Dear Chairman Majoras and Commissioners:

On behalf of the Center of the Digital Democracy, I respectfully urge you to impose
conditions designed to protect competition in the matter of Google and DoubleClick.
Since the planned acquisition was announced last spring, we have provided competition
bureau staff with information concerning both the overall competitive conditions of the
interactive advertising marketplace and specific materials related to the two companies
themselves. We have brought in a distinguished professor and one of the country's
leading experts on digital marketing—Professor Joseph Turow of the Annenberg School
at the University of Pennsylvania—to meet with competition staff. We also offered to
provide additional analysis and information, but the staff has not requested such data.
I am alarmed by reports that the commission is about to approve the merger without
imposing any of the conditions required to maintain a semblance of competition in the
interactive advertising market. Given the scale needed to compete with a combined
Google/DoubleClick, there will be insurmountable barriers to entry in the interactive ad
market.

[to read the entire document, download the PDF below]

28 Groups Tell FCC That Digital TV Rules Lack Public Benefit

August 2007

Over the past 12 years, the Federal Communications Commission (FCC) has repeatedly failed to redefine broadcasters’ public interest obligations in light of the nation’s ongoing transition to digital television, a coalition of 28 groups said in a filing at the FCC today. The groups echoed the warnings of FCC Commissioner Michael Copps that this “record of inaction” may “go down . . . as the Commission’s major failing in its efforts to move the digital transition forward.”

The groups’ filing came in the FCC’s third periodic review of the conversion of the nation’s broadcast television system from analog to digital television (“DTV”). The DTV transition will increase efficient use of the spectrum, expand consumer choice for video programming, and increase the amount of spectrum available for public safety and other wireless services. Analog TV broadcasts are to end February 17, 2009. In its rulemaking, the FCC proposed procedures and rule changes necessary to complete the transition, but once again failed to address broadcasters’ obligations to serve local communities’ educational, informational, civic, minority, disability and emergency information needs – or how these services should be disclosed to the public.

“Congress and the courts have been clear,” said Benton Foundation Chairman Charles Benton, “that the rights of viewers are paramount in broadcasting. The FCC has worked long and hard to help broadcasters make the transition to digital TV technology, a transition that could greatly increase the value of their businesses. The Commission must now do the work to define the benefits of the transition for the public, a transition that could make their airwaves more valuable to them.”

FOR IMMEDIATE RELEASE July 17, 2007

Contact: Kathryn Montgomery, American University202-494-1501
Jeff Chester, Center for Digital Democracy, 202-494-7100

Statement from
Kathryn Montgomery, PhD
Professor, American University

Co-author, “Interactive Food & Beverage Marketing:
Targeting Children and Youth in the Digital Age”
Available from www.digitalads.org

Note to Journalists covering tomorrow’s FTC/HHS Forum on Marketing, Self-Regulation, & Childhood Obesity: Professor Kathryn Montgomery of American University is a panelist who will summarize her recent research on digital food marketing targeting children and youth. In the expectation of several industry announcements, she is releasing this statement:

Center for Digital Democracy responds

(Originally published on Tech Confidential Blog)
July 2007

Jeff Chester, executive director of the Center for Digital Democracy, a leading public interest group focused on technology, responded to a recent post on the Federal Trade Commission's ongoing review of Google Inc.'s acquisition of DoubleClick Inc.:

I just want to make clear our message (Center for Digital Democracy) to the FTC and the Congress is that the Google acquisition of DoubleClick must be rejected on competition [antitrust] grounds. (We also have serious concerns about consumer data privacy as well with the proposed merger.) CDD already petitioned the FTC to investigate the growing consolidation in the online ad marketplace in a filing last November (see our Web site, www.democraticmedia.org ). There has been a steady — and alarming — trend of acquisitions and buyouts in the field over the last two or so years. Certainly the developments in the last several months are stunning — anywhere between $12-15B in deals focused on the control of consumer data, primarily for interactive advertising (Google-DoubleClick; Micrsoft-aQuantive; Yahoo!-Right Media; WPP-24/7 Real Media and the proposed private takeover of Acxiom).

FTC Responds to CDD/US PIRG November '06 Complaint on Behavioral Targeting

Agency Will Hold National "Town Meeting" on this Threat to Online Privacy
June 2007

As the nation’s consumer protection agency, the FTC endeavors to regularly update and expand its knowledge of emerging technologies and business practices to guide its law enforcement and policy objectives. In the area of online privacy, our goal is to help consumers benefit from commerce and the free flow of information online without encountering undue privacy or security tasks. For this reason, we place a high priority on learning more about ongoing developments with regard to online advertising technology and practices, and we appreciate you bringing your concerns to the Commission’s attention.