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Google’s System to Control Advertising
   Inventory on Multiple Platforms
       Examples of Company Practices
       with Supporting Facts and Data

         PART 2: DESKTOP INTERNET

                18th April 2010


            Simon Buckingham

        PRIVATE AND CONFIDENTIAL
Background

- Simon Buckingham is a New York based Internet and Mobile Entrepreneur- Founder and
CEO of 3 companies

- Simon has spent nearly 20 years in the mobile industry since starting at the carrier group
Vodafone in 1991 where he launched SMS text messaging and its business partner
programs

- Perspective is as an advertiser and customer of Google in the US and globally spending
significant sums on digital marketing to raise awareness and drive sales of our products and
services

- Google has been not just a tool and a supplier with keyword search (AdWords) but also
our ad agency for digital, TV and print inventory buying

- Have been generally happy working with them until I read a blog post in December 2009
which mentioned they had extended ad campaigns to run on smartphones which I wasn’t
aware of. This led me to research Google’s mobile extensions and led ultimately to the
production of this presentation




                                                                                               2
Google’s Strategic Direction and System

We believe that Google has developed a system of automatic program and platform linkages, opt-
ins and extensions that are opaque and costly for their advertisers. These systems are designed to
extend Google’s Internet search dominance into commerce, advertising and apps on the Internet
and mobile platforms, giving them disproportionate control of advertising inventory on multiple
platforms:

 Desktop Search      Internet Advertising System                     Mobile Internet Advertising,
 and Keywords                                                        commerce and Apps
                     Google’s Product Set allows for complete
 Estimated 75%       coverage and control of Internet advertising.   Together Google and AdMob
                     Products include AdSense, AdWords,              would have an estimated 75%
 Market Share
                     DoubleClick, Mobile, Checkout, Search,          of the in-app mobile advertising
                     Nexus One, Android, YouTube, Gmail, Affiliate   market (whilst Google’s
                     Network, New separately auctioned Search        program is still in beta and with
                     Products (Sitelinks, Product Ads, Local/ Map    no ads in most of its own apps.
                     Ads, Comparison Ads)
                                                                     Unlike the Internet, Yahoo and
                     Largest single provider of Advertising and      Microsoft have no presence in
                     Audience on the Internet                        the in-app ads space




                                                                                                  3
Automatic Opt-In and Linkage of Services
Google repeatedly links separate programs to one another, leveraging its audience and
reach and strengths in one service to extend its dominant position on the Internet. By
migrating users (consumers and enterprises) from one Google product to another, Google
builds its total audience which creates new advertising inventory for it to sell. It then migrates
these products from platform to platform such as from Internet to Mobile.

Automatic opt-ins are something Google regularly uses as part of its control system for
important company initiatives like mobile and social networking

                                                                           When Google introduced
                                                                           Buzz it automatically
                                                                           linked it with Gmail and
                                                                           opted everyone’s Gmail
                                                                           contacts into the
                                                                           program. Following
                                                                           consumer outrage about
                                                                           privacy, Google
                                                                           retreated on the auto
                                                                           opt-in but Google still links
                                                                           them and leverages a
                                                                           popular existing consumer
                                                                           product- Gmail- to build
                                                                           usage of a new one- Buzz




                                                                                                           4
Linkage of Consumer Services- Chrome
“New! Find more Checkout deals while shopping at stores across the web by installing our
Chrome extension” when you click on the link, you are told that:
“Google Chrome Extensions are not supported by your browser. Please download Google
Chrome to install extensions.”




                                                                                       5
Linkage of Advertiser Programs- DoubleClick

–   “The Ad Exchange is also gaining great traction as we move all buyers and sellers into the
    latest version of the platform.” (Google Q110 Earnings Call)

–   “DoubleClick Ad Exchange 2.0 offers all the best features from 1.0 plus access to even more
    buyers and sellers through integration with Google AdWords and AdSense, a new easy to use
    streamlined UI, enhanced reporting capabilities and more”

                                                                           “Google Ad
                                                                           Manager is
                                                                           upgrading to
                                                                           DFP Small
                                                                           Business”

                                                                           Google Affiliate
                                                                           Network plus
                                                                           AdSense = 1m
                                                                           plus AdSense
                                                                           publishers can
                                                                           instantly be
                                                                           affiliates



                                                                                                 6
Linkage of Advertiser Programs- AdWords

“Upgrade your browser for faster account navigation. We suggest that
you upgrade to a recommended browser for optimal performance with
AdWords”


                                                    It is not clear
                                                    why installing
                                                    Google Chrome
                                                    enables faster
                                                    account
                                                    navigation and
                                                    optional
                                                    performance for
                                                    AdWords
                                                    advertisers




                                                                      7
Linkage of Advertiser Programs- AdSense

 Google mandated that all Google Affiliate Network members must have
 an AdSense account by October 31st 2009 to remain as affiliates. This
 allowed Google to turn all ad affiliates into ad publishers too:




                                                                   8
Linkage of Checkout fees to AdWords spend

When Google extended its Checkout commerce solution to mobile devices, it
linked the mobile transaction fees it charged to the amount of AdWords
advertising spend:




                                                                            9
Linkage of AdWords to Chrome

As you use Google’s products, you are constantly encouraged to to use other
products:



                                                      “Upgrade your
                                                      browser for faster
                                                      account navigation.
                                                      We suggest that you
                                                      upgrade to a
                                                      recommended
                                                      browser for optimal
                                                      performance with
                                                      AdWords”




                                                                              10
Extension and Automatic Opt-In of YouTube Ads

“Beginning on November 4th, 2009, all new and existing Promoted Videos may begin running
on search partner sites. Your existing bid for Search placements will be automatically
applied and your budget will remain unchanged (but keep in mind that expanding your
placements beyond YouTube may cause your budget to be consumed more quickly.”




                                                                                    11
Use of Beta Programs- Analytics for Mobile

 Google uses Beta Programs for new solutions stating that “Please also remember that this
 product is confidential, and not be shared with anyone outside of your companies under
 the terms of the Non Disclosure Agreement you signed with us.” Here is an example of us
 being invited to trial Google Analytics for Mobile:




                                                                                       12
Linkage of Live and Beta Programs
 Google’s Advertising Program Terms communicate that "Some Program features are
 identified as "Beta," "Ad Experiment," or otherwise unsupported ("Beta Features"). To the
 fullest extent permitted by law, Beta Features are provided "as is" and at Customer's option
 and risk. Customer shall not disclose to any third party any information from Beta Features,
 existence of non-public Beta Features or access to Beta Features."



                                                                Google's Product
                                                                Search program
                                                                remains a beta
                                                                program despite
                                                                having been
                                                                launched nearly a
                                                                decade ago in 2002
                                                                under the Froogle
                                                                brand




                                                                                         13
Linkage of Live and Beta Programs

-Google advertisers have told Appitalism that Google has “compelled” them to sign
up for the Google Affiliate Network and appoint Google as an affiliate selling their
products by covertly linking the Google Affiliate Network program to the
appearance of those advertiser’s products in Google’s Product Listings on its search
results page

-Google appears to shop the most popular product categories amongst competitors
who can’t afford to let their competitors occupy that prime real estate above the
fold on the Google search results page

-Instead of paying Google a Cost Per Click (CPC) through the AdWords paid search
program as before, advertisers seem now to be induced to pay Google on a Cost
Per Acquisition (CPA) percentage of revenue fee for completed purchases made on
the advertiser’s website that originate from Google

- Other successful specialist companies on the Internet such as affiliate networks like
LinkShare and Commission Junction aren’t able to compete with Google’s search
volumes and home page traffic and end up losing affiliate business to Google



                                                                                      14
Linkage of Live and Beta Programs

 In Google’s Q1 2010 earnings call, a Google executive commented:

 “One additional thing I would like to add is we definitely see an opportunity to move to
 taking a percentage of the conversions. In fact we call this CPA, cost per acquisition. One
 of the products that was developed in this area that are optimistic about is the product ad
 product. The way that works is the way the retailer just gives us all of the information about
 their product; price, listing, description, etc. and then Google actually does the targeting
 to decide where to show those ads. Then we take a percentage when the product is
 actually purchased when the user actually converts. We do see that as an opportunity to
 really simplify the process for advertisers over time and it is something we are investing in.”

 Google has now taken on the role of deciding when to show ads, which has real risk of a
 conflict of interest issues as it relates to Google’s impartiality towards consumers and other
 advertisers who are using the traditional forms of CPC advertising. Consumers may not be
 getting the best recommendations and are unlikely to know that Google has changed its
 business model in this way. Advertisers who want their products to be listed in Google’s
 search results have no choice but pay Google on a CPA basis for the best positions in the
 search results. Google now appears to think it can target goods more effectively than the
 retailers of those products can




                                                                                            15
Increasing Monetization of Home Page

 - Over time, Google seems to have gradually given into the temptation of selling
 off more and more of its search results and home page real estate through the
 introduction of new types of paid search ads programs, following a path that the
 likes of AOL and Yahoo have taken in the past

 - This is despite Google’s corporate principle that: “Advertising on Google is
 always clearly identified as a "Sponsored Link," so it does not compromise the
 integrity of our search results. We never manipulate rankings to put our partners
 higher in our search results and no one can buy better PageRank. Our users trust
 our objectivity and no short-term gain could ever justify breaching that trust.”

 - On Google’s Q12010 earnings call, they commented that: “Starting about a year
 ago we asked ourselves why do search ads just have to be text links. In organic
 search the right results might be a video, a book or an update from a social
 network. We call this universal search. But ads are also information. They are
 commercial information and in many cases it may be more useful to the users and
 the advertiser if we show a video or picture or product in the ad.”



                                                                               16
Linkage of Search Results to Use of Google Services

Paid ads dominate the search results page. Additionally, use of Google Checkout
as a payment mechanism appears to result in preferred advertiser placement in
Google’s paid search results:




                                                                            17
New Search Products- Products in Search Results

All of the product listings on the search results page here are paid ads, although
they aren’t clearly shown as product listings using a pink background:




                                                                                18
New Search Products- Site Links

Both the title of the advertiser link and the individual sub links below it are
paid for:




                                                                             19
New Search Products- Product Pictures

Advertisers can feature pictures as well as words in search ad results allowing
them to get premium placement at the top of the sponsored links and shopping
results:




                                                                             20
Integration of Ads with Google Maps

A search for this store results in one giant ad unit including a map, product
offer links and a built in location search:




                                                                         21
Integration of Ads with Google Maps

Sponsored Links are prominently featured at the top and side of the
search results page:




                                                                      22
New Search Ads- Comparison Ads

A Google UK test shows Comparison Ads between credit cards resulting in more
sponsored results, which don’t have the usual pink colored distinction:




                                                                          23
Google News: How Search Used To Work
Google’s Search Results page may have become polluted by commercial intentions over
the years but at least on Google News, the search results are determined impartially: “The
selection and placement of stories on this page were determined automatically by a
computer program.”



                                                                 It is however a computer
                                                                 program has been
                                                                 programmed by and is
                                                                 controlled by Google and
                                                                 whose algorithm is
                                                                 completely proprietary
                                                                 and resides within the
                                                                 Company’s black box of
                                                                 search algorithms- and
                                                                 algorithm that appears to
                                                                 routinely return YouTube
                                                                 video links on the search
                                                                 results page




                                                                                         24
Google’s Leverage of its Market Power

– Google has a dominant market share in Internet search which it seems intent upon
  leveraging to move into other areas of Internet commerce such as affiliate networks and
  enforce participation in new advertising programs as well as extend across Internet platforms

– Because these advertisers have traditionally relied on Google AdWords for generation of
  much of the traffic to their websites, as the prominent positions on the home page have
  become more expensive, if advertisers want to maintain a visible presence above the fold on
  Google’s search results page, they appear increasingly to have no choice but to accept
  paying Google a percentage of the revenue generated from sales their search results
  generates

– Since its advertising customers face competition within their business categories, Google is
  likely in a position to play advertisers off against each other for popular search terms on its
  homepage and significantly increase the advertiser fees it levies and change the economics
  from Cost Per Click (CPC) to Cost Per Acquisition (CPA)

– It is not the new ad programs that are concerning here, as much as the new economics that
  Google seems because of its market power to be able to attach to them



                                                                                           25
Google’s Leverage of its Market Power

– By keeping programs such as product listings in beta, and having non-public
  beta features such as the linkage between the affiliate network and product
  listings, Google appears to have been able to keep the details of the economics
  and the program linkages and non-public beta features confidential

– Google appears to use beta programs to reward compliant uncomplaining
  advertisers with participation in new product beta programs before their
  competitors do or at least at the same time

– Advertisers seem to have been unwilling to complain publicly about Google’s
  underhanded practices and constant new schemes to extract more ad dollars
  out of their budgets and deliver less value because of the lack of viable
  alternatives. Intelligent digital marketers appear to be frustrated but feel like they
  have no choice other than to accept that Google controls the vast majority of
  advertising on the Internet and will continue to leverage that strength with more
  and more costly programs

– It is highly likely that Google will continue to dominate the monetization of the
  Internet as long as its able to leverage and extend its market power


                                                                                           26
Contact Details


Feel free to contact me with any Questions or Comments on this presentation:


 Simon Buckingham
 Appitalism, Inc.
 909 Third Avenue
 28th Floor
 New York
 NY 10022

 o: 212-451-9854
 m: 917.573.6067

 e: simon.buckingham@appitalism.com

 w: http://www.appitalism.com




                                                                               27

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Google control system part 2 internet

  • 1. Google’s System to Control Advertising Inventory on Multiple Platforms Examples of Company Practices with Supporting Facts and Data PART 2: DESKTOP INTERNET 18th April 2010 Simon Buckingham PRIVATE AND CONFIDENTIAL
  • 2. Background - Simon Buckingham is a New York based Internet and Mobile Entrepreneur- Founder and CEO of 3 companies - Simon has spent nearly 20 years in the mobile industry since starting at the carrier group Vodafone in 1991 where he launched SMS text messaging and its business partner programs - Perspective is as an advertiser and customer of Google in the US and globally spending significant sums on digital marketing to raise awareness and drive sales of our products and services - Google has been not just a tool and a supplier with keyword search (AdWords) but also our ad agency for digital, TV and print inventory buying - Have been generally happy working with them until I read a blog post in December 2009 which mentioned they had extended ad campaigns to run on smartphones which I wasn’t aware of. This led me to research Google’s mobile extensions and led ultimately to the production of this presentation 2
  • 3. Google’s Strategic Direction and System We believe that Google has developed a system of automatic program and platform linkages, opt- ins and extensions that are opaque and costly for their advertisers. These systems are designed to extend Google’s Internet search dominance into commerce, advertising and apps on the Internet and mobile platforms, giving them disproportionate control of advertising inventory on multiple platforms: Desktop Search Internet Advertising System Mobile Internet Advertising, and Keywords commerce and Apps Google’s Product Set allows for complete Estimated 75% coverage and control of Internet advertising. Together Google and AdMob Products include AdSense, AdWords, would have an estimated 75% Market Share DoubleClick, Mobile, Checkout, Search, of the in-app mobile advertising Nexus One, Android, YouTube, Gmail, Affiliate market (whilst Google’s Network, New separately auctioned Search program is still in beta and with Products (Sitelinks, Product Ads, Local/ Map no ads in most of its own apps. Ads, Comparison Ads) Unlike the Internet, Yahoo and Largest single provider of Advertising and Microsoft have no presence in Audience on the Internet the in-app ads space 3
  • 4. Automatic Opt-In and Linkage of Services Google repeatedly links separate programs to one another, leveraging its audience and reach and strengths in one service to extend its dominant position on the Internet. By migrating users (consumers and enterprises) from one Google product to another, Google builds its total audience which creates new advertising inventory for it to sell. It then migrates these products from platform to platform such as from Internet to Mobile. Automatic opt-ins are something Google regularly uses as part of its control system for important company initiatives like mobile and social networking When Google introduced Buzz it automatically linked it with Gmail and opted everyone’s Gmail contacts into the program. Following consumer outrage about privacy, Google retreated on the auto opt-in but Google still links them and leverages a popular existing consumer product- Gmail- to build usage of a new one- Buzz 4
  • 5. Linkage of Consumer Services- Chrome “New! Find more Checkout deals while shopping at stores across the web by installing our Chrome extension” when you click on the link, you are told that: “Google Chrome Extensions are not supported by your browser. Please download Google Chrome to install extensions.” 5
  • 6. Linkage of Advertiser Programs- DoubleClick – “The Ad Exchange is also gaining great traction as we move all buyers and sellers into the latest version of the platform.” (Google Q110 Earnings Call) – “DoubleClick Ad Exchange 2.0 offers all the best features from 1.0 plus access to even more buyers and sellers through integration with Google AdWords and AdSense, a new easy to use streamlined UI, enhanced reporting capabilities and more” “Google Ad Manager is upgrading to DFP Small Business” Google Affiliate Network plus AdSense = 1m plus AdSense publishers can instantly be affiliates 6
  • 7. Linkage of Advertiser Programs- AdWords “Upgrade your browser for faster account navigation. We suggest that you upgrade to a recommended browser for optimal performance with AdWords” It is not clear why installing Google Chrome enables faster account navigation and optional performance for AdWords advertisers 7
  • 8. Linkage of Advertiser Programs- AdSense Google mandated that all Google Affiliate Network members must have an AdSense account by October 31st 2009 to remain as affiliates. This allowed Google to turn all ad affiliates into ad publishers too: 8
  • 9. Linkage of Checkout fees to AdWords spend When Google extended its Checkout commerce solution to mobile devices, it linked the mobile transaction fees it charged to the amount of AdWords advertising spend: 9
  • 10. Linkage of AdWords to Chrome As you use Google’s products, you are constantly encouraged to to use other products: “Upgrade your browser for faster account navigation. We suggest that you upgrade to a recommended browser for optimal performance with AdWords” 10
  • 11. Extension and Automatic Opt-In of YouTube Ads “Beginning on November 4th, 2009, all new and existing Promoted Videos may begin running on search partner sites. Your existing bid for Search placements will be automatically applied and your budget will remain unchanged (but keep in mind that expanding your placements beyond YouTube may cause your budget to be consumed more quickly.” 11
  • 12. Use of Beta Programs- Analytics for Mobile Google uses Beta Programs for new solutions stating that “Please also remember that this product is confidential, and not be shared with anyone outside of your companies under the terms of the Non Disclosure Agreement you signed with us.” Here is an example of us being invited to trial Google Analytics for Mobile: 12
  • 13. Linkage of Live and Beta Programs Google’s Advertising Program Terms communicate that "Some Program features are identified as "Beta," "Ad Experiment," or otherwise unsupported ("Beta Features"). To the fullest extent permitted by law, Beta Features are provided "as is" and at Customer's option and risk. Customer shall not disclose to any third party any information from Beta Features, existence of non-public Beta Features or access to Beta Features." Google's Product Search program remains a beta program despite having been launched nearly a decade ago in 2002 under the Froogle brand 13
  • 14. Linkage of Live and Beta Programs -Google advertisers have told Appitalism that Google has “compelled” them to sign up for the Google Affiliate Network and appoint Google as an affiliate selling their products by covertly linking the Google Affiliate Network program to the appearance of those advertiser’s products in Google’s Product Listings on its search results page -Google appears to shop the most popular product categories amongst competitors who can’t afford to let their competitors occupy that prime real estate above the fold on the Google search results page -Instead of paying Google a Cost Per Click (CPC) through the AdWords paid search program as before, advertisers seem now to be induced to pay Google on a Cost Per Acquisition (CPA) percentage of revenue fee for completed purchases made on the advertiser’s website that originate from Google - Other successful specialist companies on the Internet such as affiliate networks like LinkShare and Commission Junction aren’t able to compete with Google’s search volumes and home page traffic and end up losing affiliate business to Google 14
  • 15. Linkage of Live and Beta Programs In Google’s Q1 2010 earnings call, a Google executive commented: “One additional thing I would like to add is we definitely see an opportunity to move to taking a percentage of the conversions. In fact we call this CPA, cost per acquisition. One of the products that was developed in this area that are optimistic about is the product ad product. The way that works is the way the retailer just gives us all of the information about their product; price, listing, description, etc. and then Google actually does the targeting to decide where to show those ads. Then we take a percentage when the product is actually purchased when the user actually converts. We do see that as an opportunity to really simplify the process for advertisers over time and it is something we are investing in.” Google has now taken on the role of deciding when to show ads, which has real risk of a conflict of interest issues as it relates to Google’s impartiality towards consumers and other advertisers who are using the traditional forms of CPC advertising. Consumers may not be getting the best recommendations and are unlikely to know that Google has changed its business model in this way. Advertisers who want their products to be listed in Google’s search results have no choice but pay Google on a CPA basis for the best positions in the search results. Google now appears to think it can target goods more effectively than the retailers of those products can 15
  • 16. Increasing Monetization of Home Page - Over time, Google seems to have gradually given into the temptation of selling off more and more of its search results and home page real estate through the introduction of new types of paid search ads programs, following a path that the likes of AOL and Yahoo have taken in the past - This is despite Google’s corporate principle that: “Advertising on Google is always clearly identified as a "Sponsored Link," so it does not compromise the integrity of our search results. We never manipulate rankings to put our partners higher in our search results and no one can buy better PageRank. Our users trust our objectivity and no short-term gain could ever justify breaching that trust.” - On Google’s Q12010 earnings call, they commented that: “Starting about a year ago we asked ourselves why do search ads just have to be text links. In organic search the right results might be a video, a book or an update from a social network. We call this universal search. But ads are also information. They are commercial information and in many cases it may be more useful to the users and the advertiser if we show a video or picture or product in the ad.” 16
  • 17. Linkage of Search Results to Use of Google Services Paid ads dominate the search results page. Additionally, use of Google Checkout as a payment mechanism appears to result in preferred advertiser placement in Google’s paid search results: 17
  • 18. New Search Products- Products in Search Results All of the product listings on the search results page here are paid ads, although they aren’t clearly shown as product listings using a pink background: 18
  • 19. New Search Products- Site Links Both the title of the advertiser link and the individual sub links below it are paid for: 19
  • 20. New Search Products- Product Pictures Advertisers can feature pictures as well as words in search ad results allowing them to get premium placement at the top of the sponsored links and shopping results: 20
  • 21. Integration of Ads with Google Maps A search for this store results in one giant ad unit including a map, product offer links and a built in location search: 21
  • 22. Integration of Ads with Google Maps Sponsored Links are prominently featured at the top and side of the search results page: 22
  • 23. New Search Ads- Comparison Ads A Google UK test shows Comparison Ads between credit cards resulting in more sponsored results, which don’t have the usual pink colored distinction: 23
  • 24. Google News: How Search Used To Work Google’s Search Results page may have become polluted by commercial intentions over the years but at least on Google News, the search results are determined impartially: “The selection and placement of stories on this page were determined automatically by a computer program.” It is however a computer program has been programmed by and is controlled by Google and whose algorithm is completely proprietary and resides within the Company’s black box of search algorithms- and algorithm that appears to routinely return YouTube video links on the search results page 24
  • 25. Google’s Leverage of its Market Power – Google has a dominant market share in Internet search which it seems intent upon leveraging to move into other areas of Internet commerce such as affiliate networks and enforce participation in new advertising programs as well as extend across Internet platforms – Because these advertisers have traditionally relied on Google AdWords for generation of much of the traffic to their websites, as the prominent positions on the home page have become more expensive, if advertisers want to maintain a visible presence above the fold on Google’s search results page, they appear increasingly to have no choice but to accept paying Google a percentage of the revenue generated from sales their search results generates – Since its advertising customers face competition within their business categories, Google is likely in a position to play advertisers off against each other for popular search terms on its homepage and significantly increase the advertiser fees it levies and change the economics from Cost Per Click (CPC) to Cost Per Acquisition (CPA) – It is not the new ad programs that are concerning here, as much as the new economics that Google seems because of its market power to be able to attach to them 25
  • 26. Google’s Leverage of its Market Power – By keeping programs such as product listings in beta, and having non-public beta features such as the linkage between the affiliate network and product listings, Google appears to have been able to keep the details of the economics and the program linkages and non-public beta features confidential – Google appears to use beta programs to reward compliant uncomplaining advertisers with participation in new product beta programs before their competitors do or at least at the same time – Advertisers seem to have been unwilling to complain publicly about Google’s underhanded practices and constant new schemes to extract more ad dollars out of their budgets and deliver less value because of the lack of viable alternatives. Intelligent digital marketers appear to be frustrated but feel like they have no choice other than to accept that Google controls the vast majority of advertising on the Internet and will continue to leverage that strength with more and more costly programs – It is highly likely that Google will continue to dominate the monetization of the Internet as long as its able to leverage and extend its market power 26
  • 27. Contact Details Feel free to contact me with any Questions or Comments on this presentation: Simon Buckingham Appitalism, Inc. 909 Third Avenue 28th Floor New York NY 10022 o: 212-451-9854 m: 917.573.6067 e: simon.buckingham@appitalism.com w: http://www.appitalism.com 27