnEOOIMLrcmUsOkZ7Fo5h7DOV5CtdY6hNdE%25252DIfXpP0xZg6WO8T7xvSy7HBreVFdJGu277WVk0qfeG%25255FGOW%2
5255F772GnNVme5ujWkF3s%25252DJ%25255F0%25252Dmdn4RvDE8%25252E%2526pstart%3d7%2526b%3d11&googleip=O;72.14.20
4.104;226&ch=711984234986 HTTP/1.1
User-Agent: Mozilla/4.0 (compatible; GoogleToolbar 6.4.1208.1530; Windows XP 5.1; MSIE 8.0.6001.18702)
Accept-Language: en
Host: toolbarqueries.google.com
Connection: Keep-Alive
Cache-Control: no-cache
Cookie: PREF=ID=…

HTTP/1.1 200 OK …

 

Screenshots – Google Toolbar Continues Tracking Browsing Even When Users "Disable" the Toolbar via Its "X" Button

Consistent with modern browser plug-in standards, the current Google Toolbar features an “X” button to disable the toolbar:

Google Toolbar features an

I clicked the “X” and received a confirmation window:

I chose the top option and pressed OK. The Google Toolbar disappeared from view, indicating that it was disabled for this window, just as I had requested. Within the same window, I requested the Whitehouse.gov site:

Google Toolbar disappeared from view, as instructed. Google Toolbar seems to be disabled.

Although I had asked that the Google Toolbar be "disable[d] … for this window " and although the Google Toolbar disappeared from view, my network monitor revealed that Google Toolbar continued to transmit my browsing to its toolbarqueries.google.com server:

See also a screen-capture video memorializing these transmissions.

These Nonconsensual Transmissions Affect Important, Routine Scenarios (added 1/26/10, 12:15pm)

In a statement to Search Engine Land, Google argued that the problems I reported are "only an issue until a user restarts the browser." I emphatically disagree.

Consider the nonconsensual transmission detailed in the preceding section: A user presses "x", is asked "When do you want to disable Google Toolbar and its features?", and chooses the default option, to "Disable Google Toolbar only for this window." The entire purpose of this option is to take effect immediately. Indeed, it would be nonsense for this option to take effect only upon a browser restart: Once the user restarts the browser, the "for this window" disabling is supposed to end, and transmissions are supposed to resume. So Google Toolbar transmits web browsing before the restart, and after the restart too. I stand by my conclusion: The "Disable Google Toolbar only for this window" option doesn’t work at all: It does not actually disable Google Toolbar for the specified window, not immediately and not upon a restart.

Crucially, these nonconsensual transmissions target users who are specifically concerned about privacy. A user who requests that Google Toolbar be disabled for the current window is exactly seeking to do something sensitive, confidential, or embarrassing, or in any event something he does not wish to record in Google’s logs. This privacy-conscious user deserves extra privacy protection. Yet Google nonetheless records his browsing. Google fails this user — specifically and unambiguously promising to immediately stop tracking when the user so instructs, but in fact continuing tracking unabated.

Google Toolbar Continues Tracking Browsing Even When Users "Disable" the Toolbar via "Manage Add-Ons"

Internet Explorer 8 includes a Manage Add-Ons screen to disable unwanted add-ons. On a PC with Google Toolbar, I activated Manage Add-Ons, clicked the Google Toolbar entry, and chose Disable. I accepted all defaults and closed the dialog box.

Again I requested the whitehouse.gov site. Again my network monitor revealed that Google Toolbar continued to transmit my browsing to its toolbarqueries.google.com server. Indeed, as I requested various pages on the whitehouse.gov site, Google Toolbar transmitted the full URLs of those pages, as shown in the second and third circles below.

See also a screen-capture video memorializing these transmissions.

In a further test, performed January 23, I reconfirmed the observations detailed here. In that test, I demonstrated that even checking the "Google Toolbar Notifier BHO" box and disabling that component does not impede these Google Toolbar transmissions. I also specififically confirmed that these continuing Google Toolbar transmissions track users’ searches at competing search engines. See screen-capture video.

In my tests, in this Manage Add-Ons scenario, Google Toolbar transmissions cease upon the next browser restart. But no on-screen message alerts the user to the need for a browser-restart for changes to take effect, so the user has no reason to think a restart is required.

Google Toolbar Continues Tracking Browsing When Users "Disable" the Toolbar via Right Click (added 1/26/10 11:00pm)

Danny Sullivan asked me whether Google Toolbar continues Enhanced Features transmissions if users hide Google Toolbar via IE’s right-click menu. In a further test, I confirmed that Google Toolbar transmissions continue in these circumstances. Below are the four key screenshots: 1) I right-click in empty toolbar space, and I uncheck Google Toolbar. 2) I check the final checkbox and choose Disable. 3) Google Toolbar disappears from view and appears to be disabled. I browse the web. 4) I confirm that Google Toolbar’s transmissions nonetheless continue. See also a screen-capture video.

I right-click in empty toolbar space, and I uncheck Google Toolbar I check the final checkbox and choose Disable

Google Toolbar Disappeared from View and Seems to Be Disabled

I confirm that Google Toolbar's transmissions nonetheless continue.

Users May Easily or Accidentally Activate “Enhanced Features” Transmissions

Google Toolbar invites users to activate Enhanced Features with a single click, the default. Also, notice self-contradictory statements (transmitting 'site' names versus full 'URL' adresses).Google Toolbar invites users to activate Enhanced Features with a single click, the default. Also, notice self-contradictory statements (transmitting ‘site’ names versus full ‘URL’ adresses).

The above-described transmissions occur only if a user runs Google Toolbar in its “Enhanced Features” mode. But it is strikingly easy for a user to stumble into this mode.

For one, the standard Google Toolbar installation encourages users to activate Enhanced Features via a “bubble” message shown at the conclusion of installation. See the screenshot at right. This bubble presents a forceful request for users to activate Sidewiki: The feature is described as “enhanced” and “helpful”, and Google chooses to tout it with a prominence that indicates Google views the feature as important. Moreover, the accept button features bold type plus a jumbo size (more than twice as large as the button to decline). And the accept button has the focus – so merely pressing Space or Enter (easy to do accidentally) serves to activate Enhanced Features without any further confirmation.

I credit that the bubble mentions the important privacy consequence of enabling Enhanced Features: “For enhanced features to work, Toolbar has to tell us what site you’re visiting by sending Google the URL.” But this disclosure falls importantly short. For one, Enhanced Features transmits not just “sites” but specific full URLs, including directories, filenames, URL parameters, and search keywords. Indeed, Google’s bubble statement is internally-inconsistent – indicating transmissions of “sites” and “URLs” as if those are the same thing, when in fact the latter is far more intrusive than the former, and the latter is accurate.

The bubble also falls short in its presentation of Google Toolbar’s Privacy Policy. If a user clicks the Privacy Policy hyperlink, the user receives the image shown in the left image below. Notice that the Privacy Policy loads in an unusual window with no browser chrome – no Edit-Find option to let a user search for words of particular interest, no Edit-Select All and Edit-Copy option to let a user copy text to another program for further review, no Save or Print options to let a user preserve the file. Had Google used a standard browser window, all these features would have been available, but by designing this nonstandard window, Google creates all these limitations. The substance of the document is also inapt. For one, “Enhanced Toolbar Features” receive no mention whatsoever until the fifth on-screen page (right image below). Even there, the first bullet describes transmission of “the addresses [of] the sites” users visit – again falsely indicating transmission of mere domain names, not full URLs. The second bullet mentions transmission of “URL[s]” but says such transmission occurs “[w]hen you use Sidewiki to write, edit, or rate an entry.” Taken together, these two bullets falsely indicate that URLs are transmitted only when users interact with Sidewiki, and that only sites are transmitted otherwise, when in fact URLs are transmitted whenever Enhanced Features are turned on.

Clicking the 'Privacy Policy' link yields this display. Note the lack of browser chrome -- no options to search text, copy to the clipboard, save, or print. Note also the absence of any on-screen mention of the special privacy concerns presented by Enhanced Features.

Clicking the ‘Privacy Policy’ link yields this display. Note the lack of browser chrome — no options to search text, copy to the clipboard, save, or print. Note also the absence of any on-screen mention of the special privacy concerns presented by Enhanced Features.
 The first discussion of Enhanced Features appears five pages down. Furthermore, the text falsely indicates that transmission covers mere domain names, not full URLs.

The first discussion of Enhanced Features appears five pages down. Furthermore, the text falsely indicates that ordinary transmission covers mere domain names, not full URLs. The text says "URL[s]" are transmitted "when you use Sidewiki" and indicates that URLs are not transmitted otherwise.

Certain bundled installations make it even easier for users to get Google Toolbar unrequested, and to end up with Enhanced Features too. With dozens of Google Toolbar partners, using varying installation tactics, a full review of their practices is beyond the scope of this article. But they provide significant additional cause for concern.

Enhanced Features: Easy to Enable, Hard to Turn Off

Google Toolbar's Options screen shows no obvious way to disable Enhanced Features.The preceding sections shows that users can enable Google Toolbar’s Enhanced Features with a single click on a prominent, oversized button. But disabling Enhanced Features is much harder.

Consider a user who changes her mind about Enhanced Features but wishes to keep Google Toolbar in its basic mode. How exactly can she do so? Browsing the Google Toolbar’s entire Options screen, I found no option to disable Enhanced Features. Indeed, Enhanced Features are easily enabled with a single click, during installation (as shown above) or thereafter. But disabling Enhanced Features seems to require uninstalling Google Toolbar altogether, and in any event disabling Enhanced Features certainly lacks any comparably-quick command.

I’m reminded of The Eagles’ Hotel California: "you can check out anytime you like, but you can never leave." And of course, as discussed above, a user who chooses the X button or Manage Add-Ons, will naturally believe the Google Toolbar is disabled, when in fact it continues transmissions unabated.

Google Toolbar Disclosures Have Worsened Over Time

Google Toolbar’s historic installer provided superior notice

I first wrote about Google Toolbar’s installation and privacy disclosures in my March 2004 FTC comments on spyware and adware. In that document, I praised Google’s then-current toolbar installation sequence, which featured the impressive screen shown at right.

I praised this screen with the following discussion:

I consider this disclosure particularly laudable because it features the following characteristics: It discusses privacy concerns on a screen dedicated to this topic, separate from unrelated information and separate from information that may be of lesser concern to users. It uses color and layout to signal the importance of the information presented. It uses plain language, simple sentences, and brief paragraphs. It offers the user an opportunity to opt out of the transmission of sensitive information, without losing any more functionality than necessary (given design constraints), and without suffering penalties of any kind (e.g. forfeiture of use of some unrelated software). As a result of these characteristics, users viewing this screen have the opportunity to make a meaningful, informed choice as to whether or not to enable the Enhanced Features of the Google Toolbar.

I stand by that praise. But six years later, Google Toolbar’s installation sequence is inferior in every way:

  • Now, initial Enhanced Features privacy disclosures appear not in their own screen, but in a bubble pitching another feature (Sidewiki). Previously, format (all-caps, top-of-page), color (red) and language ("… not the usual yada yada") alerted users to the seriousness of the decision at hand.
  • Now, Google presents Enhanced Features as a default with an oversized button, bold type, and acceptance via a single keystroke. Previously, neither option was a default, and both options were presented with equal prominence.
  • Now, privacy statements are imprecise and internally-inconsistent, muddling the concepts of site and URL. Previous disclosures were clear in explaining that acceptance entails "sending us [Google] the URL" of each page a user visits.
  • The current feature name, "Enhanced Features," is less forthright than the prior "Advanced Features" label. The name "Advanced Features" appropriately indicated that the feature is not appropriate for all users (but is intended for, e.g., "advanced" users). In contrast, the current "Enhanced Features" name suggests that the feature is an "enhancement" suitable for everyone.

Google’s Undisclosed Taskbar Button

This 'Google' button was added to my Taskbar without any notice or consent whatsoever -- highly unusual for a toolbar or any other software download.Google’s installer added this ‘Google’ button to my Taskbar without notice or consent.

The Google Toolbar also added a “Google” button to my Taskbar, immediately adjacent to the Start button. The Toolbar installer added this button without any disclosure whatsoever in the installation sequence – not on the toolbar.google.com web page, not in the installer EXE, not anywhere else.

An in-Taskbar button is not consistent with ordinary functions users reasonably expect when they seek and install a “toolbar.” Because this function arrives on a user’s computer without notice and without consent, it is an improper intrusion.

What Google Should Do

Google’s first step is simple: Fix the Toolbar so that X and Manage Add-Ons in fact do what they promise. When a user disables Google Toolbar, all Enhanced Features transmissions need to stop, immediately and without exception. This change must be deployed to all Google Toolbar users straightaway.

Google also needs to clean up the results of its nonconsensual data collection. In particular, Google has collected browsing data from users who specifically declined to allow such data to be collected. In some instances this data may be private, sensitive, or embarrassing: Savvy users would naturally choose to disable Google Toolbar before their most sensitive searches. Google ordinarily doesn’t let users delete their records as stored on Google servers. But these records never should have been sent to Google in the first place. So Google should find a way to let concerned users request that Google fully and irreversibly delete their entire Toolbar histories.

Even when Google fixes these nonconsensual transmissions, larger problems remain. The current Toolbar installation sequence suffers inconsistent statements of privacy consequences, with poor presentation of the full Toolbar Privacy Statement. Toolbar adds a button to users’ Taskbar unrequested. And as my videos show, once Google puts its code on a user’s computer, there’s nothing to stop Google from tracking users even after users specifically decline. I’ve run Google Toolbar for nearly a decade, but this week I uninstalled Google Toolbar from all my PCs. I encourage others to do the same.

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Google Click Fraud Inflates Conversion Rates and Tricks Advertisers into Overpaying

I’ve repeatedly reported improper placements of Google ads. In most of my write-ups, the impropriety occurs in ad placement — Google PPC ads shown in spyware popups (1, 2, 3, 4), in typosquatting sites (1, 2), or in improperly-installed and/or deceptive toolbars (1, 2). This article is different: Here, the impropriety includes a fake click — click fraud — charging an advertiser for a PPC click, when in fact the user never actually clicked.

But this is no ordinary click fraud. Here, spyware on a user’s PC monitors the user’s browsing to determine the user’s likely purchase intent. Then the spyware fakes a click on a Google PPC ad promoting the exact merchant the user was already visiting. If the user proceeds to make a purchase — reasonably likely for a user already intentionally requesting the merchant’s site — the merchant will naturally credit Google for the sale. Furthermore, a standard ad optimization strategy will lead the merchant to increase its Google PPC bid for this keyword on the reasonable (albeit mistaken) view that Google is successfully finding new customers. But in fact Google and its partners are merely taking credit for customers the merchant had already reached by other methods.

In this piece, I show the details of the spyware that tracks user browsing and fakes Google PPC ad clicks, and I identify the numerous intermediaries that perpetrate these improper charges. I then criticize Google’s decision to continue placing ads through InfoSpace, the traffic broker that connected Google to this click fraud chain. I consider this practice in light of Google’s advice to advertisers and favored arguments that click fraud problems are small and manageable. Finally, I propose specific actions Google should take to satisfy to prevent these scams and to satisfy Google’s obligations to advertisers.

Introducing the Problem: A Reader’s Analogy

Reading a prior article on my site, a Register discussion forum participant offered a useful analogy:

Let’s say a restaurant decides [it] wants someone to hand out fliers … so they offer this guy $0.10 a flier to print some and distribute them.

The guy they hire just stands at the front door and hand the fliers to anyone already walking through the door.

Restaurant pays lots of money and gains zero customers.

Guy handing out the fliers tells the owner how many fliers were printed and compares that to how many people bring the fliers into his restaurant.

The owner thinks the fliers are very successful and now offers $0.20 for each one.

It’s easy to see how the restaurant owner could be tricked. Such scams are especially easy in online advertising — where distance, undisclosed partnerships, and general opacity make it far harder for advertisers to figure out where and how Google and its partners present advertisers’ offers.

Google and Its Partners Covering Advertisers’ Sites with Spyware-Delivered Click-Fraud Popups

PPC advertisers (e.g. Finish Line)
money viewers
   Google   
money viewers
InfoSpace
money viewers
Cheapstuff
money viewers
Adfirmative
money viewers
dSide Marketing
money viewers
Netaxle
money viewers
eWoss
money viewers
AdOn Network
money viewers
Trafficsolar

The money trail – how funds flow from advertisers to Google to Trafficsolar spyware.

In testing of December 31, 2009, my Automatic Spyware Advertising Tester browsed Finishline.com, a popular online shoe store, on a virtual computer infected with Trafficsolar spyware (among other advertising software, all installed through security exploits without user consent). Trafficsolar opened a full-screen unlabeled popup, which ultimately redirected back to Finish Line via a fake Google PPC click (i.e., click fraud).

My AutoTester preserved screenshots, video, and packet log of this occurrence. The full sequence of redirects:

Trafficsolar opens a full-screen popup window loading from urtbk.com, a redirect server for AdOn Network. (AdOn, of Tempe, Arizona, first caught my eye when it boasted of relationships with 180solutions/Zango and Direct Revenue. NYAG documents later revealed that AdOn distributed more than 130,000 copies of Direct Revenue spyware. More recently, I’ve repeatedly reported AdOn facilitating affiliate fraud, inflating sites’ traffic stats, and showing unrequested sexually-explicit images.)

AdOn redirects to eWoss. (eWoss, of Overland Park, Kansas, has appeared in scores of spyware popups recorded by my testing systems.)

eWoss redirects to Netaxle. (NetAxle, of Prairie Village, Kansas, has also appeared in numerous popups — typically, as here, brokering traffic from eWoss.)

Netaxle redirects to dSide Marketing. (dSide Marketing, of Montreal, Canada, says it provides full-service SEO and SEM services.)

dSide Marketing redirects to Adfirmative. (Adfirmative, of Austin, Texas, promises “click-fraud protected, targeted advertising” and “advanced click-fraud prevention.”)

Adfirmative redirects to Cheapstuff. (Cheapstuff fails to provide an address on its web site or in Whois, though its posted phone number is in Santa Monica, California. Cheapstuff’s web site shows a variety of commercial offers with a large number of advertisements.)

Cheapstuff redirects to InfoSpace. (InfoSpace, of Bellevue, Washington, is discussed further in the next section.)

InfoSpace redirects to Google, which redirects through DoubleClick and onwards back to Finish Line — the same site my tester had been browsing in the first place.

This placement is a bad deal for Finish Line for at least two reasons. First, Google charges Finish Line a fee to access a user already at Finish Line’s site. But that’s more of a shake-down then genuine advertising: an advertiser should not have to pay to reach a user already at its site. Furthermore, Google styles its advertising as “pay per click”, promising advertisers that “You’re charged only if someone clicks your ad.” But here, the video and packet log clearly confirm that the Google click link was invoked without a user even seeing a Google ad link, not to mention clicking it. Advertisers paying high Google prices deserve high-quality ad placements, not spyware popups and click fraud.

Finally, the popup lacks the labeling specifically required by FTC precedent. Consistent with FTC’s settlement in its Direct Revenue and Zango cases, every spyware/adware popup must be labeled with the name of the program that caused the popup, along with uninstall instructions. Furthermore, the FTC has taken an appropriately dim view of advertising software installed on users’ computers without user consent. But every single Trafficsolar installation I’ve ever seen has arrived on my test computers through security exploits, without consent. For these reasons, this Trafficsolar-Google popup clearly falls afoul of applicable FTC requirements.

Critiquing InfoSpace’s role

As shown in the prior section and diagram, traffic flows through a remarkable seven intermediaries en route from Trafficsolar spyware to the victim Google advertiser. Looking at such a lengthy chain, the problem may seem intractable: How could Google effectively supervise a partner’s partner’s partner’s partner’s partner’s partner’s partner’s partner? That insurmountable challenge is exactly why Google should never have gone down this path. Instead, Google should place ads only through the companies with which Google has direct relationships.

In this instance, when traffic finally gets to Google, it comes through a predictable source: InfoSpace. It was InfoSpace, and InfoSpace alone, that distributed Google ads into the morass of subsyndicators and redistributors detailed above.

Flipping through my records of prior InfoSpace observations, I was struck by the half-decade of bad behavior. Consider:

June 2005: I showed InfoSpace placing Google ads into the IBIS Toolbar which, I demonstrated in multiple screen-capture videos, was arriving on users’ computers through security exploits (without user consent). The packet log revealed that traffic flowed from IBIS directly to InfoSpace’s Go2net.com — suggesting that InfoSpace had a direct relationship with IBIS and paid IBIS directly, not via any intermediary.

August 2005: I showed InfoSpace placing ads through notorious spyware vendor Direct Revenue (covering advertisers’ sites with unlabeled popups presenting their own PPC ads). The packet log revealed that traffic flowed from Direct Revenue directly to InfoSpace — suggesting that InfoSpace had a direct relationship with Direct Revenue and paid Direct Revenue directly, not via any intermediary.

August 2005: I showed InfoSpace placing ads through notorious spyware vendor 180solutions/Zango. The packet log revealed that traffic flowed from 180solutions directly to InfoSpace — suggesting that InfoSpace had a direct relationship with 180solutions and paid 180solutions directly, not via any intermediary.

February 2009: I showed InfoSpace placing Google ads into WhenU popups that covered advertisers’ sites with their own PPC ads.

May 2009: Again, I showed InfoSpace using WhenU to cover advertisers’ sites with their own PPC ads, through partners nearly identical to the February report.

January 2010 (last week): I showed InfoSpace’s still placing Google ads into WhenU popups and still covering advertisers’ sites with their own PPC ads.

And those are just placements I happened to write up on my public site! Combine this pattern of behavior with InfoSpace’s well-documented accounting fraud, and InfoSpace hardly appears a sensible partner for Google and the advertisers who entrust Google to manage their spending.

Nor can InfoSpace defend this placement by claiming Cheapstuff looked like a suitable place to show ads. The Cheapstuff site features no mailing address or indication of the location of corporate headquarters. WHOIS lists a “privacy protection” service in lieu of a street address or genuine email address. These omissions are highly unusual for a legitimate advertising broker. They should have put InfoSpace and Google on notice that Cheapstuff was up to no good.

This Click Fraud Undercuts Google’s Favorite Defense to Click Fraud Complaints

When an advertiser buys a pay-per-click ad and subsequently makes a sale, it’s natural to assume that sale resulted primarily from the PPC vendor’s efforts on the advertiser’s behalf. But the click fraud detailed in this article takes advantage of this assumption by faking clicks to target purchases that would have happened anyway. Then, when advertisers evaluate the PPC traffic they bought, they overvalue this “conversion inflation” traffic — leading advertisers to overbid and overpay.

Indeed, advertisers’ following Google’s own instructions will fall into the overbidding trap. Discussing “traffic quality” (i.e. click fraud and similar schemes),Google tells advertisers to “track campaign performance” for “ROI monitoring.” That is, when an advertiser sees a Google ad click followed by a sale, the advertiser is supposed to conclude that ads are working well and delivering value, and that click fraud is not a problem. Google’s detailed “Click Fraud: Anecdotes from the Front Line” features a similar approach, advising that “ROI is king,” again assuming that clicks that precede purchases must be valuable clicks.

Google’s advice reflects an overly optimistic view of click fraud. Google assumes click fraudsters will send random, untargeted traffic. But click-frauders can monitoring user activities to identify the user’s likely future purchases, just as Trafficsolar does in this example. Such a fraudster can fake the right PPC clicks to get credit for traffic that appears to be legitimate and valuable — even though in fact the traffic is just as worthless as other click fraud.

What Google Should Do

Google’s best first step remains as in my posting last week: Fire InfoSpace. Google doesn’t need InfoSpace: high-quality partners know to approach Google directly, and Google does not need InfoSpace to add further subpartners of its own.

Google also needs to pay restitution to affected advertisers. Every time Google charges an advertiser for a click that comes from InfoSpace, Google relies on InfoSpace’s promise that the click was legitimate, genuine, and lawfully obtained. But there is ample reason to doubt these promises. Google should refund advertisers for corresponding charges — for all InfoSpace traffic if Google cannot reliably determine which InfoSpace traffic is legitimate. These refunds should apply immediately and across-the-board — not just to advertisers who know how to complain or who manage to assemble exceptional documentation of the infraction.

More generally, Google must live up to the responsibility of spending other people’s money. Through its Search Network, Google takes control of advertisers’ budgets and decides, unilaterally, where to place advertisers’ ads. (Indeed, for Search Network purchases, Google to this day fails to tell advertisers what sites show their ads. Nor does Google allow opt-outs on a site-by-site basis — policies that also ought to change.) Spending others’ money, wisely and responsibly, is a weighty undertaking. Google should approach this task with significantly greater diligence and care than current partnerships indicate. Amending its AdWords Terms and Conditions is a necessary step in this process: Not only should Google do better, but contracts should confirm Google’s obligation to offer refunds when Google falls short.

I’m disappointed by Google’s repeated refusal to take the necessary precautions to prevent these scams. InfoSpace’s shortcomings are well-known, longstanding, and abundantly documented. What will it take get Google to eject InfoSpace and protect its advertisers’ budgets?

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Google Still Charging Advertisers for Conversion-Inflation Traffic from WhenU Spyware updated January 7, 2010

When an advertiser buys a pay-per-click ad and subsequently makes a sale, it’s natural to assume that sale resulted primarily from the PPC vendor’s efforts on the advertiser’s behalf. But tricky PPC platforms take advantage of this assumption by referring purchases that would have happened anyway. Then, when advertisers evaluate the PPC traffic they bought, they overvalue this “conversion inflation” traffic — leading advertisers to overbid and overpay.

In this piece, I show Google and its partners still covering popular sites with PPC advertisements promoting those same sites. I present the role of InfoSpace, the Google partner at the core of these misplacements, and I argue that Google should long ago have severed its ties to InfoSpace. I cite specific Google promises that these placements violate, and I critique Google’s contractual disclaimers that claim advertisers must pay for these bogus placements. Finally, I propose specific actions Google should take to satisfy to its obligations to advertisers.

Google and Its Partners Still Covering Advertisers’ Sites with Spyware-Delivered Popups

WhenU covers Continental with its own Google ads -- charging ad fees for traffic Continental would otherwise receive for free
WhenU covers Continental with its own Google ads — chargingad fees for traffic Continental would otherwise receive for free

As shown in the thumbnail at right and detailed in screenshots, video, and packet log, WhenU continues to cover web sites with PPC popups. Crucially, those popups show Google ads — often promoting the very same sites users are already browsing.

In the example shown at right, I browsed the Continental Airlines site. WhenU opened the popup shown at right — covering the Continental site with a list of Google ads, putting a prominent Continental ad front-and-center. Thus, Google charges Continental a fee to access a user already at Continental’s site. That’s a rotten deal for Continental: For one, an advertiser should not have to pay to reach a user already at its site. Furthermore, advertisers paying high Google prices deserve high-quality ad placements, not spyware popups.

The details of the Continental ad, as shown in the WhenU-Google popup, further entice users to click. The ad promises a “low fare guarantee” — suggesting that users who book some other way (without clicking the ad) may not enjoy that guarantee. And the ad promises to take users to the “official site” — suggesting that users who don’t click the ad will book through a site that is less than official. In fact both suggestions are inaccurate, but a reasonable user would naturally reach these conclusions based on the wording of the advertisement and the context of its appearance.

The WhenU-Google popup lacks the labeling specifically required by FTC policy. In particular, all sponsored search ads are to be labeled as such, pursuant to the FTC ‘s 2002 instructions. But look closely at the popup screenshot. On my ordinary 800×600 screen, no such label appears. I gather the required label would ordinarily appear on a sufficiently large screen, but the FTC’s policies make no exceptions for users with small to midsized screens. Indeed, as netbooks gain popularity, small screens are increasingly common.

The diagram below (left) confirms the specific intermediaries passing traffic from WhenU to Google in this instance.

The money trail: how funds flow from advertisers to Google to WhenU
(three examples persisting over ten months)
December 2009

PPC advertisers
(e.g. Continental)
money viewers
   Google   
money viewers
InfoSpace
money viewers
LocalPages
money viewers
(unknown company*)
money viewers
WhenU
May 2009

PPC advertisers
(e.g. RCN)
money viewers
   Google   
money viewers
InfoSpace
money viewers

*  LocalPages
money viewers
Nbcsearch
money viewers
LocalPages

money viewers
WhenU
February 2009

PPC advertisers
(e.g. Verizon)
money viewers
   Google   
money viewers
InfoSpace
money viewers
LocalPages
money viewers
WhenU

This observation marks the third sequence by which I have observed Google paying WhenU to cover advertisers’ sites with the advertisers’ own Google ads. The center and right diagrams (above) show the intermediaries in my May 2009 and February 2009 observations of similar placements.

The Impropriety of Google’s Relationship with InfoSpace

In all three instances I reported (as summarized in the diagram above), Google’s closest link is to InfoSpace. That is, Google pays InfoSpace, and InfoSpace pays the various entities that follow. In my view, Google’s relationship with InfoSpace is ill-advised for at least three reasons:

First, InfoSpace has a track record of improper placements of Google ads. InfoSpace is implicated in all three of the placements detailed above — misplacements that have continued over a lengthy period despite ample notice and opportunity for correction. Furthermore, I have personally observed other improper placements by InfoSpace. (Perhaps I’ll post more in a futher piece.) Google need not continue to do business with a distributor with such a poor track record.

Second, Google does not need a distributor whose business model entails farming out ad placements to subdistributors. If InfoSpace’s subdistributors seek to distribute Google ads, and to be paid for doing so, let them apply directly to Google and undergo Google’s ordinary quality control and oversight. Inserting InfoSpace as an additional intermediary serves only to lessen accountability.

Third, InfoSpace’s corporate history undermines any request for lenience or forgiveness. The Seattle Times chronicles InfoSpace’s accounting fraud in a three-part investigative report, “Dot-Con Job“, presenting 12,000+ words of analysis as well as primary source documents and even voicemail recordings. The Seattle Times byline summarizes their findings: “Investors were cashing out millions, and faithful investors were left with pennies.” Hardly a mark of trustworthiness!

These Ads Violate Google’s Promises to Users

These ad placements fall short of Google’s promises to users. By paying spyware vendors to show advertisements, Google both enlarges and prolongs the spyware problem. In particular, Google’s funding supports software that users struggle to remove from their computers. Google’s payments make it more profitable for vendors to sneak such software onto users’ computers in the first place.

Furthermore, Google’s Software Principles specifically disallow WhenU’s practices. Google’s “installation” and “upfront disclosure” principles disallow deceptive and nonconsensual WhenU installations. (I have video proof on file showing nonconsensual WhenU installations.) Google’s prohibition on “snooping” prohibits certain WhenU privacy practices, including WhenU’s historic violation of its own privacy policy (transmitting full page URLs despite a privacy policy promising “As the user surfs the Internet, URLS visited by the user … are NOT transmitted to WhenU.com or any third party server”).

Crucially, Google’s partnership with WhenU directly contradicts Google’s call for software makers and advertising intermediaries to “keep[] good company” by supervising partners. Despite that commitment, present on Google’s site for 4+ years, Google inexplicably continues its relationship with WhenU.

These Ads Violate Google’s Promises to Advertisers

These ad placements also fall short of Google’s obligations to advertisers. For example, when Google describes its Search Network, Google promises:

Ads are targeted based on a user’s search terms.   (emphasis added)

But here, the user performed no search — so there was no proper cause to display a Search Network ad or charge an advertiser a high Search Network price.

Google confirms:

On the Search Network, ads are shown … on … the search results pages of … Google’s search partners … within the Search Network. On our search partners, your ads may appear alongside or above search results, as part of a results page as a user navigates through a site’s directory, or on other relevant search pages.   (emphasis added)

A placement through a spyware popup does not meet these criteria: A spyware popup is not a “page.” Furthermore, a user browsing an ordinary web site (like the Continental site shown above) is neither “search[ing]” nor navigating a “directory,” contrary to Google’s promise that search ads are shown to users at search engines and directories.

Despite these clear promises, Google’s AdWords Terms and Conditions purport to allow these placements and any others Google might choose to foist on unsuspecting advertisers. Google requires advertisers to accept the following form contract provisions:

Customer understands and agrees that ads may be placed on … (z) any other content or property provided by a third party (‘Partner’) upon which Google places ads (‘Partner Property’).   (emphasis added)

That’s circular, uninformative, and a rotten deal. Advertisers should demand better. Nor should Google’s fine print claim the right to impose such bogus charges. Google should amend its contract to disavow charges from spyware, adware, conversion-inflation, and other schemes contrary to Google’s affirmative promises.

What Google Should Do

Google’s first step is easy: Fire InfoSpace. Google doesn’t need InfoSpace, and there’s zero reason for this relationship to continue in light of InfoSpace’s repeated failings.

Google also needs to pay restitution to affected advertisers. Every time Google charges an advertiser for a click that comes from InfoSpace, Google relies on InfoSpace’s promise that the click was legitimate, genuine, and lawfully obtained. But there is ample reason to doubt these promises. Google should refund advertisers for corresponding charges — for all InfoSpace traffic if Google cannot reliably determine which InfoSpace traffic is legitimate. These refunds should apply immediately and across-the-board — not just to advertisers who know how to complain or who manage to assemble exceptional documentation of the infraction. (Indeed, in response to my May 2009 report, I know Google provided a credit to RCN — the specific advertiser whose targeting I happened to feature in my example. But I gather Google failed to provide automatic credits to all affected advertisers, even though Google’s billing records provide ample documentation of which advertisers faced charges from which Google partners. And I understand that Google denied requests for refunds or credits from other affected advertisers.)

More generally, Google must live up to the responsibility of spending other people’s money. Through its Search Network offering, Google takes control of advertisers’ budgets and decides, unilaterally, where to place advertisers’ ads. (Indeed, for Search Network purchases, Google to this day fails to tell advertisers what sites show their ads. Nor does Google allow opt-outs on a site-by-site basis — policies that also ought to change.) Spending others’ money, wisely and responsibly, is a weighty undertaking. Google should approach this task with significantly greater diligence and care than current partnerships indicate. Amending its AdWords T&C’s is a necessary step in this process: Not only should Google do better, but contracts should confirm Google’s obligation to offer refunds when Google falls short.

I’m disappointed by how little has changed since my year-ago reports of these same practices. In a conference presentation in February 2009, I demonstrated substantially similar WhenU placements, with Google’s Rose Hagan (Senior Trademark Counsel) present in the audience. In May 2009 I wrote up these WhenU placements on my web site in great detail. Yet ten months later, the problem continues unabated. Indeed, the other misplacements I identified in May 2009 also continue: Google continues partnering with IAC SmileyCentral (deceptive browser plug-ins that induce searches when users attempt navigations), placing ads on typosquatting sites (including sites that show a company’s own ads when users mistype that company’s domain name), and, through Google Chrome, inviting users to search (and click prominent top-of-page ads) when direct navigation would better satisfy users’ requests and avoid unnecessary advertising costs for advertisers. I’m disappointed by the lack of progress when, in each instance, the improper charges are clear and well-documented. Google’s intransigence confirms the need for the Bill of Rights for Online Advertisers I proposed this fall.

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Measuring the Perpetrators and Funders of Typosquatting

Moore, Tyler, and Benjamin Edelman. “Measuring the Perpetrators and Funders of Typosquatting.” Lecture Notes in Computer Science. Springer-Verlag. Financial Cryptography and Data Security: Proceedings of the International Conference 6052 (2010). (Introduction, Web appendix.)

We describe a method for identifying “typosquatting”, the intentional registration of misspellings of popular website addresses. We estimate that at least 938,000 typosquatting domains target the top 3,264 .com sites, and we crawl more than 285,000 of these domains to analyze their revenue sources. We find that 80% are supported by pay-per-click ads, often advertising the correctly spelled domain and its competitors. Another 20% include static redirection to other sites. We present an automated technique that uncovered 75 otherwise legitimate websites which benefited from direct links from thousands of misspellings of competing websites. Using regression analysis, we find that websites in categories with higher pay-per-click ad prices face more typosquatting registrations, indicating that ad platforms such as Google AdWords exacerbate typosquatting. However, our investigations also confirm the feasibility of significantly reducing typosquatting. We find that typosquatting is highly concentrated: of typo domains showing Google ads, 63% use one of five advertising IDs, and some large name servers host typosquatting domains as much as four times as often as the web as a whole.

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How Google and Its Partners Inflate Measured Conversion Rates and Inflate Advertisers’ Costs

When advertisers measure the effectiveness of their pay-per-click ad campaigns, advertisers systematically assume additionality, i.e. that the sales that follow a paid click are sales that would not have happened without the ad platform’s assistance. This assumption offers intuitive appeal: If a user clicked an ad and then bought the advertised product, by all indications the ad platform should be thanked for finding and sending an interested customer. Or should it?

As it turns out, Google and its partners systematically inflate advertisers’ conversion rates by interceding in transactions advertisers would otherwise have received for free. This conversion-inflation syndication fraud overstates the true effectiveness of the ads Google delivers — leading advertisers to pay more than they should.

In this piece, I offer four examples of Google and its partners inflating conversions to claim credit for traffic advertisers would otherwise have received for free. In each example, an advertiser intensely measuring its conversion rate would mismeasure the true effectiveness of its ads, and would end up overpaying for traffic that is far less valuable than reporting systems suggest.

Traffic source How users are found What would have happened had Google and its partners not interceded
WhenU – adware User requests advertiser’s site. Adware covers advertiser’s site with pay-per-click listings. Advertiser’s site displays as usual, with no covering popup. User stays at advertiser’s site, and advertiser pays no PPC fee.
SmileyCentral – toolbar Reconfigured browser tricks user into running a “search” for a site’s domain name. User’s browser retains its ordinary configuration. User runs a direct navigation, and advertiser pays no PPC fee.
Typosquatting User misspells advertiser’s domain name. User’s browser shows a list of alternatives, and user selects one — reaching advertiser’s site at no charge. Or, user sees an error page, notices the misspelling, and corrects the spelling to reach the advertiser’s site without a PPC fee.
Chrome – browser suggestions User typing a web address is encouraged to run a search instead. User finishes typing the site’s web address and reaches the advertiser’s site without a PPC fee.

WhenU Covers Advertisers’ Sites with Advertisers’ Own Google Ads

WhenU covers RCN with its own Google ads -- charging ad fees for traffic RCN would otherwise have received for free.
WhenU covers RCN with its own Google ads — chargingad fees for traffic RCN would otherwise have received for free.

PPC advertisers (e.g. RCN)
money viewers
   Google   
money viewers
InfoSpace
money viewers
Nbcsearch
money viewers
LocalPages
money viewers
WhenU

The money trail – how funds flow from advertisers
to Google to WhenU.

Through popups shown to users already at advertisers’ sites, WhenU (and its partners) charge advertisers for traffic they would have otherwise received for free. Google passes along these clicks through its advertising platform, and Google charges advertisers as if these were genuine leads, even though in fact these users were already on advertisers’ sites.

In testing of May 9, 2009, I browsed the web site RCN.com. Advertising software (generously, “adware”) from WhenU popped open the window shown at right — covering more than 80% of the RCN site with a list of pay-per-click ads, among them a prominent ad for RCN. I clicked the RCN ad, and I was taken back to RCN. See screenshots detailing the full sequence, or a screen-capture video.

As a provider of high-speed Internet access (with attendant concerns for user security, PC reliability, and tech support expense), RCN is unlikely to advertise with a notorious adware program like WhenU. Nor is RCN likely to want to show its ads to users already at rcn.com — users who RCN has already managed to reach. So how did RCN’s ads end up in this unfortunate placement? Using a network monitor, I confirmed the full sequence of intermediaries: WhenU and its MediaTraffic ad system sent traffic to LocalPages, which redirected to Nbcsearch, which forwarded the traffic to Infospace, which finally passed the traffic to Google. Google in turn paid Infospace, which paid Nbcsearch, which paid LocalPages, which paid WhenU. See the diagram at right and the full packet log.

For RCN, this placement is a rotten deal. RCN has already paid to get a user to its site — perhaps via a postcard, TV advertisement, display ad, or other paid search activity. But then WhenU intercedes and puts a roadblock in front of that user, in the form of the popup at right. A typical user presented with that popup will click the RCN entry to get back to RCN and continue the signup process. But then RCN pays twice to reach a single user.

Meanwhile, if RCN is tracking conversion rates, it will notice that this WhenU/Google placement seems to have a high conversion rate — reflecting that this ad was shown to users already on the verge of signing up with RCN. So in all likelihood, RCN will increase its Google bid to attempt to obtain more traffic of similar (apparent) quality. But the supposed high conversion rate is misleading at best: Since these are users who were already at the RCN site, without any intervention by Google or WhenU, it is nonsense to credit Google or WhenU for resulting sales.

This ad placement also lacks the labeling required by FTC policy and precedent. For one, all sponsored search ads are to be labeled as such, pursuant to the FTC ‘s 2002 instructions. But look closely at the popup screenshot. On my ordinary 800×600 screen, no such label appears. Furthermore, the FTC’s Direct Revenue and Zango complaints, decisions, and orders reveal an additional duty that adware vendors specifically and clearly label each popup with, among other information, a statement that the popup is an advertisement. (See Direct Revenue Decision and Order, provision VI.(1), and Zango Decision and Order, provision VI.(1).) Here, the popup bears the WhenU icon and even a phone number, but it lacks any disclosure that the window’s listings are advertisements. I gather the required label would ordinarily appear on a sufficiently large screen, but the FTC’s policies make no exceptions for users with small screens. Indeed, as netbooks gain popularity, small screens are increasingly common.

These ad placements are particularly troubling because they have continued for months on end. I first observed substantially similar placements on February 7, 2009, though I have reason to think the placements began well before then. Furthermore, Google has been on actual notice of these practices for 3+ months: I first reported these placements to the public in my lunch keynote at the INTA Trademark Law and the Internet conference on February 10, 2009. I posted my slides that very day, and slides 23-24 show substantially this same set of relationships. Importantly, Google’s Rose Hagan, Senior Trademark Counsel, was present in the audience, and she responded to this portion of the talk by promising to investigate. But despite her presence, my clear posting of the parties responsible, and a three month opportunity to act, Google has nonetheless failed to sever these relationships.

Plenty more could be said about WhenU. I have personally observed a wide variety of deceptive WhenU installations, including even WhenU installations via security exploits. (I never had occasion to post those videos to my public site, but I have them on file.) The Google-funded StopBadware declared multiple WhenU-bundlers to be “badware” (1, 2, 3) based on WhenU’s automatic startup, disruptive pop-ups, and other “bad or undisclosed” behaviors. But I doubt Google will defend its WhenU placements, so I’ll save full critique of WhenU for another day.

IAC’s SmileyCentral Grabs Advertisers’ Organic Traffic to Show Google Ads

Standard web browsers place a search bar at top-left. Click that box, type an address, and press enter to reach a site.
Standard web browsers place a search bar at top-left. Click that box, type an address, and press enter to reach a site.

With SmileyCentral installed, a 'direct navigation' request for www.verizon.com yields search results, not the Verizon site. With SmileyCentral installed, a “direct navigation” request for www.verizon.com yields search results, not the Verizon site.

PPC advertisers (e.g. Verizon)
money viewers
   Google   
money viewers
IAC/SmileyCentral

The money trail – how funds flow from advertisers
to Google to IAC/SmileyCentral.

By reconfiguring users’ web browsers, IAC’s SmileyCentral toolbars charge advertisers for traffic they would otherwise have received for free. Google passes along these clicks through its advertising platform, and Google charges advertisers as if these were genuine leads, even though in fact these are users who were specifically and unambiguously trying to reach advertisers’ sites directly.

Since the earliest web browsers, a user seeking a particular web site clicks in the browser’s upper-left text box, types the desired address, and presses Enter. See the first inset image at right — standard Internet Explorer 6, offering exactly this layout to request a site.

But suppose a user installs the “SmileyCentral” toolbar from IAC (the advertising powerhouse that also owns Ask.com, Match.com, and more). SmileyCentral modifies longstanding browser layout by pushing a user’s Address Bar to the right, and inserting at left a search box where users naturally expect the Address Bar to appear. Then, when a user goes to the top-left box and enters a domain name, seeking a direct navigation to the specified site, SmileyCentral runs a search instead. See the second inset image at right — the result of typing www.verizon.com, then pressing Enter, into the top-left box. Notice that the user receives a list of search ads for Verizon, even though the user asked for Verizon by its correct web address.

IAC/SmileyCentral’s search results increase advertisers’ costs. Consider user behavior upon reaching the listings shown at right. In all likelihood, a user facing these listings will click one of the top links — perhaps the first listed (to verizonwireless.com) or the second (which specifically indicates it is the “Verizon Official Site”). But these are sponsored links. Every time a user clicks one of these links, Verizon pays a fee to Google, which in turn pays IAC/SmileyCentral. (To confirm Google’s role, see the packet log.)

As in the WhenU example above, this placement is a bad deal for advertisers. Had it not been for IAC/SmileyCentral’s tricky toolbar, these users would have directly reached the sites they requested. Instead, IAC/SmileyCentral grabs the users and sends them to lists of ads — saddling advertisers with unnecessary advertising expense.

Here too, advertisers are likely to be tricked if they attempt to assess the value of this traffic based on its conversion rate. The conversion rate may well be high — for these users asked for advertisers by name, suggesting that the users are nearly ready to make purchases. But the traffic is still a bad deal for advertisers: By all rights, this is still traffic advertisers should have gotten for free.

This placement is all the worse for advertisers because IAC makes ad clicks excessively easy. Even a click 230 pixels to the right of a Verizon Wireless ad would be treated as a paid click “on” that ad. See video at 0:23, and accompanying screenshot, showing that the hyperlink area extends far beyond the text of the ad.

IAC may claim that users understand that, with MyWebSearch installed, the top-left box no longer allows direct navigations by domain name or URL. But IAC often sneaks its toolbars onto users’ computers in ways that don’t obtain meaningful consent: I previously demonstrated nonconsensual installations through security exploits and undisclosed bundles. IAC’s installations often target kids (as I have repeatedly documented). And even a direct installation from Smileycentral.com places a picture of the post-installation browser layout in a bottom-of-page image, below the fold on 800×600 screens and easily overlooked on larger screens. IAC’s use of the generic “My Web Search” label (just as in “My Documents”, “My Computer”, etc.) further compounds users’ sense that this box is part of Internet Explorer. Combining IAC’s user focus with its choice of labeling and positioning, IAC creates conditions in which users are bound to be confused.

Typosquatting: Cmcast.com, MediaLogik, and Thousands More Intercept Users’ Misspellings to Show Google Ads

Requesting Cmcast.com (s.i.c.) yields a page of Google ads.
Requesting cmcast.com (s.i.c.) yields a page of Google ads.

If no typosquatter had registered Cmcast.com, a user would have reached this page and reached Comcast without charge. If no typosquatter had registered cmcast.com, a user would have reached this page and found Comcast without charge.

PPC advertisers (e.g. Comcast)
money viewers
   Google   
money viewers
Typosquatters & brokers (e.g. MediaLogik)

The money trail – how funds flow from advertisers
to Google to typosquatters.

By paying partners to register typosquatting sites and to send the resulting clicks to Google’s ad platform, Google charges advertisers for traffic they would otherwise have received for free. Google charges advertisers as if these were genuine leads. Yet had typosquatters not registered these domains, ordinary web browsers would have assisted users in reaching advertisers’ sites without charge.

A staggering number of typosquatting web sites target users who misspell the domain names of famous web sites. For example, in my INTA presentation this spring, I showed 200+ typosquatting sites all targeting variations of “cartoonnetwork.com.” I’ll have further thoughts on typosquatting in a future article. But for present purposes, two facts are most important: Typosquatting sites are overwhelmingly funded through pay-per-click ads, and these days Google is the advertising provider of choice for most typosquatters. (My preliminary analysis indicates that Google funds more than 75% of those typosquatting sites that show Google ads.)

Consider a user who misspells comcast.com, instead typing cmcast.com (s.i.c.). Such a user will receive the first screen shown at right, presenting a series of pay-per-click links for Comcast. In all likelihood, such a user will then click a paid link to Comcast — meaning Comcast has to pay Google an advertising fee. Google in turn pays the typosquatter which had the foresight to register a domain. See the packet log.

(In some instances, traffic flows from a typosquatter to one or more brokers or intermediaries, then to Google and finally to the advertiser. As to cmcast.com: The packet log confirms that Google pays MediaLogik of Hong Kong. I cannot readily determine whether MediaLogik registered this domain for its own account, or whether MediaLogik brokers ads for some other registrant. Based on the domain’s hosting in the Bahamas, its monetization through a Hong Kong service provider, and its display of Google PPC ads, it is highly unlikely that this domain was authorized by Comcast.)

Although these typosquatting sites ultimately direct users where the users were trying to go, typosquatters leave targeted advertisers importantly worse-off. Had it not been for the typosquatter, the user would have received a standard browser page identifying the typo and, in general, referring the user to the requested site without charge. See the second screenshot at right, showing a request for cmcast.com in a standard installation of Internet Explorer 6. So, even if no typosquatter had registered cmcast.com, the user would still reach Comcast with equal ease; the typosquatter does not actually make it easier for the user to reach Comcast. But notice that a standard IE6 error page shows few ads — here, just one small ad, at far right — whereas the MediaLogik page showed all ads, front and center. So passing the user’s misspelled request to a standard IE landing page, rather than to a typosquatter, would spare Comcast an expensive Google pay-per-click fee.

Notably, typosquatting exactly fits the traffic pattern detailed in preceding examples. First, Google and its partners identify users who are already trying to reach a given advertiser. Then Google and its partners intercede — here, by registering a typosquatting domain. The user thus stumbles into Google’s ad listings and clicks through to the advertiser’s site — letting Google charge the advertiser a fee, even though the user would have reached the advertiser even without Google’s assistance.

Google Chrome Suggestions Divert Users from Direct Navigation to Search

Typing 'expedia' yields a suggestion that users search Google (simply by pressing 'Enter') rather than visiting Expedia.com directly (third entry -- requiring a mouse-click or multiple keystrokes). Meanwhile, the second link ('expedia/') yields an error -- discouraging future exploration of green direct-navigation listings.
Typing “expedia” yields a suggestion that users search Google (just press “Enter”) rather than visit Expedia.com directly (third entry — requiring a mouse-click or multiple keystrokes). The second link (“expedia/”) yields an error — discouraging future exploration of green direct-navigation listings.

As users type web addresses into Google’s Chrome web browser, Chrome’s “Omnibox” address bar suggests that users run searches instead of direct navigation. See the screenshot at right, showing the Omnibox’s suggestion after I typed “Expedia” and before I typed the final “.com”.

If a user accepts Chrome’s suggestion — by clicking the “Search for …” drop-down, or by merely pressing Enter — the user is taken to a page of Google search results for the specified term. See screenshot and screen-capture video. As usual, Google’s most prominent search result is an advertisement. If the user clicks the ad, the advertiser pays a pay-per-click fee — even though the user was nearly at the advertiser’s site, for free, before Chrome interceded with its “Search for…” suggestion.

To complete a direct navigation to the Expedia site, without passing through Google search results, a user must ignore Google’s suggestion and continue typing (“.com”), click the “expedia.com” entry (third on Google’s autocomplete list), or use the keyboard (down-down-enter) to navigate manually. In principle these steps are straightforward — just a few extra seconds. But by pushing default behavior from direct navigation to search, Google makes searches that much more frequent — yielding that many more ad-clicks, that much more revenue to Google, and that much more expense for advertisers.

Chrome further encourages searching by mixing useful autocomplete direct navigation listings (e.g. “www.expedia.com/”) with nonfunctional listings. Notice that the second entry on Chrome’s autocomplete drop-down is “expedia/” (s.i.c.) — not a valid domain name. If a user clicks that entry, the user suffers a delay followed by a DNS error — hardly a good user experience. (video) By placing this nonfunctional result prominently in the autocomplete drop-down, above the one working direct link to Expedia, and in the same distinctive green font as the working direct link, Chrome discourages users from exploring direct links. After all, if the prominently-listed “expedia/” link did not work, users are less likely to try the similar-looking link Google ranked lower.

Although competing browsers also perform searches if users enter malformed text into the Address Bar, competing browsers are less pushy in suggesting and encouraging searches in lieu of direct navigation. Chrome thus extends browser norms through its increasingly forceful suggestion of search, not direct navigation, as the default way to reach a site.

Beyond its effects on advertisers’ costs, Chrome’s Omnibox raises other serious concerns too. For example, Chrome transmits users’ every navigation keystroke to Google — including what users search for, what addresses users request by name, and what addresses users begin to request but ultimately decline to visit. CNET reports EFF and EPIC staff concerned about Omnibox’s privacy implications, and I share their discomfort.

Fair Play and a Way Forward

Notice similarities across all four examples:

  • In all four examples, Google and its partners intercede to divert traffic that, but for their intervention, would reach advertisers’ sites directly — without advertisers incurring any advertising expense.
  • In all four examples, Google and its partners ultimately pass the traffic back to the advertisers users were trying to reach — but only after collecting pay-per-click advertising fees.
  • In all four examples, if an advertiser attempts to measure its conversion rate, it will conclude that it receives traffic at attractive prices — at effective cost-per-acquisition consistent with its objectives. Standard conversion rate measurements will overlook the fact that, were it not for the intervention of Google and its partners, the advertiser would have received this traffic for free.

Not all advertisers measure conversion rates. For one, some advertisers may take Google at its word, rather than attempting detailed and rigorous monitoring of Google’s effectiveness. Furthermore, for some advertisers, conversion rates are unmeasurable. (Advertisers may have offline sales process, rather than online sales. Certain advertisers may seek brand awareness rather than immediate purchases.) But for advertisers that measure conversion rates and adjust bids accordingly, inflated conversion rates are of grave concern. In particular, inflated conversion rates yield records that seem to indicate that campaigns are working well and delivering fair value, when the truth might be exactly the opposite.

Aggrieved advertisers could sue Google over these placements. But Google imposes terms and conditions that discourage advertisers from pursuing such claims. Google’s Advertising Program Terms purport to “disclaim[] all warranties … [and] guarantees regarding positioning, levels, quality, or timing of costs per click, … clicks, conversions, or any other results” (internal numbering omitted). Google further claims that “Any refunds for suspected invalid impressions or clicks are within Google’s sole discretion.” Google also insists that advertisers’ sole remedy is advertising credits (never refunds), and Google says advertisers must complain within 60 days of a disputed charge (even if advertisers did not know about the improper charges because the charges were concealed through, e.g., inflated conversion rates). I doubt whether all these harsh provisions are enforceable. But if these provisions are enforceable, they would tightly limit advertisers’ ability to obtain redress from Google. Even if these provisions are unenforceable, their mere presence serves to discourage advertisers from filing complaints, whether informal (through Google’s customer service staff) or in court.

In a recent presentation defending its competitive posture and overall approach, Google claimed “advertisers pay what a click is worth to them” (slides 17-21). But does Google have the right to charge such a fee for all traffic, even the traffic advertisers receive without any Google assistance whatsoever? Few advertisers would tolerate such charges, if presented explicitly. Nor does Google ever seek permission to charge advertisers for their existing traffic. Yet in the future Google seems to envision, all manner of ruses intercede to claim Google delivered a customer, when in fact the customer reached the advertiser’s site without bona fide assistance from Google.

More generally, when Google and its partners overstate the effectiveness of the ads they deliver, advertisers cannot make well-informed decisions about which ads to buy or how much to be willing to pay. Danny Sullivan calls AdWords pricing a “black box,” and I certainly share that sentiment. But here, Google’s actions are even worse than opacity: By claiming to have delivered traffic advertisers would have received anyway, Google tricks advertisers into paying for that traffic — and even tricks advertisers into concluding, mistakenly, that the traffic is a good deal.

It’s also hard to reconcile Google’s WhenU and IAC/SmileyCentral placements with Google’s “Software Principles” requirements. With bundled installations disclosing WhenU’s presence only midway through installation, WhenU is anything but “upfront” (contrary to Google’s “upfront disclosure” section heading). Showing the generic “My Web Search” toolbar label after users requested the distinctively-named SmileyCentral, Ask’s offering similarly flunks Google’s call for “clear behavior.” I could continue. But even if these programs satisfied Google’s criteria, they still fall short of advertisers’ reasonable expectations — for they still intercede to claim traffic advertisers they did nothing to deliver.

Looking forward, I see two key principles. First, ad platforms must deliver genuine, incremental traffic — not just intercept and repackage traffic advertisers were already going to receive for free. Second, ad platforms need to stand behind their products — abandoning one-sided attempts to disclaim responsibility, and instead offering meaningful commitments to provide what they promise. In both these respects, Google currently falls short.

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Competition among Sponsored Search Services

Edelman, Benjamin. “Competition among Sponsored Search Services.” U.S. House of Representatives, Committee on the Judiciary, Task Force on Competition Policy and Antitrust Laws, 2008. (Hearing cancelled.) (Reprinted in Working Knowledge: Google-Yahoo Ad Deal is Bad for Online Advertising.)

Last month I was asked to testify to the United States House of Representatives Committee on the Judiciary Task Force on Competition Policy and Antitrust Laws about competition among paid search providers, particularly the proposed Google-Yahoo partnership.

At the last minute, the hearing was cancelled, and I won’t be able to testify at the rescheduled session. Rather than let my draft written statement languish, I’m taking this opportunity to post the prepared testimony I had planned to offer:

Competition among Sponsored Search Services.