Publishings Digital Consumer

Julie Brill faces a formidable task as she tries to balance what she knows are industry-wide practices that undermine privacy with the intense commercial pressures to financially harvest our data. Whether Julie can successfully act as a one woman privacy truth squad is to early to tell. She recognizes all the ways that companies take advantage of consumers today, including tracking them on every device and wherever they are. Consumer groups will expect Julie to push her powerful clients to change how the way they do business today, where—despite lip service to the contrary-- privacy is viewed as an impediment to success in the marketplace. Whether Julie Brill can survive as a privacy Wallanda is to early to tell. She will face an industry that is largely in denial of what they do with our data. Julie does have the skills to walk the privacy tightrope. She has often reconciled her decades long role as a consumer advocate with work to get industry to act more responsibly—especially regarding how they collect and use consumer information. Julie Brill has been an extraordinary FTC commissioner who has played an important role supporting the strongest possible consumer protection actions by the agency. She has a unique, deep and personal relationship with many in the consumer community. She is already missed. The hiring of Julie Brill is not only the recognition by Hogan Lovells that she is extraordinarily well-connected, knowledgable and skilled. Hogan recognizes that powerful changes are now underway, led by the EU, that will potentially transform how consumer information is treated. The new (EU) General Data Protection Regulation (GDPR)—its privacy law—is going to give new rights to the public that will force companies to treat our data differently. The uncertainty of the future of digital trade between the U.S. and EU also plays a role in Julie’s hiring I believe. With Safe Harbor struck down by the EU Court of Justice and privacy advocates threatening to see the same legal outcome for its replacement—the Privacy Shield—Hogan’s clients (and the industry) need someone like Julie who is respected by many powerful EU officials. With the US/EU trade deal that focuses on digital trade and data flows now being negotiated (Transatlantic Trade and Investment Partnership, TTIP), the stakes are enormous in whether the U.S. data companies can win favorable rules.

Coors Light, Attract Media (TouchTunes), Kinetic, Initiative and Common Ground collaborated to develop and implement the “reFRESH” music campaign, creating a fully interactive user experience across multiple screens that drove brand awareness, engagement and on-premise sales at thousands of targeted social venues. The custom-designed full-screen touchscreen experience placed users in control, enabling them to take and share real-time photos with friends and embark on a digital tour through the history and culture of hip-hop while experiencing its regional flavors and unique features.Affiliated Agency: Affiliated Agency: Kinetic Worldwide, Initiative, Common Ground.

The Center for Digital Democracy (CDD) and the U.S Public Interest Research Group (USPIRG) filed comments today in response to the Treasury Department’s request for information (RFI) on “Expanding Access to Credit through Online Marketplace Lending.” Specifically, the department sought public comment on (1) the various business models of and products offered by online marketplace lenders to small businesses and consumers; (2) the potential for online marketplace lending to expand access to credit to historically underserved market segments; and (3) how the financial regulatory framework should evolve to support the safe growth of this industry.”CDD/USPIRG’s detailed comments cautioned that “the ‘technology-enabled credit provisioning’ marketplace should not be uncritically viewed as a panacea, especially for financially underserved and economically at-risk Americans.” Rather than giving online lenders special treatment, in fact, the filing calls on the Department of the Treasury “to work with other agencies to propose or implement rules that integrate the online lending sector within the financial services regulatory sector.” Pointing out that instead of “being a new source that can support the needs of low-income or underbanked consumers,” the majority of online loans are actually going to “consumers who already have ‘prime’ ratings.” CDD and USPIRG believe that the entire financial services sector—and its use of Big Data to assess and “score” consumers—warrants closer regulatory scrutiny.“Marketplace lending should be regulated by prudential and consumer protection regulators in the same way that other financial services are,” the filing concludes, “with CFPB authority where appropriate for banks and non-banks and meaningful consumer and prudential supervision by other responsible regulators. Certainly, the lessons of 2008 provide a strong warning against allowing an under-regulated, shadow banking system to grow and pose risks to the financial system, its safety net, or the overall economy.”

1. Why has the FTC waited so long to review this serious threat to our privacy? The Federal Trade Commission’s November 16, 2015, workshop (link is external) on cross-device tracking is a examination of a very disturbing practice that emerged several years ago. The online industry’s business model of identifying specific individuals and following them on whatever device they may use (PCs, mobile, etc.), so their behaviors can be analyzed for more effective micro-targeting, is well-known. For example, companies such as Drawbridge, which “track how [an] individual user traverses the web on his or her smartphone, tablet, laptop and PC,” and analyze “billions” of pieces of data on us, has been around since 2010.[1] Cross-device targeter Tapad has been operating since 2011.[2] During the last few years there has been a veritable explosion of cross-device tracking of individuals—illustrating how our privacy has been lost regardless of what device we may use.[3] The FTC should be monitoring much more closely industry developments to expand their data-driven profiling and targeting techniques. The serious erosion of our privacy is reported daily by leading trade publications and is not a secret.[4] The commission—and other agencies responsible for consumer privacy, such as the FCC and CFPB—need to become much more proactive if they are to actually protect the public. 2. Why isn’t the FTC bringing complaints against both Google and Facebook under their respective “consent decrees” for their own cross-device surveillance of consumers? Both Facebook and Google—as the two dominant online marketing companies—have significantly expanded their own collection, analysis, and use of data from individuals for cross-device tracking. Both companies are under 20-year legal agreements with the FTC that is supposed to ensure that their practices protect our privacy.[5] But the commission has been silent regarding a major violation of our privacy, given the range of Facebook and Google cross-device practices. For example, Facebook’s acquisition of Atlas and its incorporation of new ways to engage in cross-device tracking have not been challenged by the agency.[6] Nor has the FTC pursued Google’s cross-device tracking as a consent decree matter.[7] The commission’s consent decrees are only as good as their enforcement. The FTC’s inaction regarding Facebook’s and Google’s expansion of cross-device data harvesting undermines its claims that its decrees actually protect our privacy. 3. How has the FTC’s and Department of Justice’s (DoJ) failure to stop “Big Data” mergers furthered the expansion of cross-device gathering of our information? As one of two U.S. antitrust and competition regulators, the FTC plays a key role reviewing mergers and acquisitions. Yet the agency has approved Big Data-related mergers that have further weakened consumer privacy and expanded the ability of marketers to track our behaviors across devices. While the FTC’s consumer protection and competition bureaus are separate, the commission has a responsibility to protect the public. Even with mergers reviewed by the DoJ, the FTC should speak out against deals that erode privacy and place consumers at further disadvantage through the use of Big Data. For example, Oracle was allowed to acquire both BlueKai and Datalogix—significantly expanding its sources of data used to profile Americans and to engage in cross-platform targeting. Alliance Data Systems was permitted to acquire Conversant, which bolstered its cross-device applications. The FTC should acknowledge that it is helping weaken the privacy of the American public by allowing data-driven mergers to be approved without effective consumer safeguards.[8] 4. Isn’t cross-device tracking and targeting just a part of an ever-growing commercial Big Data surveillance complex that continually gathers and uses all our information? Anyone who follows the online industry recognizes that our privacy is being continually undermined. Every major company has become its own “data broker,” harvesting all the data they directly gather on a person (when you come to their site, for example). They now merge that data with the abundance of so-called third-party information available for sale or use today. A key goal is to engage in what they call “identity management, ”which means using information on us to help influence our actions, purchases, and behaviors. Cross-device tracking is made possible through the unlimited ability companies now have to use our online and offline information without any serious consideration of our privacy.[9] 5. What is the role that Big Data companies and technologies—such as Data Management Platforms (DMPs)—play in cross-device tracking of individuals? The most powerful U.S. companies are using sophisticated data engines and analytics to gather data on individuals. The growing use of technologies such as DMPs, along with the real-time data targeting now embraced by the industry (known as “programmatic”) is at the core of cross-device practices.[10] While the FTC is aware of these practices, it has not taken any actions to protect consumers.[11] 6. Isn’t the gathering of information from our use of mobile phones, including for cross-device targeting, a major privacy violation? The answer is yes. The mobile phone is the digital spy in our pockets that we take and use nearly everywhere. Gaining access and insights from our mobile phones serves as a veritable digital gold mine for brands and advertisers. Marketers continually research how we use mobile devices, in order to help their clients identify our actual or intended location, as well other data about us (such as income, race, ethnicity, and gender). Companies such as Facebook, Google, and many others have developed ingenious ways to encourage consumers to use “apps” that, once they are downloaded, report on our actions. Google, for example, explains they can help marketers understand how to take advantage of what they call a person’s “micro-moments”--when through the use of our mobile phone we reveal we are searching for a product, store, activity or location.[12] Cross-device tracking and targeting is fueled by the unchecked data gathering from our mobile devices.[13] 7. Will the FTC address how cross-device tracking is helping marketers and brands reach us when we are in retail, grocery stores, and other “real-world” locations? As we use our phone or tablet to search for information, download coupons, or scan for price information, these signals allow marketers to learn about our location and quickly connect data they have about us. So-called “hyper-location” tracking enables companies to identify what neighborhoods we live and work in, for example. As stores deploy so-called “beacons,” Wi-Fi-networks, “geo-fences,” and other ways to connect to people in and around stores, the data they gather from our use of multiple devices becomes more complex and valuable to them.[14] Online and offline distinctions are quickly fading, as cross-device tracking merges with sophisticated data targeting services. 8. Can the FTC protect consumers from cross-device tracking when we watch video online? There is an explosion of video consumption, as more people use their mobile devices to watch online video content. Internet-delivered video to TV’s (so-called “over-the-top”) is another key way we see such programming. Incorporating our video viewing as part of the cross-device tracking apparatus is the latest way our media behaviors are being closely observed, whether we watch on small or large-screen devices.[15] 9. Will the FTC investigate how consumers are tracked and analyzed by cross-device “measurement” services? Measurement is built in to today’s tracking and targeting online system. Marketers wish to know whether we see an ad or promotional message and how we responded. Since we use multiple devices, measurement techniques now reflect an analysis of what we do on all our devices. With advances in measurement having a direct impact on our privacy, as well as with the transactions we make, the commission should investigate the impact of cross-platform “attribution” techniques now broadly deployed.[16] 10. Will the FTC call on the online industry to “cease and desist” from cross-device tracking until privacy safeguards can be proposed and implemented? The online ad lobby has—for decades—worked to keep the FTC relatively powerless to protect privacy. It has opposed calls to provide the agency with “rulemaking” authority so it could develop safeguards that would protect the public.[17] The lack of FTC authority to effectively address privacy threats is a key reason why U.S. data-driven marketers are able to expand their commercial surveillance activities. Despite its lack of power to require companies to engage in a moratorium on cross-device tracking, the FTC should use its moral authority. The commission should declare that the use of cookie syncing, probabilistic or deterministic attribution, unique identifiers, and other methods of stealthily following us from device to device should not be permitted. Leading data companies such as Google and Facebook, digital marketing trade groups such as the Interactive Advertising Bureau and Mobile Marketing Association, data brokers such as Axciom, Oracle, and Merkle, and cross-platform companies such as Tapad and Drawbridge should all be asked to support the commission’s call to stop the tracking of individuals across devices. During the period established for the data-gathering moratorium, the FTC should propose safeguards. The commission’s policies should empower individuals to decide whether and how they can be tracked and analyzed on any device. It’s time for action by the FTC. It knows that Americans confront the loss of their privacy—and it should speak out against the eavesdropping practices that enable online companies to gather data on us—whether we use a PC, mobile phone, or even TV. [1] http://adage.com/article/digital/drawbridge-raises-14-million-vc-investm... (link is external) [2] http://adexchanger.com/press-release/tapad-announces/;http://techcrunch.... (link is external) [3] http://bits.blogs.nytimes.com/2013/10/10/a-senator-raises-privacy-questions-about-cross-device-tracking/?_r=0 (link is external); http://blogs.teradata.com/teradata-applications/connecting-the-dots-at-t... (link is external) http://adexchanger.com/ad-exchange-news/data-management-platforms-are-ev... (link is external) [4] https://econsultancy.com/blog/62754-cross-device-measurement-in-google-analytics-will-turn-mobile-marketing-on-its-head/ (link is external); https://www.admonsters.com/blog/fight-fragmentation-grasping-cross-device-audience-behavior (link is external); “Mobile creativity: Track mobile performance. AdMap. September 2015. Warc.com. Personal copy. [5] https://www.ftc.gov/news-events/press-releases/2011/11/facebook-settles-ftc-charges-it-deceived-consumers-failing-keep (link is external); https://www.ftc.gov/enforcement/cases-proceedings/102-3136/google-inc-ma... (link is external) [6] http://atlassolutions.com/why-atlas/cross-everything/ (link is external); http://atlassolutions.com/2015/09/02/in-app-conversion-measurement/ (link is external); http://atlassolutions.com/2015/09/17/cross-everything-dilemma/ (link is external); http://atlassolutions.com/2015/05/11/the-4cs/ (link is external); https://www.facebook.com/business/news/cross-device-measurement (link is external); http://digiday.com/platforms/omnicom-adds-atlas-tags-doubleclick-served-... (link is external) [7] http://doubleclickadvertisers.blogspot.com/2015/06/cross-device-conversion-metrics-come-to.html (link is external); http://adexchanger.com/online-advertising/google-adds-cross-device-metrics-to-doubleclick-partially-answers-facebooks-people-power/ (link is external); https://support.google.com/ds/answer/6139741?hl=en (link is external); https://www.youtube.com/watch?v=qFodrj2Drxg (link is external); http://adwords.blogspot.com/2013/10/estimated-total-conversions.html (link is external); http://adage.com/article/digital/google-tests-desktop-mobile-retargeting... (link is external) [8] https://www.oracle.com/marketingcloud/products/data-management-platform/id-graph.html (link is external); https://www.oracle.com/marketingcloud/products/cross-channel/mobile-marketing.html (link is external); http://adexchanger.com/data-exchanges/oracle-links-cross-platform-ids-touts-data-neutrality/ (link is external); http://www.bluekai.com/mobiledmp/ (link is external); http://www.tapad.com/press-release/tapads-cross-device-data-now-integrated-into-oracle-data-cloud/ (link is external); http://techcrunch.com/2015/05/04/drawbridge-cross-device/ (link is external); http://www.conversantmedia.com/digital-marketing-product-overview (link is external); https://www.quantcast.com/audience-grid/ (link is external) [9] http://adexchanger.com/mobile/google-allows-targeted-ads-based-on-first-party-data/ (link is external); http://liquid.pch.com/press/case-for-first-party-data-in-a-third-party-world/ (link is external); http://www.krux.com/blog/data-management/cross-device-identity-management-the-path-to-one-to-one-marketing/ (link is external); http://www.merkleinc.com/what-we-do/marketing-technology/merkle-data-management-cloud/connected-recognition#.Vkjj7craNyo (link is external); http://www.drawbrid.ge/technology (link is external); [10] https://www.neustar.biz/marketing-solutions (link is external); https://www.neustar.biz/blog/cross-device-dmp-as-the-unifying-layer-in-the-adtech-stack (link is external); http://www.lotame.com/resource/the-cross-device-question/ (link is external); http://blogs.adobe.com/digitalmarketing/digital-marketing/adobe-audiencemanager-takes-cross-device-targeting-new-level/ (link is external); http://www.mediapost.com/publications/article/237039/cross-device-marketing-no-longer-hypothetical-use.html (link is external); https://radiumone.com/products/advertiser/programmatic/ (link is external); http://www.digilant.com/digilant-announces-partnership-with-crosswise-to... (link is external) [11] http://www.mediapost.com/publications/article/242295/ftc-consumer-protec... (link is external) [12] http://www.nielsen.com/us/en/press-room/2015/exelate-expands-its-mobile-user-dataset-by-billions-of-monthly-interactions-with-pushspring.html (link is external); https://www.thinkwithgoogle.com/topics/mobile.html (link is external); https://developers.facebook.com/docs/app-ads/measuring/installs-and-in-app-conversions (link is external); http://doubleclickadvertisers.blogspot.com/2015/11/active-view-updates-improved-cross.html (link is external); https://www.fiksu.com/about/news-releases/precision-audience-targeting-w... (link is external) ; https://www.kochava.com/aol-partners-kochava-expand-programmatic-targeting-attribution-mobile-apps/ (link is external); http://adexchanger.com/mobile/kochava-attempts-to-crack-the-cross-device-attribution-code/ (link is external); https://www.fiksu.com/technology/audience-targeting (link is external); http://www.pushspring.com/news.html?post=124 (link is external) [13] http://streetfightmag.com/2015/06/02/why-cross-device-matching-will-transform-the-mobile-advertising-industry/ (link is external); http://www.marinsoftware.com/resources/whitepapers/the-cross-device-targeting-playbook-for-display-advertisers (link is external); http://www.marinsoftware.com/resources/whitepapers/the-cross-device-targ... (link is external) [14] http://www.criteo.com/resources/cross-device-advertising-how-to-navigate-the-next-big-opportunity-in-mobile-marketing/ (link is external); http://developer.android.com/training/location/geofencing.html (link is external); http://www.aislelabs.com/blog/2014/04/29/aislelabs-launches-the-first-marketing-automation-platform-for-physical-retail-locations/ (link is external); http://www.huffingtonpost.co.uk/jon-buss/cross-device-use_b_6969120.html (link is external) [15] http://www.experian.com/marketing-services/cross-device-video-analysis.html (link is external); https://www.doubleclickbygoogle.com/articles/?category=video&product=all&type=whitepaper (link is external); http://www.videologygroup.com/industry-insights/P40/programmatic-tv-driving-multi-screen-conversation/#.VkjyoMraNyo (link is external); https://www.tubemogul.com/cross-channel-advertising/ (link is external) [16] http://adexchanger.com/digital-tv/comscore-dives-deeper-into-cross-platform-video-measurement/ (link is external); http://cimm-us.org/cimms-annual-summit-examines-cross-platform-media-mea... 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The FTC requested that comments for the upcoming October 30, 2015 workshop on lead generation be submitted by September 20th so that issues could be addressed during the sessions. USPIRG and CDD submitted initial comments, which are attached below and also summarized. One of our findings from a recent analysis of the online "lead gen" marketplace was that digital industry leaders--including Google and Facebook--engage and support online lead generation in ways that raise substantive consumer protection concerns. USPIRG and CDD have been working for the last several years to encourage policymakers to rein-in lead generatio activities, especially those that play a role promoting financial products that can be expensive and harmful to consumers. We have written background papers on lead generation and payday loans, its use by for-profit colleges, and how Hispanics are targeted, for example. At its workshop, follow-up report and thru new enforcement activities, the FTC needs to analyze and address how contemporary online lead generation embodies a panoply of applications and tactics to acquire, use, and often share or sell a person’s personal data. Lead generation is no longer the simple process of encouraging a consumer to fill out an online form. Today, online “lead gen,” as it is called, incorporates the use of YouTube, Facebook, Twitter, search engines, mobile phones, apps, geo-location, native advertising, email, sentiment mining, data-driven audience buying (programmatic), user “scoring” methods, attribution analysis for measurement, and a network of data brokers providing instantaneous identity and other sensitive information. The commission, in its workshop, report, and follow-up activity, should focus on the leaders of the digital data marketing industry—starting with Facebook and Google but including many others—and its use of lead generation. While there are likely many “bad” lead generator actors, as the commission’s enforcement actions have already identified, we believe that the most significant threats to consumers overall arise from the growing and now endemic use of powerful, non-transparent lead-generation techniques, especially for financial products, by the leading companies in the marketplace. Unless it is subjected to some floor of enforceable consumer protection—including but not limited to transparency and real consumer choices to avoid it—lead generation will become—if it has not already—a patently unfair system of consumer manipulation and control. Few consumers know that when they are encouraged to provide data about themselves—when they seek a home, college or auto loan, for example—that the supposedly informational website promising attractive rates and up-to-date information is really in the business on capturing their personal information to be used or sold as a lead. Online lead-generation techniques are integrated into the digital medium, with many interconnected applications fostering ongoing data collection for lead-related profiling and targeted services (e.g., search, social media, financial digital marketing). The commission should note that the leading business segments for online marketing revenues and expenditures—retail, financial services, and the automotive sectors—significantly use online lead-generation tactics. So do the leaders in the digital media business—including Google, Facebook, and Twitter, for example. The commission, in its workshop, report and follow-up activity, should focus on the leaders of the digital data marketing industry and their use of lead generation

The Internet as a whole has become an important part of our global public sphere. Internet provides access to a wealth of information and knowledge, and the possibility to participate, create and communicate. This public space made up of internet infrastructures is increasingly threatened from two sides; by the centralization and commercialization through the dominant positions held by giant telecom and Internet companies, as well as by an increasing trend in state regulation and censorship of the net. This poses important questions about how we choose to organize and regulate our digital societies, and how Internet governance models can be developed and implemented to ensure fair and democratic participation. When it comes to the future of the Internet, a key discussion is one of infrastructures; who owns, runs and controls them. The question of regulation, and who oversees the regulators, is made complicated by the transnational nature of the net. As much as people expect a broadly and equitably accessible Internet open to diversity, we are, slowly but surely, moving away from it. Monopolization of Internet infrastructures and services by companies such as Facebook and Google has gone hand in hand with privacy intrusions, surveillance and the unbounded use of personal data for commercial gain. As we all interact in these centralized commercial platforms that monetize our actions we see an effective enclosure and manipulation of our public spaces. Decentralization and democratization of the Internet infrastructure and activities is essential to keep a free, open and democratic Internet for all to enjoy equitably. But can the “small is beautiful”-idea be compatible with the building of state-of-the-art successful infrastructure in the future? The debates around net neutrality, infrastructure neutrality and Internet monopolies reflect the important choices that are to be made. It is essential the EU formulates a comprehensive vision on the internet that addresses the protection of civil liberties such as free speech and privacy, but also the growing commercialization of our digital public spaces and the commodification of personal data with the effect of the market encroaching on all aspects of our daily lives. Only then can it make relevant interventions regarding the Internet and its governance. Let´s discuss how to re-decentralize and reclaim the Internet for all. This conference (link is external) is organised in cooperation with Commons Network and Heinrich Böll Foundation. DRAFT PROGRAMME (TBC) 15:00-15:30 Introduction 15:30-16:45 1st panel, The big picture What, if anything, in the current model of Internet Governance is clashing with a decentralized, resilient internet viewed as a common good? And what steps should be made by policymakers to foster the best environment for decentralized, community managed projects to grow? Confirmed speakers: Renata Avila, Aral Balkan 16:45-17:00 Coffee break 17:00–18:15 Decentralised infrastructure: Examples what examples of local and decentralized projects do we have today and what are the obstacles they face? Confirmed speakers: Edmon Chung, Robbert Mica, Olivier Schulbaum 18:15–18:30 Conclusions and final remarks This conference will be live streamed at: http://greenmediabox.eu/en/live/ (link is external) http://greenmediabox.eu/en/live/>* (link is external) Background & Programme: http://www.greens-efa.eu/internet-as-a-commons-13850.html (link is external) Joint the event community on Facebook: https://www.facebook.com/events/939398269451418/ (link is external) https://www.facebook.com/events/939398269451418/> (link is external) Registration: http://www.greens-efa.eu/events/registrations/658-internet-as-a-commons.... (link is external)

Chango lets you target and retarget users wherever they spend their time on-the-go. Our intent data — to find users on desktop and reach them on mobile. Our Approach Our cross-device solutions can be used in a variety of ways, depending on your set of goals. Highlighted below is our approach to these different cross-device solutions. Scenario 1, Facebook: Retarget customers on Facebook mobile based on their previous behavior on desktop. Change’s cross-device Facebook solution is a combination of Chango’s intent data and Facebook’s cross-device data. This allows you to reach your target audience on their desktop and mobile devices as part of the same campaign. Chango identifies the target audience for the campaign. Chango messages the target audience on desktop. Change re-messages the same target audience. For the full article, visit http://bit.ly/1I5Yv9d (link is external)

What’s up with The New York Times Co. and programmatic? We’ve pondered that question before (link is external), but the publishing giant declined to speak at the time. Since then, Times SVP of Ad Products and R&D Michael Zimbalist has revealed to AdExchanger that the company intends to release more inventory cautiously into the RTB space. It also is planning an expansion of non-RTB programmatic initiatives. One such area the Times is considering is developing an audience extension buy. Much has changed at the Times in recent months. “We had a change of leadership in our sales department,” Zimbalist said. “Meredith Levien came in to head sales after a long search, and we’ve reorganized the whole department. In doing that, I stepped in and took on, in addition to my role as head of R&D, a new role in the company, which is head of ad products. We never had a formal head of ad products function before.” As part of this restructuring, the Times has consolidated a number of functions: ad ops, ad systems, product management, some of its custom development work and, of course, programmatic. Zimbalist spoke with AdExchanger on the changes. AdExchanger: What elements of programmatic has The New York Times embraced, and what elements has it decided to forego? Michael Zimbalist: There’s no area of programmatic we’re philosophically opposed to going forward with. Programmatic is now part of an overall practice. We’ve recast our thinking around programmatic as part of a total yield-management practice, which is part of ad products. So it reframed our view in the marketplace to incorporate total yield both in our direct-sold and in our overall market. That’s the setting. At the present time, we’re leaning into programmatic through our partnership with Google and Google AdX. Full interview available at http://bit.ly/1gmbzhQ (link is external)