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If you are not familiar with the CMA report then how do you know it does not address display ads on third party websites, i.e., "open web adverting"? In the CM

If you are not familiar with the CMA report then how do you know it does not address display ads on third party websites, i.e., "open web adverting"? In the CMA report "open web advertising" is referred to as the "open display market". https://assets.publishing.service.gov.uk/media/5dfa0580ed915d0933009761/Interim_report.pdf https://assets.publishing.service.gov.uk/media/5dfa0580ed915... "We have organised our work into three thigh-level themes: Theme 1 considers to what extent Google and Facebook have market power in search and social media respectively and the sources of this market power; Theme 2 assesses whether consumers have adequate control over the use of their data by online platforms, by exploring the choices they are given, how easy it is to exercise those choices and whether there is adequate protection for those who do not engage; and Theme 3 focusses on the business to business digital advertising markets, exploring a range of concerns including a lack of transparency, conflicts of interest and the leveraging of market power to undermine competition." Not disagreeing with your premise, however the Google response to the CMA report devotes a significant amount of verbiage to explaining and defending their position in the "open display market". On page 4 of the 25-page response to the CMA report you will find the heading "Competition in Digital Advertising". Under this you will see the subheadings "Search Advertising", "Display Advertising on Third Party Websites" and "Our Relationship with Publishers". The "Search Advertising" section is just over 3 pages. The "Display Advertising on Third Party Websites" is 4.5 pages. The "Our relationship with Publishers" section is just over 2 pages. It is true the CMA did not make precisely the same arguments as the authors of the "roadmap" paper. They are two different jusrisdictions. However the CMA report forms the factual basis for all the arguments in the roadmap paper.

nl 6y ago
Why do you think Google didn't list these companies? I found the Google response[1] and I'd note that they don't name any other companies at all (at least in a very quick glance through). I suspect this is a policy choice by Google - they don't want to be seen as pointing regulators at competitors. I would also note that on page 23 footnote 69 they point references showing "the top 100 U.S. advertisers use an average 4 to 7 DSPs according to a 2016-2018 study" and "500 largest U.S. publishers use an average of 6 SSPs" [1] https://assets.publishing.service.gov.uk/media/5d78ba3540f0b61c7a66407c/190802_Google_-_Response_to_SoS__Non-confidential_.pdf https://assets.publishing.service.gov.uk/media/5d78ba3540f0b...
- pwdisswordfish2 6y ago
  In parapgraph 29 of the response, with respect to "publisher ad serving", Google mentioned several competitors by name. In the roadmap paper the authors note the publisher ad server market is "particularly concentrated" with Google having a "90% or higher share". Not sure I understand what you are thinking regarding the "policy choice" idea. Would need some more elaboration.
  - nl 6y ago
    > In parapgraph 29 of the response Could you refer to page number or something? I'm not going through counting paragraphs. I searched for "publisher ad serving" and didn't find it, and searched for "Facebook" and didn't find anything that seemed to sound like what you are talking about. I don't understand the gist of your comments here either. You asked me why Google didn't refer to competitors in their response, but now you say that they do? > Not sure I understand what you are thinking regarding the "policy choice" idea. "they don't want to be seen as pointing regulators at competitors."
    - pwdisswordfish2 6y ago
      The paragraphs are numbered for you. The legal field often prefers to reference numbered paragraphs instead of page numbers. It can be easier. Paragraph 29 is on page 8. You claimed the authors of the roadmap paper are "wrong". You cited a couple of purported Google competitors, Facebook and Verizon. I noted that in their response to CMA report Google did not mention those two competitors. They mentioned several other ones, none of them as prominent as Facebook or Verizon. Then you said there are "many other" competitors, too, besides Facebook and Verizon. I am wondering why Google did mention any of these competitors you are referring to in their response to the CMA report. Seems like it would be relevant to mention them.
      - nl 6y ago
        Page 8 has footnote 29. Paragraphs aren't numbered. It doesn't name competitors there so I'm pretty confused. However page 7 does say: The Market Study will need to take account of the ways in which other players are entering, expanding, or consolidating in the supply of digital ads Examples include Amazon’s growing ads business, Verizon (which purchased AOL and Yahoo!), the integrated AT&T/Time Warner/AppNexus businesses, AdForm, and Alibaba – one of China’s largest digital ad providers that recently... The reference in that quote include footnote 29. Perhaps you are confusing footnotes/references with the substantive response?

nl 6y ago

Why do you think Google didn't list these companies? I found the Google response[1] and I'd note that they don't name any other companies at all (at least in a very quick glance through). I suspect this is a policy choice by Google - they don't want to be seen as pointing regulators at competitors. I would also note that on page 23 footnote 69 they point references showing "the top 100 U.S. advertisers use an average 4 to 7 DSPs according to a 2016-2018 study" and "500 largest U.S. publishers use an average of 6 SSPs" [1] https://assets.publishing.service.gov.uk/media/5d78ba3540f0b61c7a66407c/190802_Google_-_Response_to_SoS__Non-confidential_.pdf https://assets.publishing.service.gov.uk/media/5d78ba3540f0b...

pwdisswordfish2 6y ago
In parapgraph 29 of the response, with respect to "publisher ad serving", Google mentioned several competitors by name. In the roadmap paper the authors note the publisher ad server market is "particularly concentrated" with Google having a "90% or higher share". Not sure I understand what you are thinking regarding the "policy choice" idea. Would need some more elaboration.
- nl 6y ago
  > In parapgraph 29 of the response Could you refer to page number or something? I'm not going through counting paragraphs. I searched for "publisher ad serving" and didn't find it, and searched for "Facebook" and didn't find anything that seemed to sound like what you are talking about. I don't understand the gist of your comments here either. You asked me why Google didn't refer to competitors in their response, but now you say that they do? > Not sure I understand what you are thinking regarding the "policy choice" idea. "they don't want to be seen as pointing regulators at competitors."
  - pwdisswordfish2 6y ago
    The paragraphs are numbered for you. The legal field often prefers to reference numbered paragraphs instead of page numbers. It can be easier. Paragraph 29 is on page 8. You claimed the authors of the roadmap paper are "wrong". You cited a couple of purported Google competitors, Facebook and Verizon. I noted that in their response to CMA report Google did not mention those two competitors. They mentioned several other ones, none of them as prominent as Facebook or Verizon. Then you said there are "many other" competitors, too, besides Facebook and Verizon. I am wondering why Google did mention any of these competitors you are referring to in their response to the CMA report. Seems like it would be relevant to mention them.
    - nl 6y ago
      Page 8 has footnote 29. Paragraphs aren't numbered. It doesn't name competitors there so I'm pretty confused. However page 7 does say: The Market Study will need to take account of the ways in which other players are entering, expanding, or consolidating in the supply of digital ads Examples include Amazon’s growing ads business, Verizon (which purchased AOL and Yahoo!), the integrated AT&T/Time Warner/AppNexus businesses, AdForm, and Alibaba – one of China’s largest digital ad providers that recently... The reference in that quote include footnote 29. Perhaps you are confusing footnotes/references with the substantive response?