Request for Comments and Announcement of Workshop on Blurred Lines: Advertisement or Editorial? FTC Workshop on Native Advertising, Project No. P134510 #00004

Submission Number:
Jeffrey Chester
Center for Digital Democracy
District of Columbia
Initiative Name:
Request for Comments and Announcement of Workshop on Blurred Lines: Advertisement or Editorial? FTC Workshop on Native Advertising, Project No. P134510
Matter Number:


Native advertising, on the one hand, is nothing more then digitally dressed up product placement (with viral marketing added). But it also illustrates that the traditional distinctions that have gingerly separated advertising/marketing from editorial content are being further eroded. Marketers--not since the 1950's when (sadly) both Lucy and Desi lighted up cigarettes (to the sponsored delight of advertiser Phillip Morris), have marketers had so much influence over the content and structure of the electronic media. Driving the growth of native and other branded experiences online is a major transformation of advertising. As the commission knows, increasingly individual consumers are bought and sold in real-time through what is known as Real-time buying (or programmatic) exchanges. Content sites that traditionally could draw in ad revenues, now find themselves under pressure to please advertisers, who have the technological ability to bypass them and precision target a prospective consumer (including when they are visiting a lower cost to advertise site, even on mobile devices). Consumers are also being further segmented, permitting advertisers to seek out specific individuals with the "right" demographics--such as a propensity to buy. They can ignore those deemed less valuable. The rise of native ads also illustrates that advertisers now see themselves in the content business. Marketers are in the forefront of developing and deploying digital tools designed to deeply engage with users. They have the knowledge and resources to create, as they call it, "brand stories," “brand newsrooms,” and social media “command centers.” They are able to propagate these new forms of product placement at scale through social media, online video, geo-targeting, etc. (native advertising is merely one aspect of the digital ad ecosystem, as its called by the industry). Safeguards are especially required when such content is used for sensitive data categories--including financial, health and services targeting youth. Beyond the ethical and regulatory issues related to transparency and disclosure (for both the advertiser and the content service), the commission should also address the ethical dimensions. What happens to the capabilities of the public living in a democratic society to make meaningful decisions when the information they receive is increasingly shaped to further the interests of brands? Will the growth of native ads/digital product placement further weaken already vulnerable journalistic institutions that we rely on for our news and information? The transformation of the ad marketplace as a result of technological change must also be on the agenda, especially implications for privacy