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]