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Re: Frequency Capping

From: Joseph Lorenzo Hall <joehall@gmail.com>
Date: Wed, 11 Jul 2012 20:29:45 -0400
Message-ID: <CACDmtYZw9G85XsisCxBvYye9=pVY1SLmwRqc6VNyDxt7=mUuHg@mail.gmail.com>
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
Received on Thursday, 12 July 2012 00:30:55 UTC

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