FTC Seeks Input for Revising Its Guidance to Businesses About Online Advertising, FTC Matter No. P114506 #00009 

Submission Number:
Bill  Kelm
"Brokerblogger" (Nickname)
South Carolina
Initiative Name:
FTC Seeks Input for Revising Its Guidance to Businesses About Online Advertising, FTC Matter No. P114506
As an avid user of the Internet since about 1995 for business and personal use, and as a consumer advocate who participated in the 6/9/05 Consumer Reports WEBWATCH conference on "Trust or Consequence: How Failure to Disclose Ad Relationships Threatens to Burst the Search Bubble" ( http://www.consumerwebwatch.org/dynamic/conferences-search-research.cfm ) , I believe that with the coming of high usage of small mobile screens in smartphones to scan quickly for information, that something more needs to be done about Google, Yahoo, and Bing making a better distinction between the organic results and the paid "Ads" results that appear right on top of the organic. "Skimming and Scanning" on a small screen makes it even more difficult to know if you're "clicking on" and looking at "Ads"! I don't mind the "Sponsored Results" that appear below the organic results, or the ones that appear to the right on a SERP. But, the top left/middle real estate is prime and, I believe, will no longer be sometimes recognized as "Paid Ads" that are "Sponsored" because of the reduced size print on that small screen along with a very faint gray background color! A consumer wanting information only, may not realize that he is "being sold" in many cases, and these "Ads" can lead consumers to "infomercial" type results. I stated that as "Bill Kelm, SEO-SEM Consultant Broker" at that 6/9/05 C.R. conference. On 6/5/05 Jørgen Wouters of C.R. said at that conference: "Let’s face it, a lot of people tend to use Google and Google was actually one of the very few engines not listed in that FTC complaint. And, in fact, when we did our research last year, we relied on some information professionals. All of them criticized Google for the fact that the sponsored listings heading indeed was a very faint gray." Well, nothing has changed in six years, as you can see if you do a search on Google, Yahoo, and Bing, and look at the first page search results for "smartphones": The current FTC's "Dot Com Disclosures" says about disclosures: "Additional considerations include: the prominence of the disclosure, whether items in other parts of the ad distract attention from the disclosure,.." I believe that many people in a rush to get the answers they want that are relative to their intent will focus on, and be distracted by, what the paid listings say in bold/underlined print vs. looking at the smaller text that says "Ads" to the right of them. I constructively suggest that the text of "Ads" or "Sponsored Links" be made larger, bolder, and done in a more noticeable color in order to be more clear and conspicuous, along with the background color deepened/darkened (or a "box border" put around the paid listings). Google and Bing need to make a hyperlink out of those words like Yahoo does for consumers to have a more complete and comprehendable understanding of what "Ads" exactly means on their respective search engines. See this well done 2010 "Eye-Tracking Study" of Search Engine Results Pages: http://www.gbuscher.com/publications/BuscherDumais10_adQuality.pdfOn page 7 under "5. CONCLUSION" it says: "Consistent with previous research, we found a considerable bias of users’ visual attention towards the top few organic result entries which is even stronger for informational than for navigational tasks. Furthermore, we found a strong bias against sponsored links in general." Therefore, if the consumer can not easily, quickly, and clearly tell the difference between the "Ads" and the organic listings, then they are being MISLED and DISCEIVED, in my opinion. Thanks.