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]

(This is a link to the original article published in The Nation, September 2007 )

Should we be worried about Google? Ten years after the search engine was launched by two Stanford University graduate students, Google has become an empowering force and a adopted behavior that has transformed the way we access news and information, shop for goods and services and--increasingly--how we engage in politics. Who would have imagined four years ago, that Google and its subsidiary YouTube would co-sponsor debates in which ordinary citizens could directly engage with presidential candidates?

Last week, Google's stock hit an all-time high, on the strength of reports that the company will earn more this year than the $10.6 billion it earned in 2006. But while Google has almost overnight become a trusted source of information for the technologically attuned, few have thought to question the extent to which its success poses threats to both our privacy and our aspirations for the positive potential of the Internet.

Second Filing of Supplemental Materials in Support of Pending Complaint and Request for Injunction, Request for Investigation and for Other Relief

(Click to view the filing (pdf) )

Request for Audit of Google Inc. and DoubleClick Inc.

1. We are writing to request that you commence an audit of the personal information management practices of Google, Inc. (“Google”), under s.18 of the Personal Information Protection and Electronic Documents Act (PIPEDA), on the grounds that:
   • there are reasonable grounds to believe that Google is violating PIPEDA in one or more respects;
   • while other organizations may be engaging in similar privacy-invasive practices, Google dominates the online marketplace and sets industry standards for online advertising as well as search, maps, video sharing, and other online applications; and
   • the recently announced acquisition by Google of Click Holding Corp. (“DoubleClick”) could lead to even more serious and widespread privacy invasions, if action is not taken now to limit the combined entity’s collection, use, retention and disclosure of internet users’ personal information.

Google's DoubleClick Takeover: Double Data-Dealing

Comments by Jeff Chester, Center for Digital Democracy

National Press Club, September 17, 2007

Online and interactive advertising and marketing is a powerful, but still largely invisible, force shaping the future of our global society. The diversity of our news, information, and entertainment, our personal privacy, and ultimately our values related to family, work, friendship, and democracy are now linked to the structure of digital communications. Interactive marketing is at the core of the business model for much of the new media, including the personal computer and mobile platforms. A system has emerged where we are tracked, profiled, and analyzed, and then subjected to an array of sophisticated marketing communications designed to direct and change our personal behavior. Sadly, the public hasn't been well informed about what all of this means, what the choices and consequences might be, and what can be done about it. We are in a very important period of transition, where the decisions we make today about how we wish the Internet and other digital media to serve us as citizens and consumers will have profound consequences for us and for future generations.

(More - PDF below)