This document is a letter from the Federal Trade Commission providing guidance to search engines regarding clearly distinguishing paid search results from organic results. It summarizes a 2002 letter advising that failure to distinguish the two could be deceptive to consumers. While search engines initially complied, some have become less noticeable over time. The FTC recommends search engines use prominent shading, borders, and text labels to clearly label paid results as advertising and ensure disclosures are noticeable on different devices.
Nearly half of all consumers now open email on a mobile device, accordingto Experian. Mirrored by how fast website traffic from smartphone users(9.69%) has increased, many ecommerce businesses are scrambling
Remarketing is a term traditionally used to describe further communication with users leaving the site via e mail. Remarketing help companies to attract customers to their website. Article analysis remarketing definition, remarketing advantages and disadvantages, remarketing strategy and activities. M. Isoraite "Remarketing Features" Published in International Journal of Trend in Scientific Research and Development (ijtsrd), ISSN: 2456-6470, Volume-3 | Issue-6 , October 2019, URL: https://www.ijtsrd.com/papers/ijtsrd28031.pdf Paper URL: https://www.ijtsrd.com/management/marketing-management/28031/remarketing-features/m-isoraite
Nearly half of all consumers now open email on a mobile device, accordingto Experian. Mirrored by how fast website traffic from smartphone users(9.69%) has increased, many ecommerce businesses are scrambling
Remarketing is a term traditionally used to describe further communication with users leaving the site via e mail. Remarketing help companies to attract customers to their website. Article analysis remarketing definition, remarketing advantages and disadvantages, remarketing strategy and activities. M. Isoraite "Remarketing Features" Published in International Journal of Trend in Scientific Research and Development (ijtsrd), ISSN: 2456-6470, Volume-3 | Issue-6 , October 2019, URL: https://www.ijtsrd.com/papers/ijtsrd28031.pdf Paper URL: https://www.ijtsrd.com/management/marketing-management/28031/remarketing-features/m-isoraite
Here, there, and everywhere: Correlated online behaviors can lead to overesti...Ира Пустовит
Randall A. Lewis, Justin M. Rao, and David H. Reiley: “Here, there, and everywhere: Correlated online behaviors can lead to overestimates of the effects of advertising. Исследование, заставляющее усомниться во многих ранее принятых интернет-метриках
AMA_Corporate Attitudes and Adoption Trends of Multi-Channel and Omni-Channel...Scott Valentine, MBA, CSPO
Recognizing the need for insights into multi-channel use and OCM adoption,
Platt Retail Institute (PRI), in cooperation with the American Marketing
Association (AMA), and with the generous support of hybris software, decided
to undertake a survey of a portion of the AMA audience in January 2013. In
general, the purpose for conducting this research was:
1. To understand current and future marketing channel usage. As most
firms use various methods to reach their customers, we desire to gain
insights into current and future utilization, budget allocation, and
perceived channel ROI.
2. As organizations are being driven to adopt a more integrated marketing
approach, we desire to learn whether OCM strategies are being
implemented, or if there are plans to implement them within the next
three years. Underlying factors that are driving these plans, as well as
budgets allocated to implement these programs, were also considered.
The study also identifies the most significant business challenges faced
when implementing an OCM strategy, as well as who is primarily
responsible for making the decision to implement an OCM solution.
An Eye On Google: Re-engaging with digital marketing in response to recent FD...Sara (Weiner) Collis
Whitepaper on the May 2009 FDA guidelines for Pharmaceutical Paid Search. Includes overview, definitions, guideline interpretations, implications for marketers, and how the industry will need to reply in order to remain compliant.
This is the January 2016 issue of the Digital Marketing Report, published by the Joss Group (www.thejossgroup.com). The subscription cost is $399 US for 12 issues (one a month). The newsletter is for senior digital marketing professionals and the creative professionals who work with them.
Current Research Questions in Word of Mouth CommunicationAlexander Rossmann
Word of mouth (WOM) communication, long recognized as a highly influential source of information, has taken on new importance with the proliferation of online WOM. The rise of online forums and communities has dramatically increased the scope of word of mouth marketing, allowing consumers greater access to information from subject matter experts and other key influentials who impact new purchases. Online WOM data have been widely used in the literature to examine topics such as the impact of WOM recommendations and reviews, brand community involvement, and product adoption. For all the valuable contributions made by WOM research, a lot of important questions still remain unexplored. One is delineating the preconditions for user engagement in WOM communication; another is exploring the role of WOM content and WOM context on the efficacy of WOM in general. And there is final area where research is needed, focusing on organizational capabilities firms need in order to foster the impact of WOM communication on purchasing behavior.
A presentation entitled Impact of Online and Television Advertising on Consumer Behavior, was given at the Advertising Research Foundation’s (ARF) AM 6.0 conference held in 2011. The presentation includes, the challenges to measuring cross-platform media impacts, comscore methods, case studies and results. Presenters included Joan FitzGerald-Vice President of comScore & Alan Vaughn- Statistical Analyst at comScore.
The practice of PR has changed. This slideshow offers a view of the basics that every PR consultant should offer clients for 2012.
Probably the most exciting part of the presentation is the list of URL's at the end... Nice way to be very motivated.
IAB Europe White Paper : Native Advertising and Content Marketing - December ...SCREENVIEW
Today’s consumers are bombarded with advertising messages which could mean up to 5,000 messages each day. Combine this fact with the increasing use of ad blocking tools and the challenge becomes even more real and indeed some audiences have become unreachable via advertising. These contemporary challenges have meant that engaging formats and creativity have become key in online advertising. The IAB Europe Native Advertising and Content Marketing white paper provides insight into how native advertising can build better advertising experiences for consumers and therefore more meaningful relationships. It also provides guidance on key considerations for creating and distribution native advertising.
The white paper addresses:
How native advertising enables meaningful consumer relationships
Native advertising format types
Key considerations for executing native advertising and content-based advertising
The European landscape – how native advertising is developing across the different European markets
Here, there, and everywhere: Correlated online behaviors can lead to overesti...Ира Пустовит
Randall A. Lewis, Justin M. Rao, and David H. Reiley: “Here, there, and everywhere: Correlated online behaviors can lead to overestimates of the effects of advertising. Исследование, заставляющее усомниться во многих ранее принятых интернет-метриках
AMA_Corporate Attitudes and Adoption Trends of Multi-Channel and Omni-Channel...Scott Valentine, MBA, CSPO
Recognizing the need for insights into multi-channel use and OCM adoption,
Platt Retail Institute (PRI), in cooperation with the American Marketing
Association (AMA), and with the generous support of hybris software, decided
to undertake a survey of a portion of the AMA audience in January 2013. In
general, the purpose for conducting this research was:
1. To understand current and future marketing channel usage. As most
firms use various methods to reach their customers, we desire to gain
insights into current and future utilization, budget allocation, and
perceived channel ROI.
2. As organizations are being driven to adopt a more integrated marketing
approach, we desire to learn whether OCM strategies are being
implemented, or if there are plans to implement them within the next
three years. Underlying factors that are driving these plans, as well as
budgets allocated to implement these programs, were also considered.
The study also identifies the most significant business challenges faced
when implementing an OCM strategy, as well as who is primarily
responsible for making the decision to implement an OCM solution.
An Eye On Google: Re-engaging with digital marketing in response to recent FD...Sara (Weiner) Collis
Whitepaper on the May 2009 FDA guidelines for Pharmaceutical Paid Search. Includes overview, definitions, guideline interpretations, implications for marketers, and how the industry will need to reply in order to remain compliant.
This is the January 2016 issue of the Digital Marketing Report, published by the Joss Group (www.thejossgroup.com). The subscription cost is $399 US for 12 issues (one a month). The newsletter is for senior digital marketing professionals and the creative professionals who work with them.
Current Research Questions in Word of Mouth CommunicationAlexander Rossmann
Word of mouth (WOM) communication, long recognized as a highly influential source of information, has taken on new importance with the proliferation of online WOM. The rise of online forums and communities has dramatically increased the scope of word of mouth marketing, allowing consumers greater access to information from subject matter experts and other key influentials who impact new purchases. Online WOM data have been widely used in the literature to examine topics such as the impact of WOM recommendations and reviews, brand community involvement, and product adoption. For all the valuable contributions made by WOM research, a lot of important questions still remain unexplored. One is delineating the preconditions for user engagement in WOM communication; another is exploring the role of WOM content and WOM context on the efficacy of WOM in general. And there is final area where research is needed, focusing on organizational capabilities firms need in order to foster the impact of WOM communication on purchasing behavior.
A presentation entitled Impact of Online and Television Advertising on Consumer Behavior, was given at the Advertising Research Foundation’s (ARF) AM 6.0 conference held in 2011. The presentation includes, the challenges to measuring cross-platform media impacts, comscore methods, case studies and results. Presenters included Joan FitzGerald-Vice President of comScore & Alan Vaughn- Statistical Analyst at comScore.
The practice of PR has changed. This slideshow offers a view of the basics that every PR consultant should offer clients for 2012.
Probably the most exciting part of the presentation is the list of URL's at the end... Nice way to be very motivated.
IAB Europe White Paper : Native Advertising and Content Marketing - December ...SCREENVIEW
Today’s consumers are bombarded with advertising messages which could mean up to 5,000 messages each day. Combine this fact with the increasing use of ad blocking tools and the challenge becomes even more real and indeed some audiences have become unreachable via advertising. These contemporary challenges have meant that engaging formats and creativity have become key in online advertising. The IAB Europe Native Advertising and Content Marketing white paper provides insight into how native advertising can build better advertising experiences for consumers and therefore more meaningful relationships. It also provides guidance on key considerations for creating and distribution native advertising.
The white paper addresses:
How native advertising enables meaningful consumer relationships
Native advertising format types
Key considerations for executing native advertising and content-based advertising
The European landscape – how native advertising is developing across the different European markets
As far as digital marketing is concerned, attribution is unquestionably one of the major stakes in these last years. Nevertheless, the concept of attribution still seems to be a fuzzy subject. So what exactly is attribution and which model should you choose?
It is in order to answer these questions that a taskforce lead by Facebook dealt with the challenges of attribution.
Internet advertising an interplay among advertisers,online publishers, ad exc...Trieu Nguyen
Internet Advertising An Interplay among Advertisers,Online Publishers, Ad Exchanges and Web Users, Computational Advertising, contextual advertising, sponsored search, user behaviour targeting
New Native Advertising Guidelines and What Steps You Need to TakeCMI_Compas
he Federal Trade Commission recently released two documents outlining their policies around the transparency of native advertising. As marketers it's important to understand and implement these new guidelines. Our newest POV explains
Please visit our online professional network and join our community of Automotive Social Media Marketing professionals at http://www.ADPsocialMarketing.com
IAB Europe Report: Using Data Effectively in Programmatic V2.0 (GDPR Update)Romain Fonnier
The IAB Europe Using Data Effectively in Programmatic White Paper (first published in November 2016) has been updated to reflect the changing nature of the European data landscape. This updated version includes revised content with an additional section covering GDPR considerations and new case studies.
Ben Geach (Global Product Strategy Director at Oracle Data Cloud) led the white paper update with input from Thomas Park (Senior Product Director, Advertising Products at Adform) and Chris Hartsuiker (Manager, Privacy and Public Policy at IAB Europe).
The V 2.0 white paper addresses:
The types of data available, the benefits and challenges of each data type and key legal and privacy considerations
How to build an audience with the available data
Key considerations for using data effectively
Data in a cross-device environment and the opportunities and challenges
GDPR considerations for using data in advertising
Contents
Targeted Advertisements Definition
Who Makes It?
How they make it?
How Targeted Ads Work Video
What are The Targeted Advertisements advantages?
What are The Targeted Advertisements disadvantages?
How The Targeted Advertisements Connected with User Privacy?
What are the simple ways to avoid targeted ads?
Statistics
References
Marketing Attribution: Valuing The Customer JourneyDung Tri
Marketers want to do more than simply justify their digital spend; they want to optimize it. They’re looking to attribution to understand how different media perform so they can adjust the media mix and improve performance.
Causal Attribution - Proposing a better industry standard for measuring digit...Peter Weingard
Research conducted at Collective with Jeremy Stanley, CTO, Justin Evans, Strategy Officer, and Peter Weingard, CMO, discusses the pitfalls of current digital display measurement methods, and proposes alternative measures.
Joint ad trade letter to ag becerra re ccpa 1.31.2019Greg Sterling
We strongly support the objectives of the California Consumer Privacy Act (CCPA), but we have notable concerns around the likely negative impact on California consumers and businesses from some of the specific language in the law. We provide this initial comment to provide you with information about the significant importance of a data-driven and ad-supported online ecosystem, industry efforts to protect privacy, and in section III of the letter draw your attention to several areas that can be addressed and improved through the rulemaking process. We will provide more detailed comments over the coming weeks.
a group of locksmiths has filed a new class action lawsuit against Google, Microsoft and Yahoo. They claim the search engines (Google in particular) are deliberately “flooding” organic results with “scam locksmith listings” known to be false.
In an extensive and lengthy argument, Amazon argues that interactions with the Alexa virtual assistant are free speech. That includes both the human speech commands and the AI/robot responses. Interestingly, Amazon cites Search King v. Google for the proposition that Alexa responses are like search results and entitled to the same editorial protections accorded Google under that ruling and related case law
European Court of Justice Press Release GS Media vs. SanomaGreg Sterling
[W]hen hyperlinks are posted for profit, it may be expected that the person who posted such a link should carry out the checks necessary to ensure that the work concerned is not illegally published. Therefore, it must be presumed that that posting has been done with the full knowledge of the protected nature of the work and of the possible lack of the copyright holder’s consent to publication on the internet. In such circumstances, and in so far as that presumption is not rebutted, the act of posting a clickable link to a work illegally published on the internet constitutes a ‘communication to the public’.
Lifting the Corporate Veil. Power Point Presentationseri bangash
"Lifting the Corporate Veil" is a legal concept that refers to the judicial act of disregarding the separate legal personality of a corporation or limited liability company (LLC). Normally, a corporation is considered a legal entity separate from its shareholders or members, meaning that the personal assets of shareholders or members are protected from the liabilities of the corporation. However, there are certain situations where courts may decide to "pierce" or "lift" the corporate veil, holding shareholders or members personally liable for the debts or actions of the corporation.
Here are some common scenarios in which courts might lift the corporate veil:
Fraud or Illegality: If shareholders or members use the corporate structure to perpetrate fraud, evade legal obligations, or engage in illegal activities, courts may disregard the corporate entity and hold those individuals personally liable.
Undercapitalization: If a corporation is formed with insufficient capital to conduct its intended business and meet its foreseeable liabilities, and this lack of capitalization results in harm to creditors or other parties, courts may lift the corporate veil to hold shareholders or members liable.
Failure to Observe Corporate Formalities: Corporations and LLCs are required to observe certain formalities, such as holding regular meetings, maintaining separate financial records, and avoiding commingling of personal and corporate assets. If these formalities are not observed and the corporate structure is used as a mere façade, courts may disregard the corporate entity.
Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
Group Enterprises: In some cases, where multiple corporations are closely related or form part of a single economic unit, courts may pierce the corporate veil to achieve equity, particularly if one corporation's actions harm creditors or other stakeholders and the corporate structure is being used to shield culpable parties from liability.
Matthew Professional CV experienced Government LiaisonMattGardner52
As an experienced Government Liaison, I have demonstrated expertise in Corporate Governance. My skill set includes senior-level management in Contract Management, Legal Support, and Diplomatic Relations. I have also gained proficiency as a Corporate Liaison, utilizing my strong background in accounting, finance, and legal, with a Bachelor's degree (B.A.) from California State University. My Administrative Skills further strengthen my ability to contribute to the growth and success of any organization.
Defending Weapons Offence Charges: Role of Mississauga Criminal Defence LawyersHarpreetSaini48
Discover how Mississauga criminal defence lawyers defend clients facing weapon offence charges with expert legal guidance and courtroom representation.
To know more visit: https://www.saini-law.com/
Guide on the use of Artificial Intelligence-based tools by lawyers and law fi...Massimo Talia
This guide aims to provide information on how lawyers will be able to use the opportunities provided by AI tools and how such tools could help the business processes of small firms. Its objective is to provide lawyers with some background to understand what they can and cannot realistically expect from these products. This guide aims to give a reference point for small law practices in the EU
against which they can evaluate those classes of AI applications that are probably the most relevant for them.
Car Accident Injury Do I Have a Case....Knowyourright
Every year, thousands of Minnesotans are injured in car accidents. These injuries can be severe – even life-changing. Under Minnesota law, you can pursue compensation through a personal injury lawsuit.
1. United States of America
FEDERAL TRADE COMMISSION
600 Pennsylvania Avenue, NW
Washington, DC 20580
Division of Advertising Practices
Bureau of Consumer Protection
Mary K. Engle
Associate Director
June 24, 2013
[Name and Address]
[Name]:
In 2002, the staff of the Federal Trade Commission’s Bureau of Consumer Protection
published a letter (“2002 Search Engine Letter”) advising search engines about the potential for
consumers to be deceived, in violation of Section 5 of the FTC Act, unless search engines clearly
and prominently distinguished advertising from natural search results.1 After the 2002 Search
Engine Letter was issued, search engines embraced the letter’s guidance and distinguished any
paid search results or other advertising on their websites. Since then, however, we have
observed a decline in compliance with the letter’s guidance.
Although the ways in which search engines retrieve and present results, and the devices
on which consumers view these results, are constantly evolving, the principles underlying the
2002 Search Engine letter remain the same: consumers ordinarily expect that natural search
results are included and ranked based on relevance to a search query, not based on payment from
a third party.2 Including or ranking a search result in whole or in part based on payment is a
form of advertising. To avoid the potential for deception, consumers should be able to easily
distinguish a natural search result from advertising that a search engine delivers.
In recent years, the features traditional search engines use to differentiate advertising
from natural search results have become less noticeable to consumers, especially for advertising
located immediately above the natural results (“top ads”). Indeed, a recent online survey by a
1 Letter from Heather Hippsley, Acting Associate Director for Advertising Practices, to Gary
Ruskin, Executive Director of Commercial Alert (“2002 Search Engine Letter”), available at
http://www.ftc.gov/os/closings/staff/commercialalertletter.shtm.
2 For example, a Pew Research Center survey conducted in 2005 reported that 45% of search
engine users said they would stop using a search engine if it did not make it clear that some
results were paid or sponsored. Pew Internet & Am. Life Project, Search Engine Users: Internet
searchers are confident, satisfied and trusting – but they are also unaware and naïve, at 20 (Jan.
23, 2005), http://www.pewinternet.org/Reports/2005/Search-Engine-Users/1-Summary-of-
Findings.aspx (“2005 Pew Search Engine Survey”).
2. [Name]
June 24, 2013
Page 2 of 5
search strategies company found that nearly half of searchers did not recognize top ads as
distinct from natural search results and said the background shading used to distinguish the ads
was white.3
In addition, many general search engines now often integrate or offer specialized or
vertical search options as part of their search service. This allows consumers to narrow their
search to particular categories of information, such as news, images, local businesses, or
consumer goods. Although sometimes specialized search is just another way of organizing and
presenting a subset of natural results, in other instances, it is something different entirely.
Sometimes the results returned as part of a specialized search are based at least in part on
payments from a third party. If that is the case, it is also a form of advertising and should be
identified as such to consumers.
Given the importance of distinguishing advertising from natural results in a clear and
prominent manner, we recommend you review this letter and make any necessary changes to
conform to this guidance.
I. Clarity and Prominence of Advertising Disclosures Are Key
Even with the growing number of searches conducted on mobile devices, search apps,
and social media, the predominant means of search remains entering terms into a text-based box
and receiving search results in return. Subsequent to the 2002 letter, most search engines
engaged in this form of search have adopted similar conventions to distinguish any advertising
from natural search results, usually giving advertising results a different background color or
“shading” combined with a text label.4 To the extent that search engines continue to use this
convention, we encourage them to consider several factors to ensure that any labels and visual
cues used are sufficiently noticeable and understandable to consumers.5
3 SEOBook, Consumer Ad Awareness in Search Results, *2, 7-8 (Apr. 15, 2012),
http://www.seobook.com/consumer-ad-awareness-search-results. Earlier published research has
reported similar findings. For example, in the 2005 Pew Research Center survey, 62% of
searchers were not even aware of the distinction between paid and non-paid results, with only
18% saying they could always differentiate paid from non-paid results. 2005 Pew Search Engine
Survey at ii, 17.
4 Specifically, these conventions include: (1) labeling the advertising results as “sponsored” or
“ad”; (2) shading any advertising result with a different background color (“background
shading”); and/or (3) segregating advertising from the natural results, often placing the
advertising results above, below, or to the right-hand side of the natural results.
5 Disclosures must be “sufficiently prominent and unambiguous to change the apparent meaning
of the claims and to leave an accurate impression.” Removatron Int’l Corp. v. FTC, 884 F. 2d
1489, 1497 (1st Cir. 1989), aff’g 111 F.T.C. 206 (1988). Indeed, “simple, unequivocal”
disclosures that are “conspicuously and prominently made” are required to overcome any
3. [Name]
June 24, 2013
Page 3 of 5
We understand that there is not any one specific method for clearly and prominently
distinguishing advertising from natural search results, and that search engines may develop new
methods for distinguishing advertising results. Any method may be used, so long as it is
noticeable and understandable to consumers.6
A. Visual Cues
We have observed that, increasingly, search engines have introduced background shading
that is significantly less visible or “luminous” and that consumers may not be able to detect on
many computer monitors or mobile devices. Reliance on this method to distinguish advertising
results requires that search engines select hues of sufficient luminosity to account for varying
monitor types, technology settings, and lighting conditions.7 Accordingly, we recommend that
in distinguishing any top ads or other advertising results integrated into the natural search results,
search engines should use: (1) more prominent shading that has a clear outline; (2) a prominent
border that distinctly sets off advertising from the natural search results; or (3) both prominent
shading and a border.
B. Text Labels
In addition to the visual cues a search engine may use to distinguish advertising, it also
should have a text label that: (1) uses language that explicitly and unambiguously conveys if a
search result is advertising; (2) is large and visible enough for consumers to notice it; and (3) is
located near the search result (or group of search results) that it qualifies and where consumers
will see it.8
misleading impressions created. Thompson Medical Co., 104 F.T.C. 648, 783 (1984), aff’d, 791
F.2d 189 (D.C. Cir. 1986).
6 See FTC Policy Statement on Deception, appended to Cliffdale Assocs., Inc., 103 F.T.C. 110,
174 n.20 (1984) (“An interpretation may be reasonable even though it is not shared by a majority
of consumers in the relevant class, or by particularly sophisticated consumers. A material
practice that misleads a significant minority of reasonable consumers is deceptive.”).
7 We recognize the need for flexibility in optimizing web pages for viewing on mobile devices,
including selecting an attractive color scheme that displays nicely. However, in designing web
pages, search engines also should ensure that any visual cues used to distinguish advertising,
such as background shading, are sufficiently visible on both mobile devices and desktop
computers. Indeed, a search engine at a minimum can determine whether a web page will be
displayed on a mobile device as opposed to desktop computer, based on the operating system
detected. Consequently, we believe that search engines should consider using web pages of
different luminosities for mobile devices and desktop computers.
8 Further, if a voice interface is used to deliver search results, a search engine should make an
audio disclosure that is of an adequate volume and cadence for ordinary listeners to hear and
comprehend it.
4. [Name]
June 24, 2013
Page 4 of 5
We have observed that search engines have reduced the font size of some text labels to
identify top ads and other advertising and often locate these labels in the top right-hand corner of
the shaded area or “ad block,” as is the case with top ads. Consumers may not as readily notice
the labels when placed in the top right-hand corner, especially when the labels are presented in
small print and relate to more than one result. Web research suggests that web pages are
normally viewed from left-center to right, with substantially less focus paid to the right-hand
side.9
Thus, we recommend that search engines place any text label used to distinguish
advertising results immediately in front of an advertising result, or in the upper-left hand corner
of an ad block, including any grouping of paid specialized results, in adequately sized and
colored font.
In addition, to avoid the potential for ambiguity and deception, search engines should
consider using the same terminology to label any form of advertising delivered to consumers.
For example, if a search engine labels some advertisements as “ads,” it should consider using the
same label for any other advertisements. Using different terms to label various types of
advertisements risks confusing consumers.
II. New Search Platforms
Online search is far from static, and continues to evolve. Indeed, in the past few years,
the growth of social media and mobile apps, and the introduction of voice assistants on mobile
devices, have offered consumers new ways of getting information. Regardless of the precise
form search may take in the future, the long-standing principle of making advertising
distinguishable from natural results will remain applicable. For example, if a social network
were to stream recommended restaurants based on what a particular consumer’s social contacts
have enjoyed, it should clearly distinguish as advertising any information feeds included or
prioritized based in whole or in part on payments from a third party.
We recognize that business models for these new search platforms are changing and that
flexibility is required in developing the most effective methods for clearly and prominently
differentiating advertising from other information. To ensure that advertising is easily
distinguishable on any future search platform, we encourage businesses to consult the guidance
provided in this letter, as well as staff’s recently published guidelines for mobile and other online
advertisers, .com Disclosures: How to Make Effective Disclosures in Digital Advertising.10
9 See, e.g., Jakob Nielsen, Horizontal Attention Leans Left (Apr. 26, 2010),
http://www.useit.com/alertbox/horizontal-attention.html.
10 FTC Staff Revises Online Advertising Disclosure Guidelines: “Dot Com Disclosures”
Guidance Updated to Address Current Online and Mobile Advertising Environment (Mar. 4,
2013), http://ftc.gov/opa/2013/03/dotcom.shtm.
5. [Name]
June 24, 2013
Page 5 of 5
III. Conclusion
Search engines provide invaluable benefits to consumers. By using search engines,
consumers can find relevant and useful information, typically at no charge. At the same time,
consumers should be able to easily distinguish natural search results from advertising that search
engines deliver. Accordingly, we encourage you to review your websites or other methods of
displaying search results, including your use of specialized search, and make any necessary
adjustments to ensure you clearly and prominently disclose any advertising. In addition, as your
business may change in response to consumers’ search demands, the disclosure techniques you
use for advertising should keep pace with innovations in how and where you deliver information
to consumers.
We appreciate your cooperation in ensuring your business practices conform to the
supplemental guidance provided in this letter. Please contact Commission staff with any
questions you may have about this letter.
Very truly yours,
Mary K. Engle
Associate Director for Advertising Practices