FTC asked to review "Big Data" merger between Alliance Data/Conversant; Also address privacy, consumer data consolidation & expansion of tracking on public across devices

[excerpt from attached letter]

Dear Chairwoman Ramirez:

We urge the FTC to review its decision of September 24, 2014, providing “early termination” of the “Big Data” acquisition by Alliance Data Systems of Conversant (formerly ValueClick). We are deeply concerned that the commission failed to examine sufficiently the consequences to competition—and to privacy—of the consolidation of two powerful sets of consumer data. This merger reflects the continuing consolidation of the consumer data marketplace, an issue that the FTC must address. The Alliance/Conversant deal also raises serious privacy concerns, including with its intended goal of further unleashing powerful tracking technologies that follow individuals across all of their devices and applications. Both companies’ play leading roles providing data for financial services targeting, and Conversant is at the forefront of online lead-generation practices. The commission’s approval of this transaction without appropriate safeguards directly undermines its role as the country’s chief privacy regulator. The FTC cannot, on the one hand, express concern about the discriminatory and privacy implications of “Big Data” and the invisible role of databrokers, but at the same time silently consent to expanded commercial surveillance of the American people…

The failure of the commission to address key consumer protection issues with this acquisition underscores the need for a greater commitment by the FTC to tackle the competition and privacy issues of today’s data-driven digital marketing era. We specifically urge the commission to launch a formal review of “Big Data” consolidation. The level of commercial data gathering on Americans is unprecedented, growing daily without respite, and is ending up in the hands of fewer companies…

In addition, this transaction illustrates the dramatic and unfettered growth of so-called “cookie-less” cross-screen/device-tracking…The commission should not wait until American privacy is further undermined through the dramatic growth of these new “cookie-less” commercial tracking practices. Action is required now