- From: Chris Pedigo <CPedigo@online-publishers.org>
- Date: Wed, 11 Jul 2012 20:51:44 +0000
- To: Chris Mejia <chris.mejia@iab.net>, "Grimmelmann, James" <James.Grimmelmann@nyls.edu>
- CC: W3C DNT Working Group Mailing List <public-tracking@w3.org>, Mike Zaneis <mike@iab.net>, Brendan Riordan-Butterworth <Brendan@iab.net>
So, in the case of the long-tail publisher (or any publisher for that matter), the 3rd party ad-network could cap the number of times that a certain ad showed on that publisher's site. But, the ad network would have to abide by the rules for a "service provider" which means they couldn't correlate data about that user from other, unaffiliated sites. In essence, an ad network couldn't promise to cap the number of times a DNT:1 user sees a certain ad across multiple sites and over time. But, publishers could cap the number of times that a DNT:1 user sees a certain ad on their site and affiliated sites. I'm not arguing one way or the other, I just want to define the scope of we're talking about here. -----Original Message----- From: Chris Mejia [mailto:chris.mejia@iab.net] Sent: Wednesday, July 11, 2012 4:39 PM To: Chris Pedigo; Grimmelmann, James Cc: W3C DNT Working Group Mailing List; Mike Zaneis; Brendan Riordan-Butterworth Subject: Re: Frequency Capping Hi Chris, I believe we are talking about limiting 3rd-party f-capping in this thread (not something I agree with, if I wasn't clear before). As I'm sure you appreciate, the tens of thousands of small long-tail publishers who monitize their content, and thus provide their services at all, by replying on outsourced sales of their ad inventory through 3rd-party ad networks (and don't use their own ad servers to do so-- the majority) would be negatively affected under this limitation, even though they themselves are 1st-party to the user. Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | Interactive Advertising Bureau - IAB On 7/11/12 1:14 PM, "Chris Pedigo" <CPedigo@online-publishers.org> wrote: >Just a point of clarification - publishers could continue to frequency >cap advertisements on their own site or affiliated sites, correct? I >believe frequency capping could be accomplished either by the first >party or, more likely, by a service provider acting on behalf of the >first party. For this conversation about a frequency cap exception, I >believe we're talking about allowing frequency capping across multiple, >unrelated sites. > >Does anyone have a different understanding? > >-----Original Message----- >From: Grimmelmann, James [mailto:James.Grimmelmann@nyls.edu] >Sent: Wednesday, July 11, 2012 4:07 PM >To: Chris Mejia >Cc: W3C DNT Working Group Mailing List; Mike Zaneis; Brendan >Riordan-Butterworth >Subject: Re: Frequency Capping > >Chris, I think you are missing the point of my comment. > >Like Jonathan, I would like to see a detailed conversation on whether >advertisers' and publishers' interests behind frequency capping could >be addressed in ways that are not identical to frequency capping as it >is practiced today. By saying that frequency capping is required by >advertiser contracts, you were cutting off that conversation before it >could even get started. Jonathan was brainstorming for ways to limit >user exposure to the same ad that require less tracking than pure >frequency capping. I'd like to know what "good enough" frequency >capping would look like and whether it would actually be good enough. >Please help in that effort, and don't just say, "It can't be done." > >James > >On Jul 11, 2012, at 3:27 PM, Chris Mejia wrote: > >> James, >> >> Since I didn't go into the obvious details before, I will dive a >> little deeper here, as I realize now that many on this forum are not >> intimately experienced with the actual business of digital >> advertising. I hope you will appreciate that the digital advertising >> industry carefully balances business concerns with user concerns >> (thus the "win-win" model we have proven works--consumers and thus >> consumer protection are key to our success). >> >> With regards to f-capping on the side of user concerns, as I >>previously stated, advertisers AND publishers do not want to annoy >>users with repeated delivery of the same ad creative. Nor is the >>repeated delivery of the same ad creative to the same user a good >>business practice for advertisers and publishers. There is always a >>monetary cost associated with the delivery of an ad impression (such >>as the cost of ad serving and the overhead of campaign management). >> So the assertion that we just spray the same ads indiscriminately >>onto those who have turned on DNT:1 will not only be found utterly >>annoying to those users (at the additional cost of negative consumer >>brand association for those advertisers), it also costs real money. >> Remember, every single impression served costs actual money--and >>aggregated, the cost of serving billions of impressions daily is not >>trivial (take away here = nothing that happens on the Internet is >>actually "free" of costs). When a publisher's cost goes up, those >>costs are passed to the advertiser (and ultimately to the consumer). >> So when the publisher serves more ads (in this case, as a result of >>NOT f-capping a campaign), the publisher charges the advertiser for >>those additional served impressions. The idea that this increased >>cost be paid for by publishers and advertisers, on behalf of those >>users who are opting out of the publisher:consumer value exchange >>(when these consumers effectively 'devalue' themselves in the value >>exchange by turning on DNT:1), goes against the laws of market >>economics. If you think advertisers are not going to require >>f-capping, think again. Advertisers have plenty of reasonable >>business reasons to require f-capping in their contracts: i.e. >> a) not annoy consumers with overdelivery when such annoyance leads to >>negative advertiser brand association, and b) not needlessly waste ad >>impressions and money on serving ads over and over again to users who >>have opted out of the value exchange in the first place. Again, >>f-capping represents a win-win practice for industry AND users, even >>those users who have opted out with DNT:1. >> >> Since we are on the topic of publishing costs and the value exchange >> that pays for these costs so that content may be delivered to users, >> I'm very concerned about the end game of an irresponsible DNT >> specification (just as a reminder, I am FOR a responsible, balanced >> and well thought out DNT spec). In the world of ubiquitous DNT:1 >> signals that many advocates on this forum support, what do you >> suppose will be the necessary business-motivated recourse for most >> for-profit publishers? My educated guess is the rapid proliferation >> of payment gateways, with subscription services paying for content >> when advertising alone no longer supports the publishing of "free" content. >> >> In this case, is the W3C inadvertently, but consequently promoting >> the idea of a new digital divide? A divide where those with wealth >> and credit cards afford access to professionally developed content, >> while those without sufficient wealth will be blocked from accessing >> the same? If you don't think this is a realistic outcome, please >> explain precisely how professionally developed content will be paid >> for without sufficient advertising revenue. Remember, real costs >> must be paid for with real dollars. >> >> Is the answer that the reduction in revenue that a ubiquitous DNT:1 >>will undoubtedly bring, mean that publishers should scale back >>innovation, cut jobs, slow investment in the future? Should all >>consumers pay this price? >> In a free market economy, I'm going to bet that innovation will >>actually not slow; BUT it will be shifted to focus on only those who >>can afford to pay for it. Will government pay for the the (less >>financially fortunate) others? Will non-profit consumer advocates pay >>for 'the others' to access this premium content? Today, the vast >>majority of that online innovation and premium content is paid for by >>the publisher:consumer value exchange (advertising pays for >>innovation, content and access to that content). >> >> And how about the free press? Who will pay for the free press? Over >> the last 10-years we have experienced a severe reduction in >> subsidized regional newspaper content as a result of underperforming >> advertising revenues (economy/recession related?) for local news organizations. >> Consequently, to reduce costs, most regional newspapers who have >> survived (or are just barely hanging on in some cases) are >> restructuring their service to less costly Web-only publishing models. >> But even Web publishing costs money, and ad revenues per impression >> are far less online than they were in print. So when these >> newspapers (the free, advertising supported, press) cannot afford to >> self-sustain online, who will pay to replace their professional news reporting? >> Are we all comfortable moving to a government funded press model? If >> this sounds ridiculous, have a look at the trend: >> http://online.wsj.com/public/resources/documents/NEWSPAPERS0903.html. >> In conclusion, I'll step off my soapbox as soon as those who >> questions such reasonable win-win practices as f-capping step off >> theirs, and we all start working together on reasonable win-win solutions. >> >> Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | >> Interactive Advertising Bureau - IAB >> >> >> >> On 7/11/12 1:31 PM, "Grimmelmann, James" <James.Grimmelmann@nyls.edu> >> wrote: >> >>> Advertisers require frequency capping in insertion orders because ad >>> deliverers are capable of providing it. If an ad deliverer were to >>> say that it could not promise pure frequency capping for users who >>> have requested DNT, but only some best-efforts version such as the >>> one Jonathan outlines, the deliverer simply wouldn't let advertisers >>> write that term into their contracts with it. Of course, this might >>> come at some cost to the deliverer, and that tradeoff is a fair >>> subject for discussion. But let's not mistake the "requirements" of >>> current advertising contracts for the requirements of the future >>> advertising contracts that will be written in view of the DNT >>> standard and various parties' implementations of it. >>> >>> I would add that since the primary motivation of frequency capping >>> is to reduce user annoyance, users ought to be given the chance to >>> choose for themselves whether to suffer that annoyance or the >>> annoyance of being tracked for frequency capping purposes. >>> >>> James >>> >>> -------------------------------------------------- >>> James Grimmelmann Professor of Law >>> New York Law School (212) 431-2864 >>> 185 West Broadway >>> james.grimmelmann@nyls.edu<mailto:james.grimmelmann@nyls.edu> >>> New York, NY 10013 http://james.grimmelmann.net >>> >>> On Jul 11, 2012, at 12:59 PM, Chris Mejia wrote: >>> >>> Jonathan, >>> >>> Frequency capping (f-capping) is usually a contractual obligation >>>for the party responsible for delivering the ad (an ad-netork, a >>>publisher, and exchange, etc.) and is almost always required by the >>>advertiser in insertion orders (the insertion order or "IO" is the >>>contract between the parties). It looks like your assumption below >>>is that f-capping is >>> (only) a 'tactic' to increase ROI for performance campaigns. While >>>this is sometimes true (yet mostly not), it's actually rarely the >>>real motivation of doing f-capping. The requirement for f-capping >>>the delivery of a campaign to users is generally contractually >>>obligated by the advertiser, for several good reasons, but most >>>importantly for not annoying the user with multiple servings of the >>>same ad creative, over and over again in one time frame (i.e. in a >>>24-hour time period). >>> >>> As f-capping is generally contractually obligated, it's not up to >>>the deliverer of the ad to CHOOSE which campaigns to f-cap< it's a >>>REQUIREMENT to f-cap all campaigns where contractually obligated to >>>do so. F-capping has happened in television advertising for many >>>years< imagine how annoying it is when the same tv ad spot plays over >>>and over again (in fact this happens, and I'm sure we all find it >>>annoying). >>> >>> To sum up, while f-capping can sometimes increase ROI for >>>advertisers (it's not necessarily always true), it is most often >>>contractually obligated (per the Insertion Order). The primary >>>motivation for f-capping is to not annoy the user with repeated >>>serving of the same ad creative during a time period. In my >>>experience, the vast majority of f-capping is set at 1:24 or 2:24, >>>etc. (restricting the showing of a particular ad creative, 1 time in >>>24-hours, or 2-times in 24-hours). >>> >>> I hope this helps clarify the motivation for f-capping and leads to >>> mutual appreciation for the need. >>> >>> Kind Regards, >>> >>> Chris >>> >>> Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | >>> Interactive Advertising Bureau - IAB >>> >>> >>> From: Jonathan Mayer >>> <jmayer@stanford.edu<mailto:jmayer@stanford.edu>> >>> Date: Tue, 10 Jul 2012 14:26:12 -0700 >>> To: David Wainberg - NAI >>> <david@networkadvertising.org<mailto:david@networkadvertising.org>> >>> Cc: W3C DNT Working Group Mailing List >>> <public-tracking@w3.org<mailto:public-tracking@w3.org>> >>> Subject: Re: Frequency Capping >>> Resent-From: W3C DNT Working Group Mailing List >>> <public-tracking@w3.org<mailto:public-tracking@w3.org>> >>> Resent-Date: Tue, 10 Jul 2012 21:26:46 +0000 >>> >>> I'd sure like to hear more from advertising industry participants >>> about how frequency capping integrates into advertisement selection. >>> The AppNexus approach, if I read correctly, goes roughly as follows: >>> >>> 1) Begin with the set of all campaigns. >>> >>> 2) Filter by targeting criteria. >>> >>> 3) Filter by frequency capping. >>> >>> 4) Assign an expected revenue to each campaign. >>> >>> 5) Select the campaign with greatest expected revenue. >>> >>> The approach includes testing the frequency cap of every campaign >>> that matches targeting criteria. What about, instead, only testing >>> the cap for a subset of those campaigns: >>> >>> 1) Begin with the set of all campaigns. >>> >>> 2) Filter by targeting criteria. >>> >>> 3) Assign an expected revenue to each campaign. >>> >>> 4) Select the n campaigns with greatest expected revenue. >>> >>> 5) Filter by frequency capping. >>> >>> 6) Select the campaign with greatest expected revenue. >>> >>> Some relevant empirical questions include: How often are the highest >>>revenue campaigns frequency capped? How well can an ad company >>>predict which high-revenue campaigns will and won't be frequency >>>capped? >>> >>> Jonathan >>> >>> >>> On Monday, July 9, 2012 at 11:34 AM, David Wainberg wrote: >>> >>> Hi All, >>> >>> In case you haven't seen it already, I recommend Prof. Felten's >>>excellent blog on "Privacy by Design: Frequency Capping." Please also >>>read Brian O'Kelley's post in the comment section explaining what he >>>sees as the technical hurdles for these alternative frequency capping >>>methods. (I may be wrong, but I think Brian is a former student of >>>Prof. Felten.) This kind of detailed technical discussion of these >>>proposals seems very helpful. First, it helps us set reasonable >>>expectations on all sides. >>> Second, and more interesting to me, is that maybe we can have more >>>discussion and collaboration on bringing these sorts of things to >>>production. >>> >>> http://techatftc.wordpress.com/2012/07/03/privacy-by-design-frequenc >>> y >>> -capp >>> ing/ >>> >>> -David >>> >>> >>> >> > > >
Received on Wednesday, 11 July 2012 20:52:12 UTC