Behavioral Advertising - Comment from Center for Digital Democracy (CDD) and the US Public Interest

November 12, 2007 Chairman Deborah Platt Majoras Federal Trade Commission 600 Pennsylvania Ave., NW Washington, D.C. 20580 Dear Chairman Majoras: The attached "Supplemental Statement in Support of Complaint and Request for Inquiry and Injunctive Relief Concerning Unfair and Deceptive Online Marketing Practices," submitted in the "eHavioral Targeting" Town Hall docket on behalf of the Center for Digital Democracy (CDD) and the US Public Interest Research Group (USPIRG), reflects our concern that many of the issues that we raised in November 2006 ("Complaint and Request for Inquiry and Injunctive Relief Concerning Unfair and Deceptive Online Marketing Practices") remain unaddressed. The past year, moreover, has seen the continued growth of marketing technologies that have sharpened the precision with which Internet users are tracked and targeted, and these techniques are now being deployed in entirely new settings, including social networking sites. Nor, unfortunately, did the discussions at the Town Hall itself suggest that the advertising industry is prepared to offer any more meaningful response to this issue than the vague promises of self-regulation that have proved insufficient in the past. On the contrary, in the few days since the Town Hall ended, a number of announcements have been made, including ambitious new targeted advertising schemes on the part of both Facebook and MySpace, that make clear the advertising industry's ...