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GDPR: Programmatic ad buying plummets in Europe

394 points by rexbee 8y ago

sanxiyn 8y ago
It works!
adamnemecek 8y ago
Hallelujah!!
cm2012 8y ago
Temporary, probably, as people sort their stuff out. Nature abhors a vacuum and ad spend will reach the demand asymptote.
js8 8y ago
Can someone ELI5 to me why we can't simply have ads targeted to content instead of to visitors? What changed in the landscape that this is no longer possible?
- triviatise 8y ago
  how will you have ads that follow you around the internet?
- marcell 8y ago
  It’s more effective to target visitors. For example if you are male, you never need to see a tampon ad, even if you’re reading Cosmo.
  - adrianN 8y ago
    My girlfriend bought several menstrual cups because I heard about them on the Internet and suggested them to her.
    - dahdum 8y ago
      There are always untracked situations like that, but the ROAS for your demographic will so drastically different it’s like throwing money in the garbage to target you.
      - pluma 8y ago
        How likely is a man reading Cosmo to care about tampons vs cups relative to the average man? How likely is a Cosmo reader to be a cis man? Alternatively: How likely is a Cosmo reader reading an article about menstruation to be interested in a female hygiene product? The death of tracking-based ad targeting doesn't mean you have to show the same ads everywhere like an animal. You can still make the ads contextually relevant. And you don't even need to disguise them as native content (which, btw, is illegal in some EU countries already).
  - deleted 8y ago
    [deleted]
  - alkonaut 8y ago
    Someone should just invent a standard cookie that people can use if they are comfortable with it and that’s all ads can see. I’m comfortable telling advertisers my age group, gender, 3 hobbies and my zip code. I’m not comfortable with ad networks deducing those very same parameters from my browsing habits.
    - lotu 8y ago
      That is an awesome idea! I really like it, one thing I do know if you dig in the the ad settings for most provides you can find a page where they display this info and you can edit it. Unfortunately short of some type of mandate I don't see how this could work, because it would be next to impossible to get 90% of the population to fallout the cookie. My company actually did a bunch of research on collecting consent from users to show personalized ads, (aka what everyone is doing right now) Only 25% of the the users read the 3 sentences before clicking on a selection. 25% did not read anything many thought our privacy dialog was in fact an ad. :( Many people said they didn't want personalized ads because they thought it would mean filling out a survey like the one you just described even though it obviously (to us) did not. One person actually said, "I'm okay with them using my browser history to show ads but, I don't want them to use my personal data like my banking records or my medical history." This is very ironic because we presented the option to do exactly what they wanted by they didn't understand what it was because they did not consider the browser data to be "personal". I really wish that when you first opened a browser their was a dialog about hey these or the things you need to know about how we pay for the internet. Though I have no idea how get to that spot.
      - feanaro 8y ago
        > I really wish that when you first opened a browser their was a dialog about hey these or the things you need to know about how we pay for the internet. Though I have no idea how get to that spot. This sounds horrible, sorry.
  - pluma 8y ago
    Unless you're trans. Or you're doing the family shopping and aren't grossed out by hygiene products.
- cm2012 8y ago
  Most content people read is not directly related to a commercial purpose.
- zdragnar 8y ago
  1) The correlation between the content people peruse and the products people buy is pretty poor. Take a news site with an article about school shootings- what related content would they advertise? Guns? Back to school supplies? Without knowing why a person is on a page, it's difficult to understand what related products might appeal to them. 2) Tracking user behavior is fairly important to implement click fraud detection- obviously that doesn't justify shady behavior on the part of ad networks, nor does it necessitate the in-depth amount of personally identifying information they may or may not collect. However, some forms of that data- think IP addresses, click history- may be useful. 3) If you already have some data per point 2, why would you waste an opportunity to display something meaningful by putting up an ad that might be completely irrelevant given what you happen to know already? None of this is meant to justify targeted ads, only to explain why they have better appeal to both content providers and ad networks.
  - reitanqild 8y ago
    > what related content would they advertise? Guns? Back to school supplies? Without knowing why a person is on a page, it's difficult to understand what related products might appeal to them. Training for teachers? Security services? Access control systems? Yes, a lot of those reading are parents, not teachers, but what do you think they'll do if they are convinced something exists that will reduce the risk of school shootings? Editing: ad "targeting" as it has existed so far has also been insultingly, embarrassingly bad IMO. Even Google tried for years to send me ads for Russian, Ukrainian, Philippine and Thai dating sites. Round robin. I was delighted when they started showing me Wordpress ads. Those are not relevant either but now we are approaching something useful and not actively insulting (I'm very happily married and have small kids.)
    - js8 8y ago
      I think you're right about the targeted ads. Many people have expressed similar sentiment. I suspect that most advertising is actually driven by supply (that is, somebody wants to advertise X), not demand (somebody needing Y at the moment), and that's why targeting doesn't really work that well, and the disadvantage of untargeted ads (or targeted by content) is much smaller than advertising industry claims.
- Spooky23 8y ago
  The market is too segmented for broad interest ads to work, and advertisers don’t want to deal with multiple content channels. Plus, the editorial quality of ads is generally so awful, so you need to align with the users interests to help them accidentally click on it in many cases. The newspaper was a beautiful business. They had a monopoly or minimal competition, and a critical mass that supported everything from classified ads to flyers to the pet store.
- downandout 8y ago
  Can someone ELI5 to me why we can't simply have ads targeted to content instead of to visitors? Native ads do this. It's a huge industry, and will likely get far bigger under GDPR. But it takes highly specialized techniques to make the numbers back out as an advertiser. There's a ton of fraud, the bidding strategy is very different from programmatic/retargeting, the ads that work are different, etc. Most of the ad industry doesn't know how to do this, and many types of ads simply won't be profitable on native networks. From what I'm hearing from my friends that do ecommerce stuff, product ads targeted to the EU are no longer profitable across the board either. That will force a ton of review sites aimed at EU visitors to shutdown, along with many YouTube reviewers. As advertisers pull product ads out of the major ad networks because they can't make money, the revenue of publishers/content creators in the product review space will plummet in lockstep. Amazon has cut affiliate commissions to the point where turning to them is no longer an option for any site that costs money to maintain either. GDPR seems to be on track to wipe out vast swaths of businesses serving the EU market, and not just the "evil" ones it was trying to wipe out. It's a shitshow, but it was entirely predictable.
  - tannhaeuser 8y ago
    Maybe, but ad prices going down, Amazon cutting affiliation commissions, clickbait race to the bottom etc. has happened over a period of the last ten years anyway and is unrelated to GDPR. It hasn't exactly resulted in quality content, or financial stability for content creators, either. A situation where your average page contains tens of tracking scripts wasn't sustainable much longer. If anything, GDPR should be seen as an opportunity to disrupt the quasi-monopolistic online ad market.
    - downandout 8y ago
      If anything, GDPR should be seen as an opportunity to disrupt the quasi-monopolistic online ad market. The problem is that the market itself is shrinking (as we speak) as a result of GDPR. There won't be much of a market left to disrupt. Ad targeting got as invasive as it did because that was the only way to make it profitable. The moment that ads stop becoming profitable, advertisers will pull out. This won't be gradual thing for most companies - this will be a next week type of thing. Few companies can afford to light money on fire in the form of ad spend if they can't recoup it. Some ads might still work in the EU, but it will be a dramatically smaller market within a month or two.
- tjoff 8y ago
  Google can't do it. Everyone else will be fine.
  - lotu 8y ago
    I'm confused by your comment are you saying diffrent rules should apply to Google vs other companies or are you saying Google lack the engineering talent to comply and everyone else has it. The former is a deeply troubling form of government that leads (in my view anvetiablly) to corruption and abuse of power. The latter is plain backwards Google has the resources to be profitable under any regulatory regime it is small companies that don't.
    - tjoff 8y ago
      The latter, because it doesn't scale. Google is just a middleman that with the help of tracking sells lots of badly targetted ads cheaply. Google doesn't care for stuff that cannot be automated to a large degree. Now without tracking you have to actually understand the audience and the product, this research will make advertising more expensive but also in many cases have better success. And suddenly there is no reason to rely on google.
- jdietrich 8y ago
  High quality, highly relevant content just became a lot more valuable. I subscribe to Sound on Sound, a magazine about music technology. I pay them $90 a year, but I also whitelist them in my ad blocker, because the ads complement the content. If I'm reading a review of a synthesizer or an article about how to record electric guitars, it's really easy to serve relevant ads with good click-through and conversion rates without intensive tracking. Both the content and the advertising serve to enhance my enjoyment of a hobby that I care deeply about. A lot of publishers are really going to struggle post-GDPR, because their content is clickbaity and vapid. It isn't worth paying for and it isn't relevant to the readers' lives. It exists because it briefly hijacks your attention, which can be profitably monetised by ad networks that invasively track your activities online. Some good publishers are going to get caught in the crossfire which is unfortunate, but I think that the overall effect will be net positive. If publishers can't sell their ad inventory without recourse to surveillance, they need to seriously examine whether their business model is honorable and whether they are offering something of real value.
  - Barrin92 8y ago
    >It exists because it briefly hijacks your attention, which can be profitably monetised by ad networks that invasively track your activities online. Yep, I really hope that the law incentivizes businesses to really add value by producing better content rather than turning up the frequency and hitting everybody with addictive clickbait.
    - davidgerard 8y ago
      Note that the Guardian no-paywall beg for subscribers model can work surprisingly well - they've got 300,000 subscribers and another 500,000 more casual donors: http://www.thedrum.com/opinion/2017/10/26/how-the-guardian-found-800000-paying-readers http://www.thedrum.com/opinion/2017/10/26/how-the-guardian-f... I run a critical news blog about blockchains and I get about $200/mo on Patreon on this model. It's not a living, but it's a nice extra indeed. I am delighted to answer publishers who go "but how can we live without spyware-level ads!!" with "have you tried not sucking?" (I whitelist a few sites, e.g. LWN.net, and I don't block ads from the Project Wonderful network. If you don't suck, I might let you through!)
- mortehu 8y ago
  Google's main ad products, AdWords and AdSense, are content based. For many advertisers, this has always been the best type of targeting. E.g. some hotel in Toronto may advertise on the search engine results page when you search for "hotels in Toronto", or view a video about things to do in Toronto.
  - C14L 8y ago
    That's incorrect. AdSense was content based. They switched to "individual user interest" based many years ago. Its only now, after GDPR, that you finally have an option to switch back to content based ads, but sadly "for EEA users" only.
    - mortehu 8y ago
      I can only find sources that contradict you. Do you have a source for that?
Jdam 8y ago
Interesting to see how many websites will close due to a drop in ad revenue. A paywall won’t save your small news site.
MiscComment3209 8y ago
This is completely unsurprising. Ad buyers are uncertain about what the fallout of the GDPR is and are taking a "wait-and-see" approach to advertising. That's causing the price drop, since fewer people are buying. When the dust settles, and they know how to proceed, it will return to normal. If I could predict how quickly it would bounce back, I'd be tempted to get involved in the exchange market.
- onion2k 8y ago
  When the dust settles, and they know how to proceed, it will return to normal. Unless there isn't a corresponding drop in product sales. That would show the ads aren't driving sales, and there's no good reason to go back to spending on them...
  - zormino 8y ago
    But then it's not about new sales, but rather brand loyalty and maintaining market share. If coke or pepsi stopped advertising, I'm curious how long it would take for them to take a hit if the other kept advertising. Maybe it would be fast, maybe it would take a generation, but either way it would happen eventually.
    - alkonaut 8y ago
      But this drop is only for online ads, correct? So unless they buy fewer ads overall, what has happened now is that companies moved their ad money to print/broadcast/posters and other traditional media?
  - zerostar07 8y ago
    I dont think ads were ever efficient, but ad spending never stopped going up. It's an essential business lubricant. arguably however targeted ads are more efficient than anything else , even marginally.
nielsbot 8y ago
Not holding my breath but I hope something like this happens in the US.
- yborg 8y ago
  It's much more likely the current US administration will attempt to retaliate against the EU in some way in order to get this rolled back.
  - viraptor 8y ago
    Why would they? Is the US Gov expected to protect the online advertisement business for some reason?
    - tjoff 8y ago
      The US did vote against net neutrality just so that citizens could be abused for money, this seems par for the course?
      - qeternity 8y ago
        The US did not vote for this. A panel of unelected bureaucrats did.
        casefields 8y ago
        Correct. An independent federal agency run by 3 republicans and 2 democrats.
    - plorkyeran 8y ago
      The online advertisement industry is dominated by US companies.
    - deleted 8y ago
      [deleted]
  - lajhsdfkl 8y ago
deleted 8y ago
[deleted]
ma2rten 8y ago
The article makes it sound like this more due to a glitch in DoubleClick Bid Manager than anything else.
- tannhaeuser 8y ago
  Yeah that's ad tech companies and their investors and/or shareholders getting concerned with their valuation.
tannhaeuser 8y ago
Wow! What are sites supposed to do to place non-targetted ads (traditional content-based banner ads)? AFAIK, ad networks (if there are still any left) and ad customers still want tracking pixels or other instruments to measure (unique) impressions, which would also need consent under GDPR. OTOH, you could say that DoubleClick and Facebook ad impression figures aren't really more transparent or fraud-resistant than no stats at all since nobody can verify those anyway - except your own trackers, that is
- lun4r 8y ago
  besides personalization you can also target banners based on the content of the page where the banner is shown. still relevant and a lot less creepy
- alkonaut 8y ago
  Traditional banners would be fantastic. I’m hoping for a future where a fraction of sites move to traditional print style ads, some fraction moves to paid content, and a huge fraction simply moves to the waybackmachine. If tracking ads support a business it’s not a business it’s a scam.
- zerostar07 8y ago
  You can enable content-only targeted ads in Adsense for EU users, but like you said, it still requires opt-in for the cookies.
perl4ever 8y ago
This article looks very interesting, but it's full of jargon from the ad industry that makes it somewhat opaque to me. What I have an interest in is, what will this do to the stock market on Tuesday? Also, I find it interesting and confusing that the site puts up a panel on the privacy policy, which says "By using our site, you agree to these terms". But then it has an "Accept" button, as well as an "X". So (not that this site is unique) what does it mean if I don't click Accept (as is my wont)?
- bad_user 8y ago
  Under the GDPR, by not clicking Accept it means you're not agreeing to those terms.
  - perl4ever 8y ago
    Perhaps, perhaps, but (a) I think I've seen this sort of thing before, and (b) your interpretation nonetheless contradicts the statement that using the site is agreeing, and (c) I'm not in the EU.
    - bad_user 8y ago
      GDPR doesn't work like that, the user has to explicitly opt-in. So the website has to block users that don't explicitly agree, a simple statement won't do. There are exceptions, GDPR having the notion of "legitimate interest", which many services will try to abuse, however it has a precise definition and user tracking, ads targeting, marketing, or other interests like that that don't cut it, even if by not doing so results in less revenue for the service. The GDPR has teeth, which is why companies that have been violating user privacy are freaking out ;-)
      - JumpCrisscross 8y ago
        > GDPR doesn't work like that We don't know how GDPR works. Its structure grants immense discretion to political bodies. Given the EU is undergoing another cycle of political weakness, it would not be safe to assume anything about interpretation or enforcement.
mirimir 8y ago
Could someone please ELI5 how programmatic ads could be compliant with GDPR? I can vaguely imagine how Google could be compliant. But generally, there are just so many players. How could PII transfers even be tracked?
- ec109685 8y ago
  You can capture consent on your first party site (enumerating each of the networks and letting user opt out) and pass that to advertising networks: http://advertisingconsent.eu/ http://advertisingconsent.eu/
  - danieldk 8y ago
    I think the more difficult part is that you also have to be able to retract consent. So a first-party site has to offer this possibility as well and pass that to the advertising networks, which will have to remove the relevant data. Of course, this is technically possible. But apparently everyone has been sleeping during the two-year grace period.
    - mirimir 8y ago
      Right, tracking will be tedious. That's a lot of transactional data, I think.
  - Tomte 8y ago
    I don't think that ought to be possible (i.e. it's probably legal today, but shouldn't): if I'm giving consent to be tracked by company A, that does not extend to company B. And blanket consent like "ok to be tracked by whoever" should be illegal. Drain the swamp!
  - mirimir 8y ago
    As I understand it, ad networks integrate PII from many sources. From first-party sites, yes. But also using third-party cookies. And, at the point where a user is asked for consent, how can the eventual path of PII sharing be predicted?
- 8y ago
xstartup 8y ago
Funny, that most evasive ad networks pop networks operate out of EU. EU has never done anything about them.
- azernik 8y ago
  Funnily enough, the GDPR applies not just to foreign companies processing the data of people in the EU, but also to companies in the EU processing anyone's data :-D
- lima 8y ago
  > EU has never done anything about them. They just did...
  - zerostar07 8y ago
    i think he meant "invasive pop up ad networks". These are not necessarily tracking you (in fact most likely not as they are low tech), and gdpr doesnt do anything about them.
pavlov 8y ago
Targeted ads are like a cancer on the web front-end. It started out unnoticeably with one mutant script infecting a page, and now we’re at the point where the majority of client network traffic from accessing a news article goes to ad peddlers and trackers — the cancer has overtaken the host. A chemotherapy that starves the cancer’s food supply by 25-40% overnight sounds like a success to me. (Edit: USA Today decided to actively remove the cancer tumors and created an adless site for EU visitors. The results are amazing: load time shrunk from 45s to 3s, network requests from 500+ to only 34! Source: https://twitter.com/fr3ino/status/1000167643431784449?s=21 https://twitter.com/fr3ino/status/1000167643431784449?s=21 )
- raverbashing 8y ago
  Not to mention the ads keep following you after you buy the thing. And this is not only because of lack of information. Checks out a cellphone from Amazon, buys the cellphone, still get ads saying "you might like this cellphone"
  - duncanawoods 8y ago
    > Not to mention the ads keep following you after you buy the thing. There may be sense to this madness. I believe rate of returns is increasing as online sales takes over. The only way to actually see and touch many electrical devices is to buy and return them e.g. there is no store in my major UK city that has premium non-mac laptops on display. It means you might buy and return 3 devices to find the one you want to keep. If the return rate is 30%+ then a completed purchase really is a strong indicator that might purchase the same thing.
    - syllogism 8y ago
      Scoff. 30%? There's no way a rate of returns is anything like that. Just think of the volume of post that would be going out of suburban post centres! The delivery network obviously doesn't look anything like that. I think it's much simpler. The chance that any person is say, buying a fridge at any point is very low. If you're 99% sure that person has already made their purchase, that means there's a 1% chance you're wrong, and they're still looking! That's a much better signal than any other signal you're going to get.
TheForumTroll 8y ago
Nothing to see here folks. Just some angry Americans talking doom and gloom AKA FUD.
isostatic 8y ago
Good. Adverts are a drain on society, they increase prices of goods which are advertised, and mean you as the product/consumer end up paying more than the service/website gets, as the adverts take a cut. Look at television in the US, or even in the UK on non-BBC channels. You watch something for an hour, you get 40 minutes of actual use out of it, you get massive breaks in the narative which reduces your enjoyment, and you waste 20 minutes of your life. Does this mean you get free tv? No, you're still paying. The only reason that $CORP spends $1 advertising to you in your program is because it will make you spend more than $1 with them at some point in the future. When you watch advert TV, you're selling 20 minutes of your life not for $1, but to shift your $1 expense now to a $2 expense hidden elsewhere in the future. Far better to save 20 minutes, and that $2 in the future, by spending $1 upfront, and being the customer, not the product.
- MichaelBurge 8y ago
  If the advertisement is "Buy our static analysis tool. Catch bugs in your C programs", your argument considers the purchase equally as bad whether it catches 0 bugs or 100 critical CVEs. Most people don't use static analysis tools, so without persuasion the purchase would never occur.
  - CapacitorSet 8y ago
    Which highlights the need for a neutral product-discovery tool. Advertising makes most popular the products with a higher marketing budget, not necessarily the better ones. For example, search for "youtube downloader": at least the first ten results link to shady websites and apps which offer a crappy wrapper around youtube-dl, which is the ultimate youtube downloader but unknown by non-programmers. Even among wrappers, the clean versions are not as popular as the advertised and SEO'd crap.
- donatj 8y ago
  > they increase prices of goods which are advertised I think that's completely false. The price of things goes down with volume, and if no one knows about something its going to be far more expensive than something everyone uses. Advertisings entire purpose is to increase the volume sold, which lowers the price. http://www.altfeldinc.com/pdfs/BASICECONOMICS.pdf http://www.altfeldinc.com/pdfs/BASICECONOMICS.pdf is actually decent reasonably short and enlightening read if you find yourself with some time.
manibatra 8y ago
I always wonder how many of my decisions have been subconsciously influenced by ads. At the moment the only stuff I feel like spending money on is tech stuff. Probably because the only place I visit on the web is tech forums. My spending on other stuff has dropped down drastically ever since I took a hiatus from Facebook.
enterx 8y ago
Targeting a minority group... Hey... Isn't that Nazism? :D
ajb 8y ago
Everyone mourning the death of targeted ads: It's perfectly possible to do targeted ads without collecting personal data! You just keep personal data where it belongs - on the user's computer/phone - rather than stealing it. Keep the personal data in local storage, have the logic that chooses ads run locally, and you have targetted ads without invading anyone's privacy. I don't know if that satisfies the GDPR - not a lawyer. But it would satisfy me.
- xamuel 8y ago
  Careful about unintended consequences. I saw a project where someone built a version of "Asteroids" where certain fake asteroids would appear or not based on ":visited" css or something. Then by recording where players shot at, the site was able to infer which of various websites you had visited.
  - ajb 8y ago
    Yes. If you're trying to build an honest ad network, you're not going to do that; but you still have to worry about leaking information to less honest clients. If the information is in the browser, someone will try to exfiltrate it.
  - ubernostrum 8y ago
    Mozilla experimented with the idea you're replying to -- a system that would download a bundle of disparate ads from a central server, and then decide based on information in the browser which ones to show. Take away active content from the ads, or (very distant second best) sandbox them, and you can do targeting without the advertisers or even the distributor being able to figure out why a particular ad was shown.
- zerostar07 8y ago
  you need to ask permissions if you re processing them, locally or not. plus then you dont have control on data deletion, with the user leaving their data on public computer etc.
  - 8y ago
deleted 8y ago
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Mazun 8y ago
New information about Michael Jackson 2018 : http://zipansion.com/118yZ http://zipansion.com/118yZ
627467 8y ago
Yet another great benefit from GDPR. First I call this the "great unsubscriber" due to the great number of (since) forgotten newsletter i got unsubscribe from. And Now this. As european consumer (despite being outside europe) i ca only see benefits with this new regulation.
- MikkoFinell 8y ago
  Yes it's fantastic. Now if we only could ride the momentum of this and slam something equally as punishing on Facebook, then we could be heading towards a renewed golden age of the internet.
xstartup 8y ago
Why aren't subscription prices going up for EU only customers? Please if you've customers in EU, do not blend the prices. Add fee of lawyers (and future litigation/compliance risk damage) into EU customers' subscription fee.
swiley 8y ago
Wow this is fantastic! Maybe we’ll have a web with no 3rd party adds one day!
nannePOPI 8y ago
Targeted ads are great. Things cost less because there is more competitions between suppliers and they don't have to pay a lot per piece, since they can target only the specific people who needs the thing they sell. This is GREAT for people with small business and low budgets... but we know now that Europe only care about the big business and billionaire overlords. Also with targeted ads you don't have to hear/read about products you will never care for a moment in your life.
- jacksmith21006 8y ago
  Agree 100%. Targeted ads enable us to have shorter ads also.
- rubidium 8y ago
  The corrupt ecosystem around enabling "they can target only the specific people who needs the thing they sell" however is a terrible thing for humanity and targeted ads are a neccesary (and welcome to me) casualty.
- wlll 8y ago
  I feel like the GDPR is working for me to help prevent companies treating my data like it belongs to them. I guess I'll have to check under the bed for my missing billions. > Also with targeted ads you don't have to hear/read about products you will never care for a moment in your life. I don't have to look at irrelevant adverts at all because I use an adblocker. Something I started to use because of the battery sucking CPU fan abusing privacy invading toxic wasteland that is the online advertisement industry. The tech industry in general, and online advertising companies specifically proved over many years they couldn't be trusted to look after people's data and privacy, so forgive me if I don't shed a tear for the shitbags who now have to stop exploiting me and my family's data.
- xr4ti 8y ago
  In no way do the benefits outlined by OP even come close to outweighing the systemic risks posed by omnipresent surveillance coupled with precise targeting of individualized persuasive messaging with the intent of behavioral change. The way targeted advertising is currently implemented is a mass violation of privacy and autonomy, a clear and present threat to democracy and liberty, and an indicator of the complete ethical collapse of the US tech sector.
deleted 8y ago
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kerng 8y ago
Yes!
jacksmith21006 8y ago
Is this not going to hurt the EU businesses that purchased the ads?
clay_the_ripper 8y ago
Solution is simple: don’t do business in the EU. problem solved. Let the companies who can be bothered to expose themselves to litigation and spend $$ on compliance service those customers.

394 points by rexbee 8y ago

sanxiyn 8y ago

It works!

adamnemecek 8y ago

Hallelujah!!

cm2012 8y ago

Temporary, probably, as people sort their stuff out. Nature abhors a vacuum and ad spend will reach the demand asymptote.

js8 8y ago

Can someone ELI5 to me why we can't simply have ads targeted to content instead of to visitors? What changed in the landscape that this is no longer possible?

triviatise 8y ago
how will you have ads that follow you around the internet?
marcell 8y ago
It’s more effective to target visitors. For example if you are male, you never need to see a tampon ad, even if you’re reading Cosmo.
- adrianN 8y ago
  My girlfriend bought several menstrual cups because I heard about them on the Internet and suggested them to her.
  - dahdum 8y ago
    There are always untracked situations like that, but the ROAS for your demographic will so drastically different it’s like throwing money in the garbage to target you.
    - pluma 8y ago
      How likely is a man reading Cosmo to care about tampons vs cups relative to the average man? How likely is a Cosmo reader to be a cis man? Alternatively: How likely is a Cosmo reader reading an article about menstruation to be interested in a female hygiene product? The death of tracking-based ad targeting doesn't mean you have to show the same ads everywhere like an animal. You can still make the ads contextually relevant. And you don't even need to disguise them as native content (which, btw, is illegal in some EU countries already).
- deleted 8y ago
  [deleted]
- alkonaut 8y ago
  Someone should just invent a standard cookie that people can use if they are comfortable with it and that’s all ads can see. I’m comfortable telling advertisers my age group, gender, 3 hobbies and my zip code. I’m not comfortable with ad networks deducing those very same parameters from my browsing habits.
  - lotu 8y ago
    That is an awesome idea! I really like it, one thing I do know if you dig in the the ad settings for most provides you can find a page where they display this info and you can edit it. Unfortunately short of some type of mandate I don't see how this could work, because it would be next to impossible to get 90% of the population to fallout the cookie. My company actually did a bunch of research on collecting consent from users to show personalized ads, (aka what everyone is doing right now) Only 25% of the the users read the 3 sentences before clicking on a selection. 25% did not read anything many thought our privacy dialog was in fact an ad. :( Many people said they didn't want personalized ads because they thought it would mean filling out a survey like the one you just described even though it obviously (to us) did not. One person actually said, "I'm okay with them using my browser history to show ads but, I don't want them to use my personal data like my banking records or my medical history." This is very ironic because we presented the option to do exactly what they wanted by they didn't understand what it was because they did not consider the browser data to be "personal". I really wish that when you first opened a browser their was a dialog about hey these or the things you need to know about how we pay for the internet. Though I have no idea how get to that spot.
    - feanaro 8y ago
      > I really wish that when you first opened a browser their was a dialog about hey these or the things you need to know about how we pay for the internet. Though I have no idea how get to that spot. This sounds horrible, sorry.
- pluma 8y ago
  Unless you're trans. Or you're doing the family shopping and aren't grossed out by hygiene products.
cm2012 8y ago
Most content people read is not directly related to a commercial purpose.
zdragnar 8y ago
1) The correlation between the content people peruse and the products people buy is pretty poor. Take a news site with an article about school shootings- what related content would they advertise? Guns? Back to school supplies? Without knowing why a person is on a page, it's difficult to understand what related products might appeal to them. 2) Tracking user behavior is fairly important to implement click fraud detection- obviously that doesn't justify shady behavior on the part of ad networks, nor does it necessitate the in-depth amount of personally identifying information they may or may not collect. However, some forms of that data- think IP addresses, click history- may be useful. 3) If you already have some data per point 2, why would you waste an opportunity to display something meaningful by putting up an ad that might be completely irrelevant given what you happen to know already? None of this is meant to justify targeted ads, only to explain why they have better appeal to both content providers and ad networks.
- reitanqild 8y ago
  > what related content would they advertise? Guns? Back to school supplies? Without knowing why a person is on a page, it's difficult to understand what related products might appeal to them. Training for teachers? Security services? Access control systems? Yes, a lot of those reading are parents, not teachers, but what do you think they'll do if they are convinced something exists that will reduce the risk of school shootings? Editing: ad "targeting" as it has existed so far has also been insultingly, embarrassingly bad IMO. Even Google tried for years to send me ads for Russian, Ukrainian, Philippine and Thai dating sites. Round robin. I was delighted when they started showing me Wordpress ads. Those are not relevant either but now we are approaching something useful and not actively insulting (I'm very happily married and have small kids.)
  - js8 8y ago
    I think you're right about the targeted ads. Many people have expressed similar sentiment. I suspect that most advertising is actually driven by supply (that is, somebody wants to advertise X), not demand (somebody needing Y at the moment), and that's why targeting doesn't really work that well, and the disadvantage of untargeted ads (or targeted by content) is much smaller than advertising industry claims.
Spooky23 8y ago
The market is too segmented for broad interest ads to work, and advertisers don’t want to deal with multiple content channels. Plus, the editorial quality of ads is generally so awful, so you need to align with the users interests to help them accidentally click on it in many cases. The newspaper was a beautiful business. They had a monopoly or minimal competition, and a critical mass that supported everything from classified ads to flyers to the pet store.
downandout 8y ago
Can someone ELI5 to me why we can't simply have ads targeted to content instead of to visitors? Native ads do this. It's a huge industry, and will likely get far bigger under GDPR. But it takes highly specialized techniques to make the numbers back out as an advertiser. There's a ton of fraud, the bidding strategy is very different from programmatic/retargeting, the ads that work are different, etc. Most of the ad industry doesn't know how to do this, and many types of ads simply won't be profitable on native networks. From what I'm hearing from my friends that do ecommerce stuff, product ads targeted to the EU are no longer profitable across the board either. That will force a ton of review sites aimed at EU visitors to shutdown, along with many YouTube reviewers. As advertisers pull product ads out of the major ad networks because they can't make money, the revenue of publishers/content creators in the product review space will plummet in lockstep. Amazon has cut affiliate commissions to the point where turning to them is no longer an option for any site that costs money to maintain either. GDPR seems to be on track to wipe out vast swaths of businesses serving the EU market, and not just the "evil" ones it was trying to wipe out. It's a shitshow, but it was entirely predictable.
- tannhaeuser 8y ago
  Maybe, but ad prices going down, Amazon cutting affiliation commissions, clickbait race to the bottom etc. has happened over a period of the last ten years anyway and is unrelated to GDPR. It hasn't exactly resulted in quality content, or financial stability for content creators, either. A situation where your average page contains tens of tracking scripts wasn't sustainable much longer. If anything, GDPR should be seen as an opportunity to disrupt the quasi-monopolistic online ad market.
  - downandout 8y ago
    If anything, GDPR should be seen as an opportunity to disrupt the quasi-monopolistic online ad market. The problem is that the market itself is shrinking (as we speak) as a result of GDPR. There won't be much of a market left to disrupt. Ad targeting got as invasive as it did because that was the only way to make it profitable. The moment that ads stop becoming profitable, advertisers will pull out. This won't be gradual thing for most companies - this will be a next week type of thing. Few companies can afford to light money on fire in the form of ad spend if they can't recoup it. Some ads might still work in the EU, but it will be a dramatically smaller market within a month or two.
tjoff 8y ago
Google can't do it. Everyone else will be fine.
- lotu 8y ago
  I'm confused by your comment are you saying diffrent rules should apply to Google vs other companies or are you saying Google lack the engineering talent to comply and everyone else has it. The former is a deeply troubling form of government that leads (in my view anvetiablly) to corruption and abuse of power. The latter is plain backwards Google has the resources to be profitable under any regulatory regime it is small companies that don't.
  - tjoff 8y ago
    The latter, because it doesn't scale. Google is just a middleman that with the help of tracking sells lots of badly targetted ads cheaply. Google doesn't care for stuff that cannot be automated to a large degree. Now without tracking you have to actually understand the audience and the product, this research will make advertising more expensive but also in many cases have better success. And suddenly there is no reason to rely on google.
jdietrich 8y ago
High quality, highly relevant content just became a lot more valuable. I subscribe to Sound on Sound, a magazine about music technology. I pay them $90 a year, but I also whitelist them in my ad blocker, because the ads complement the content. If I'm reading a review of a synthesizer or an article about how to record electric guitars, it's really easy to serve relevant ads with good click-through and conversion rates without intensive tracking. Both the content and the advertising serve to enhance my enjoyment of a hobby that I care deeply about. A lot of publishers are really going to struggle post-GDPR, because their content is clickbaity and vapid. It isn't worth paying for and it isn't relevant to the readers' lives. It exists because it briefly hijacks your attention, which can be profitably monetised by ad networks that invasively track your activities online. Some good publishers are going to get caught in the crossfire which is unfortunate, but I think that the overall effect will be net positive. If publishers can't sell their ad inventory without recourse to surveillance, they need to seriously examine whether their business model is honorable and whether they are offering something of real value.
- Barrin92 8y ago
  >It exists because it briefly hijacks your attention, which can be profitably monetised by ad networks that invasively track your activities online. Yep, I really hope that the law incentivizes businesses to really add value by producing better content rather than turning up the frequency and hitting everybody with addictive clickbait.
  - davidgerard 8y ago
    Note that the Guardian no-paywall beg for subscribers model can work surprisingly well - they've got 300,000 subscribers and another 500,000 more casual donors: http://www.thedrum.com/opinion/2017/10/26/how-the-guardian-found-800000-paying-readers http://www.thedrum.com/opinion/2017/10/26/how-the-guardian-f... I run a critical news blog about blockchains and I get about $200/mo on Patreon on this model. It's not a living, but it's a nice extra indeed. I am delighted to answer publishers who go "but how can we live without spyware-level ads!!" with "have you tried not sucking?" (I whitelist a few sites, e.g. LWN.net, and I don't block ads from the Project Wonderful network. If you don't suck, I might let you through!)
mortehu 8y ago
Google's main ad products, AdWords and AdSense, are content based. For many advertisers, this has always been the best type of targeting. E.g. some hotel in Toronto may advertise on the search engine results page when you search for "hotels in Toronto", or view a video about things to do in Toronto.
- C14L 8y ago
  That's incorrect. AdSense was content based. They switched to "individual user interest" based many years ago. Its only now, after GDPR, that you finally have an option to switch back to content based ads, but sadly "for EEA users" only.
  - mortehu 8y ago
    I can only find sources that contradict you. Do you have a source for that?

Jdam 8y ago

Interesting to see how many websites will close due to a drop in ad revenue. A paywall won’t save your small news site.

MiscComment3209 8y ago

This is completely unsurprising. Ad buyers are uncertain about what the fallout of the GDPR is and are taking a "wait-and-see" approach to advertising. That's causing the price drop, since fewer people are buying. When the dust settles, and they know how to proceed, it will return to normal. If I could predict how quickly it would bounce back, I'd be tempted to get involved in the exchange market.

onion2k 8y ago
When the dust settles, and they know how to proceed, it will return to normal. Unless there isn't a corresponding drop in product sales. That would show the ads aren't driving sales, and there's no good reason to go back to spending on them...
- zormino 8y ago
  But then it's not about new sales, but rather brand loyalty and maintaining market share. If coke or pepsi stopped advertising, I'm curious how long it would take for them to take a hit if the other kept advertising. Maybe it would be fast, maybe it would take a generation, but either way it would happen eventually.
  - alkonaut 8y ago
    But this drop is only for online ads, correct? So unless they buy fewer ads overall, what has happened now is that companies moved their ad money to print/broadcast/posters and other traditional media?
- zerostar07 8y ago
  I dont think ads were ever efficient, but ad spending never stopped going up. It's an essential business lubricant. arguably however targeted ads are more efficient than anything else , even marginally.

nielsbot 8y ago

Not holding my breath but I hope something like this happens in the US.

yborg 8y ago
It's much more likely the current US administration will attempt to retaliate against the EU in some way in order to get this rolled back.
- viraptor 8y ago
  Why would they? Is the US Gov expected to protect the online advertisement business for some reason?
  - tjoff 8y ago
    The US did vote against net neutrality just so that citizens could be abused for money, this seems par for the course?
    - qeternity 8y ago
      The US did not vote for this. A panel of unelected bureaucrats did.
      - casefields 8y ago
        Correct. An independent federal agency run by 3 republicans and 2 democrats.
  - plorkyeran 8y ago
    The online advertisement industry is dominated by US companies.
  - deleted 8y ago
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- lajhsdfkl 8y ago

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ma2rten 8y ago

The article makes it sound like this more due to a glitch in DoubleClick Bid Manager than anything else.

tannhaeuser 8y ago
Yeah that's ad tech companies and their investors and/or shareholders getting concerned with their valuation.

tannhaeuser 8y ago

Wow! What are sites supposed to do to place non-targetted ads (traditional content-based banner ads)? AFAIK, ad networks (if there are still any left) and ad customers still want tracking pixels or other instruments to measure (unique) impressions, which would also need consent under GDPR. OTOH, you could say that DoubleClick and Facebook ad impression figures aren't really more transparent or fraud-resistant than no stats at all since nobody can verify those anyway - except your own trackers, that is

lun4r 8y ago
besides personalization you can also target banners based on the content of the page where the banner is shown. still relevant and a lot less creepy
alkonaut 8y ago
Traditional banners would be fantastic. I’m hoping for a future where a fraction of sites move to traditional print style ads, some fraction moves to paid content, and a huge fraction simply moves to the waybackmachine. If tracking ads support a business it’s not a business it’s a scam.
zerostar07 8y ago
You can enable content-only targeted ads in Adsense for EU users, but like you said, it still requires opt-in for the cookies.

perl4ever 8y ago

This article looks very interesting, but it's full of jargon from the ad industry that makes it somewhat opaque to me. What I have an interest in is, what will this do to the stock market on Tuesday? Also, I find it interesting and confusing that the site puts up a panel on the privacy policy, which says "By using our site, you agree to these terms". But then it has an "Accept" button, as well as an "X". So (not that this site is unique) what does it mean if I don't click Accept (as is my wont)?

bad_user 8y ago
Under the GDPR, by not clicking Accept it means you're not agreeing to those terms.
- perl4ever 8y ago
  Perhaps, perhaps, but (a) I think I've seen this sort of thing before, and (b) your interpretation nonetheless contradicts the statement that using the site is agreeing, and (c) I'm not in the EU.
  - bad_user 8y ago
    GDPR doesn't work like that, the user has to explicitly opt-in. So the website has to block users that don't explicitly agree, a simple statement won't do. There are exceptions, GDPR having the notion of "legitimate interest", which many services will try to abuse, however it has a precise definition and user tracking, ads targeting, marketing, or other interests like that that don't cut it, even if by not doing so results in less revenue for the service. The GDPR has teeth, which is why companies that have been violating user privacy are freaking out ;-)
    - JumpCrisscross 8y ago
      > GDPR doesn't work like that We don't know how GDPR works. Its structure grants immense discretion to political bodies. Given the EU is undergoing another cycle of political weakness, it would not be safe to assume anything about interpretation or enforcement.

mirimir 8y ago

Could someone please ELI5 how programmatic ads could be compliant with GDPR? I can vaguely imagine how Google could be compliant. But generally, there are just so many players. How could PII transfers even be tracked?

ec109685 8y ago
You can capture consent on your first party site (enumerating each of the networks and letting user opt out) and pass that to advertising networks: http://advertisingconsent.eu/ http://advertisingconsent.eu/
- danieldk 8y ago
  I think the more difficult part is that you also have to be able to retract consent. So a first-party site has to offer this possibility as well and pass that to the advertising networks, which will have to remove the relevant data. Of course, this is technically possible. But apparently everyone has been sleeping during the two-year grace period.
  - mirimir 8y ago
    Right, tracking will be tedious. That's a lot of transactional data, I think.
- Tomte 8y ago
  I don't think that ought to be possible (i.e. it's probably legal today, but shouldn't): if I'm giving consent to be tracked by company A, that does not extend to company B. And blanket consent like "ok to be tracked by whoever" should be illegal. Drain the swamp!
- mirimir 8y ago
  As I understand it, ad networks integrate PII from many sources. From first-party sites, yes. But also using third-party cookies. And, at the point where a user is asked for consent, how can the eventual path of PII sharing be predicted?
8y ago

xstartup 8y ago

Funny, that most evasive ad networks pop networks operate out of EU. EU has never done anything about them.

azernik 8y ago
Funnily enough, the GDPR applies not just to foreign companies processing the data of people in the EU, but also to companies in the EU processing anyone's data :-D
lima 8y ago
> EU has never done anything about them. They just did...
- zerostar07 8y ago
  i think he meant "invasive pop up ad networks". These are not necessarily tracking you (in fact most likely not as they are low tech), and gdpr doesnt do anything about them.

pavlov 8y ago

Targeted ads are like a cancer on the web front-end. It started out unnoticeably with one mutant script infecting a page, and now we’re at the point where the majority of client network traffic from accessing a news article goes to ad peddlers and trackers — the cancer has overtaken the host. A chemotherapy that starves the cancer’s food supply by 25-40% overnight sounds like a success to me. (Edit: USA Today decided to actively remove the cancer tumors and created an adless site for EU visitors. The results are amazing: load time shrunk from 45s to 3s, network requests from 500+ to only 34! Source: https://twitter.com/fr3ino/status/1000167643431784449?s=21 https://twitter.com/fr3ino/status/1000167643431784449?s=21 )

raverbashing 8y ago
Not to mention the ads keep following you after you buy the thing. And this is not only because of lack of information. Checks out a cellphone from Amazon, buys the cellphone, still get ads saying "you might like this cellphone"
- duncanawoods 8y ago
  > Not to mention the ads keep following you after you buy the thing. There may be sense to this madness. I believe rate of returns is increasing as online sales takes over. The only way to actually see and touch many electrical devices is to buy and return them e.g. there is no store in my major UK city that has premium non-mac laptops on display. It means you might buy and return 3 devices to find the one you want to keep. If the return rate is 30%+ then a completed purchase really is a strong indicator that might purchase the same thing.
  - syllogism 8y ago
    Scoff. 30%? There's no way a rate of returns is anything like that. Just think of the volume of post that would be going out of suburban post centres! The delivery network obviously doesn't look anything like that. I think it's much simpler. The chance that any person is say, buying a fridge at any point is very low. If you're 99% sure that person has already made their purchase, that means there's a 1% chance you're wrong, and they're still looking! That's a much better signal than any other signal you're going to get.

TheForumTroll 8y ago

Nothing to see here folks. Just some angry Americans talking doom and gloom AKA FUD.

isostatic 8y ago

Good. Adverts are a drain on society, they increase prices of goods which are advertised, and mean you as the product/consumer end up paying more than the service/website gets, as the adverts take a cut. Look at television in the US, or even in the UK on non-BBC channels. You watch something for an hour, you get 40 minutes of actual use out of it, you get massive breaks in the narative which reduces your enjoyment, and you waste 20 minutes of your life. Does this mean you get free tv? No, you're still paying. The only reason that $CORP spends $1 advertising to you in your program is because it will make you spend more than $1 with them at some point in the future. When you watch advert TV, you're selling 20 minutes of your life not for $1, but to shift your $1 expense now to a $2 expense hidden elsewhere in the future. Far better to save 20 minutes, and that $2 in the future, by spending $1 upfront, and being the customer, not the product.

MichaelBurge 8y ago
If the advertisement is "Buy our static analysis tool. Catch bugs in your C programs", your argument considers the purchase equally as bad whether it catches 0 bugs or 100 critical CVEs. Most people don't use static analysis tools, so without persuasion the purchase would never occur.
- CapacitorSet 8y ago
  Which highlights the need for a neutral product-discovery tool. Advertising makes most popular the products with a higher marketing budget, not necessarily the better ones. For example, search for "youtube downloader": at least the first ten results link to shady websites and apps which offer a crappy wrapper around youtube-dl, which is the ultimate youtube downloader but unknown by non-programmers. Even among wrappers, the clean versions are not as popular as the advertised and SEO'd crap.
donatj 8y ago
> they increase prices of goods which are advertised I think that's completely false. The price of things goes down with volume, and if no one knows about something its going to be far more expensive than something everyone uses. Advertisings entire purpose is to increase the volume sold, which lowers the price. http://www.altfeldinc.com/pdfs/BASICECONOMICS.pdf http://www.altfeldinc.com/pdfs/BASICECONOMICS.pdf is actually decent reasonably short and enlightening read if you find yourself with some time.

manibatra 8y ago

I always wonder how many of my decisions have been subconsciously influenced by ads. At the moment the only stuff I feel like spending money on is tech stuff. Probably because the only place I visit on the web is tech forums. My spending on other stuff has dropped down drastically ever since I took a hiatus from Facebook.

enterx 8y ago

Targeting a minority group... Hey... Isn't that Nazism? :D

ajb 8y ago

Everyone mourning the death of targeted ads: It's perfectly possible to do targeted ads without collecting personal data! You just keep personal data where it belongs - on the user's computer/phone - rather than stealing it. Keep the personal data in local storage, have the logic that chooses ads run locally, and you have targetted ads without invading anyone's privacy. I don't know if that satisfies the GDPR - not a lawyer. But it would satisfy me.

xamuel 8y ago
Careful about unintended consequences. I saw a project where someone built a version of "Asteroids" where certain fake asteroids would appear or not based on ":visited" css or something. Then by recording where players shot at, the site was able to infer which of various websites you had visited.
- ajb 8y ago
  Yes. If you're trying to build an honest ad network, you're not going to do that; but you still have to worry about leaking information to less honest clients. If the information is in the browser, someone will try to exfiltrate it.
- ubernostrum 8y ago
  Mozilla experimented with the idea you're replying to -- a system that would download a bundle of disparate ads from a central server, and then decide based on information in the browser which ones to show. Take away active content from the ads, or (very distant second best) sandbox them, and you can do targeting without the advertisers or even the distributor being able to figure out why a particular ad was shown.
zerostar07 8y ago
you need to ask permissions if you re processing them, locally or not. plus then you dont have control on data deletion, with the user leaving their data on public computer etc.
- 8y ago

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Mazun 8y ago

New information about Michael Jackson 2018 : http://zipansion.com/118yZ http://zipansion.com/118yZ

627467 8y ago

Yet another great benefit from GDPR. First I call this the "great unsubscriber" due to the great number of (since) forgotten newsletter i got unsubscribe from. And Now this. As european consumer (despite being outside europe) i ca only see benefits with this new regulation.

MikkoFinell 8y ago
Yes it's fantastic. Now if we only could ride the momentum of this and slam something equally as punishing on Facebook, then we could be heading towards a renewed golden age of the internet.

xstartup 8y ago

Why aren't subscription prices going up for EU only customers? Please if you've customers in EU, do not blend the prices. Add fee of lawyers (and future litigation/compliance risk damage) into EU customers' subscription fee.

swiley 8y ago

Wow this is fantastic! Maybe we’ll have a web with no 3rd party adds one day!

nannePOPI 8y ago

Targeted ads are great. Things cost less because there is more competitions between suppliers and they don't have to pay a lot per piece, since they can target only the specific people who needs the thing they sell. This is GREAT for people with small business and low budgets... but we know now that Europe only care about the big business and billionaire overlords. Also with targeted ads you don't have to hear/read about products you will never care for a moment in your life.

jacksmith21006 8y ago
Agree 100%. Targeted ads enable us to have shorter ads also.
rubidium 8y ago
The corrupt ecosystem around enabling "they can target only the specific people who needs the thing they sell" however is a terrible thing for humanity and targeted ads are a neccesary (and welcome to me) casualty.
wlll 8y ago
I feel like the GDPR is working for me to help prevent companies treating my data like it belongs to them. I guess I'll have to check under the bed for my missing billions. > Also with targeted ads you don't have to hear/read about products you will never care for a moment in your life. I don't have to look at irrelevant adverts at all because I use an adblocker. Something I started to use because of the battery sucking CPU fan abusing privacy invading toxic wasteland that is the online advertisement industry. The tech industry in general, and online advertising companies specifically proved over many years they couldn't be trusted to look after people's data and privacy, so forgive me if I don't shed a tear for the shitbags who now have to stop exploiting me and my family's data.
xr4ti 8y ago
In no way do the benefits outlined by OP even come close to outweighing the systemic risks posed by omnipresent surveillance coupled with precise targeting of individualized persuasive messaging with the intent of behavioral change. The way targeted advertising is currently implemented is a mass violation of privacy and autonomy, a clear and present threat to democracy and liberty, and an indicator of the complete ethical collapse of the US tech sector.

deleted 8y ago

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kerng 8y ago

Yes!

jacksmith21006 8y ago

Is this not going to hurt the EU businesses that purchased the ads?

clay_the_ripper 8y ago

Solution is simple: don’t do business in the EU. problem solved. Let the companies who can be bothered to expose themselves to litigation and spend $$ on compliance service those customers.