Comments on the W3C's proposed DNT standard

eyeReturn Marketing

110 Eglinton Ave. East

Suite 701

Toronto, Canada

M4P 2Y1

June 18, 2014

The Tracking Protection Working Group

public-tracking-comments@w3.org


Re: Proposed DNT standard

eyeReturn Marketing is Canada's leading Ad Tech company - second only to
Google in terms of RTB media spend - according to the IAB Canada's 2013
Programmatic Trading Year End Report. In addition to operating eyeDemand, a
real-time programmatic media buying platform, eyeReturn also provides a
broad suite of online marketing products and services. eyeReturn is an
active member of the NAI, the DAA, and the DAAC.

The proposed DNT standard, as published by the World Wide Web Consortium’s
(W3C) Tracking Protection Working Group (TPWG), concerns us for the
following reasons:


   -

   We believe the value of online advertising ROI is maximized when a
   healthy ecosystem of buyers and sellers exist. We are observing a trend in
   the Ad Tech industry towards domination by a small number of large players.
   We feel it is important to ensure that any standards that are adopted are
   designed in such a way that they do not benefit large incumbents, and
   rather, create a level playing field for all participants, where quality of
   product and service will dictate success.
   -

   Specifically we're concerned that the proposed definition of "Tracking"
   is unclear, and in it's current form tilts the playing field in favour of
   large players in the ecosystem that broadly have their tracking tags and
   widgets already installed on most of the pages on the web. Under the TPWG
   definition of Tracking, it appears that Google and Facebook, for example,
   would have an exclusion from the DNT system, and could ignore a DNT:1
   signal since they have very large user populations, and have "like"
   buttons and widgets pervasively installed across a great many websites.
   -

   There are technical hurdles associated with the DNT proposal for which
   there are no enshrined workarounds in the proposal. For example, since the
   DNT HTTP header value can be set by network devices and software, it
   therefore does not directly reflect users choice. For example, in the case
   of a proxy server setting the DNT signal, there could be hundreds or
   thousands of individuals behind the equipment, which is broadcasting a
   signal that none of them explicitly chose.
   -

   We don't agree that the W3C is the appropriate group to define policy
   that affects the industry, and feel that the W3C should focus on technical
   standards only. We support the notion that DNT should be described in two
   ways - one that deals with the technology and standards, and one that deals
   with policy, and that each document should stand independently. The W3C
   should focus on defining a technical standard, and not policy elements -
   such as the definition of Tracking - in the technical description.

In conclusion, we feel the proposed W3C DNT standard will introduce
complexity and inefficiency into the ecosystem, and does not address
privacy concerns of consumers. Ironically, the companies with the most
personal information are exempt from the standard. Finally it is confusing
to end users, and difficult for even experts in online ad technology and
policy to interpret.

Sincerely,



Tim Stoute, P.Eng.

CTO, eyeReturn Marketing




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*Tim Stoute, P.Eng. | CTO & Co-CEO*

*e*: tstoute@eyereturn.com  |  www.eyereturn.com

*p*: 416-929-4834 ext. #230   |  *m*: 416-274-7455
110 Eglinton Avenue East, Suite 701, Toronto ON, M4P 2Y1