Re: Frequency Capping

We understand that the advertising industry would be very unhappy if explicit non-consent from a consumer prevented frequency capping.

Consumers will also be unhappy without f-capping as Web browsing user experience will be degraded.

>From privacy groups' perspective, there cannot be a Do Not Track standard that allows unique IDs for frequency capping of non-consenting users.

Why not?  What's your justification?  Please cite real examples of how f-capping has negatively affected any consumer's privacy.  Do you have research to share?

Fortunately this is not an impasse, because there are many possible technical methods to do f-capping without ID cookies or other strong tracking measures.  Such methods are the obvious (and as far as I can see, the only possible) compromise for f-capping.

The methods described by advocates thus far have already been debunked — performance and scale issues previously cited (see Brian O'Kelley's post to the FTC Blog).

The job of this working group is to write some compromise language that says "you can do f-capping provided it is not achieved by tracking each user or small group of users".  And the advertising industry groups can help by bringing a few of their members' key engineers to look at that language and spread the word: "yes, we can do that".

I work with and represent those key advertising industry engineers you're calling out— the overwhelming response to the proposed "work arounds" to date has been "no, we can't do that" (sorry). Again, performance and scale issues abound, not to mention needless conflicts with the fundamentals of the advertising business.  Respectfully, the job of any working group that wants to regulate another group is to provide real justification for its need to regulate, THEN solve for real-world problems. Bring real problems; justify them; cite examples; show research/data; support your case.  THEN we can start talking and brainstorming solutions.


From: Peter Eckersley <peter.eckersley@gmail.com<mailto:peter.eckersley@gmail.com>>
Date: Wed, 11 Jul 2012 17:57:58 -0700
To: Jonathan Mayer <jmayer@stanford.edu<mailto:jmayer@stanford.edu>>
Cc: Tamir Israel <tisrael@cippic.ca<mailto:tisrael@cippic.ca>>, Chris Mejia - IAB <chris.mejia@iab.net<mailto:chris.mejia@iab.net>>, "Grimmelmann, James" <James.Grimmelmann@nyls.edu<mailto:James.Grimmelmann@nyls.edu>>, W3C DNT Working Group Mailing List <public-tracking@w3.org<mailto:public-tracking@w3.org>>, Mike Zaneis - IAB <mike@iab.net<mailto:mike@iab.net>>, Brendan Riordan-Butterworth - IAB <brendan@iab.net<mailto:brendan@iab.net>>
Subject: Re: Frequency Capping

We understand that the advertising industry would be very unhappy if explicit non-consent from a consumer prevented frequency capping.

>From privacy groups' perspective, there cannot be a Do Not Track standard that allows unique IDs for frequency capping of non-consenting users.

Fortunately this is not an impasse, because there are many possible technical methods to do f-capping without ID cookies or other strong tracking measures.  Such methods are the obvious (and as far as I can see, the only possible) compromise for f-capping.

The job of this working group is to write some compromise language that says "you can do f-capping provided it is not achieved by tracking each user or small group of users".  And the advertising industry groups can help by bringing a few of their members' key engineers to look at that language and spread the word: "yes, we can do that".


On 11 July 2012 15:26, Jonathan Mayer <jmayer@stanford.edu<mailto:jmayer@stanford.edu>> wrote:
I believe Chris Mejia entirely misunderstood my note yesterday, and the thread has since careened into a conversation about the business relationships and economic value associated with frequency capping.  While those topics appear to have been educational for some participants—please continue!—that was not at all my aim.

I want to have a software engineering discussion about how frequency capping is currently implemented, and how it might be implemented in ways that better protect consumer privacy.  The CEO of AppNexus was kind enough to give details of his company's implementation which, as he explained, does not neatly integrate into a privacy-preserving approach.  Leonid Litvin from PulsePoint suggested that the algorithm I proposed—which is compatible with a privacy-preserving approach—might work.  Let's pick up from there.

Jonathan

On Wednesday, July 11, 2012 at 2:29 PM, Tamir Israel wrote:

OK Chris, I agree. I think my point was that DNT-1 is less a rejection
of the value exchange than, say, AdBlock or a similar plugin.

I understand that targeted impressions are worth more and I've heard
they generate more click-through.

I simply meant to say that DNT-1 a.) still allows impressions; and b.)
still allows contextual targeting (by site, etc.), so its value is not '0'.

Two quick side notes:
I am not remotely convinced this spec is going to lead to ubiquitous
DNT-1, and I don't think this working group is currently considering
anything that might make this the case; and

Also, I am no longer saying there is no value to F-capping for DNT-1s.
It makes sense to me that at least some types of advertisers would want
to just reach 'everyone' so would purchase, say, 10 million impressions
hoping to reach 5-10 million people (whether targeted or not). On this
scale, there is a definite risk of a DNT-1 user seeing the same
advertisement more than once, and also there is a benefit to maximizing
the ad campaign's reach, as desired, so some form of frequency capping
would seem to have value.

On 7/11/2012 5:08 PM, Chris Mejia wrote:
Thanks Tamir. I stand corrected--consumers who elect to express DNT:1 MAY
not have completely opted out of the value exchange, you're right.
However, their relative value to the value exchange certainly goes down.
To further explain, when users see un-targeted (randomly placed) ads that
are not based on their general interests, they are likely to ignore those
ads. In ignoring those misplaced ads, it's a double-whammy on industry:
we pay to serve ads that the consumer will never engage with, nor buy
their products/services. Obviously this decreases the relative value of
that consumer engagement and lowers the overall revenue the publisher may
charge an advertiser in connection with the serving of the advertiser's
ads to that non-targeted consumer. In this case, f-capping would be even
more important from a cost-savings perspective; the more non-relevant ads
I serve a consumer, the more cost associated-- f-capping limits delivery
and thus limits costs. Also, it's probably not a stretch to assume that
many advertisers may not want to serve their ads at all to consumers who
are expressing DNT:1. Enter the digital divide once again: anti-targeting
may lead to a situation where the only ads being served to 'lower-value'
DNT:1 users are the ones everyone would rather avoid (annoying content ads
that are served only on a CPA basis). Premium content ads are generally
very expensive to produce and serve (premium rich media ads cost more to
serve), so my educated guess is that advertisers wont want to take a
chance on where they will spend money serving these ads. So imagine that
premium advertisers contractually obligate their publishers to set
f-capping at 0/24 for DNT:1 users (this means that the premium ad would
never be shown to the DNT:1 user). To play the end game, if DNT:1 signals
were ubiquitous on the Web, the overall value of "free access" publishing
would go down and I believe there would be a rapid proliferation of
payment gateways in response (the money to pay for content and innovation
has to come from somewhere). Once again, enter the new digital divide
(where the 'haves' pay for access and the 'have nots" are denied access,
based on financial ability to pay), courtesy of this working group, IF we
don't get it right.

Chris Mejia | Digital Supply Chain Solutions | Ad Technology Group |
Interactive Advertising Bureau - IAB



On 7/11/12 1:15 PM, "Tamir Israel"<tisrael@cippic.ca<mailto:tisrael@cippic.ca>> wrote:

Chris -- I personally found your explanation very useful so thank you.

On 7/11/2012 3:27 PM, Chris Mejia wrote:
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.
It's not clear to me that selecting a DNT-1 means opting out of the
value exchange. The very fact that you need to F-cap those who have
chosen to send a DNT-1 seems to imply that these impressions remain
valuable, at least to some extent (or, I imagine, no ad would be served
at all and we need not worry about annoying users with repeated
exposures or maximizing ROI).

Best,
Tamir




--
Peter