- From: Joseph Lorenzo Hall <joehall@gmail.com>
- Date: Wed, 11 Jul 2012 20:29:45 -0400
- To: Chris Mejia <chris.mejia@iab.net>
- Cc: "Grimmelmann, James" <James.Grimmelmann@nyls.edu>, David Wainberg - NAI <david@networkadvertising.org>, W3C DNT Working Group Mailing List <public-tracking@w3.org>, Mike Zaneis <mike@iab.net>, Brendan Riordan-Butterworth <Brendan@iab.net>
The core technical concern Jonathan is trying to discuss is "can f-capping be done without needing/keeping specific records about what ads an individually-identified user-agent loaded." The goal of his proposal is to try and figure out a way to accomplish f-capping in a way that doesn't transmit this kind of detail. That seems like a win-win, no? And James was referring to a term-of-art, "threat model", and saying his description of harm from f-capping as now accomplished was a tenuous example. Hopefully that's not a misrepresentation of their words but a clarification? best, Joe On Wed, Jul 11, 2012 at 7:58 PM, Chris Mejia <chris.mejia@iab.net> wrote: > James, can you please point to the actual research (or proof) you or others > have conducted that supports the notion you propose in the rather strong > accusatory statement below, that the practice of f-capping poses an > "attenuated threat model"? > > "But in some cases, information about the browsing history can be > reconstructed with some better-than-random probability by observing the > counts and combining that information with the provider's records of > campaigns. That is, to be sure, a pretty attenuated threat model." > > I haven't seen that research myself, which is curious, since I live and > breath this stuff. But there is a lot of information out there and I'm > certainly nowhere near an expert on all of it, so if it exists, let's all > review the real data. Thanks in advance for sharing data that supports your > stated hypothesis. > > Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group | > Interactive Advertising Bureau - IAB > > > > On 7/11/12 7:48 PM, "Grimmelmann, James" <James.Grimmelmann@nyls.edu> wrote: > > Pure frequency-counting has the advantage of not directly storing browsing > history. But in some cases, information about the browsing history can be > reconstructed with some better-than-random probability by observing the > counts and combining that information with the provider's records of > campaigns. That is, to be sure, a pretty attenuated threat model. But it > still involves storing some detailed information. > > I expect that some users who object to being "tracked" will consider this to > be completely fine. Some may not. As far as possible, I don't want to be > in the position of telling any of these users that they're right or wrong > about their privacy. I favor giving all of them good information about what > storage and tracking is actually happening, and giving those who object to > particular practices the means to request exclusion from them. > > James > > -------------------------------------------------- > James Grimmelmann Professor of Law > New York Law School (212) 431-2864 > 185 West Broadway james.grimmelmann@nyls.edu > New York, NY 10013 http://james.grimmelmann.net > > On Jul 11, 2012, at 4:58 PM, David Wainberg wrote: > > Hi James, > To me, the implementation of frequency capping that Brian describes is quite > privacy friendly. It records only the number of times a particular UA was > delivered a particular ad, or when was the last time that UA saw an ad from > a particular advertiser. Is that tracking? What is the privacy impact of it? > I'm not asking rhetorically. I'm very interested in hearing why what Brian > described is not already privacy-friendly enough. I honestly don't get why > this model of frequency capping would be included in DNT. > Cheers, > David > On 7/11/12 4:07 PM, Grimmelmann, James wrote: > > 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-frequency-capp > ing/ > -David > > > -- Joseph Lorenzo Hall Postdoctoral Research Fellow Media, Culture and Communication New York University https://josephhall.org/
Received on Thursday, 12 July 2012 00:30:55 UTC