WHY SHOULD YOU CARE ABOUT WHAT I‘M SAYING?
Other than that, I will let my commentary speak for itself.
NAA MAKES A COMPLAINT TO FTC FOR INVESTIGATION ON DECEPTIVE AD-BLOCKING PRACTICES
On a complaint dated 26th of May 2016, Newspaper Association of America requests FTC formally to investigate what NAA claims as “deceptive ad-blocking practices”. This commentary is focused on the part where material claims are made in regard to Brave and its model. I too agree that models such as the one introduced by Adblock Plus raise more questions than answer them. Brave’s model is unique in the way it approaches the underlying problems that cause ad blocking use, without forgetting the rights of the publishers.
The first material claim in the letter is:
A technology such as Brave undermines the status quo of internet publishing. Much in the same way as Apple iTunes undermined the status quo of the music industry. The current business model NAA’s members rely on is a result of rapid commoditization of ad serving technology, tracking technology and various online advertising formats over the past 2 decades. Yet to a far extent it significantly resembles the first online advertising models dating back to Modem Media placing the alleged first online ad on wired.com in -94.
The most significant change between now and then in terms of online publishers monetizing their readers can be found in what has come to be known as surveillance capitalism. In a startling recent study of tracking practices on 1 million sites by Princeton University, researchers found that News site had the most tracking tags on them out of any category of sites.
Another important change is related to how advertisements are increasingly being used to deliver ransomware and other kinds of malware.
In terms of the vibrant, content-filled internet we have, the most significant “clear and present” danger to American public associated with it comes from malvertising being delivered through ads increasingly on major websites, including those of NAA’s members . At the moment it is widely agreed within the information security community, that ad blocking, such as provided by Brave, is the only means for users to protect themselves against malvertising attacks. A recent Cisco Talos landmark report on Ransomware stated advertisements as one of the 4 common ways to deliver Ransomware . Brave is as the moment the only solution that provides users with the needed complete protection, while promising to generate revenue in what can be considered “fair terms” with the publishers.
As it comes out from the Princeton study, it is online publishers and particularly news sites that do not adequately disclose their practices to consumers. Where as Brave provides a high level of transparency on its website, using well thought out graphics and easy-to-undertand language. Compared to adtech companies and online publishers, Brave is exceptionally transparent in communicating with its users. Brave’s CEO is very active on Twitter in terms of responding to questions and concerns users or critics have about Brave and its model. Brave’s core team is made of people with track record for building user-centric internet solutions as part of highly transparent organizations, including key development roles in Mozilla, Khan Academy, IETF and EFF.
When taken out of the context, advertising substitution, especially in the conventional sense of so-called ad injection, is a deceptive practice and often associated with criminal activity such as ad fraud.
In the case of Brave anyhow, the practice of advertising substitution is merely associated with taking in to consideration the publishers’ need and right to make money from its readers regardless of which browser those readers use to visit publisher site. This is after Brave has on the publisher’s behalf effectively solved the issues of malvertising, privacy violations and bandwidth cost caused by a given publisher’s 3rd and nth-party relationships and the resulting often out-of-control and poorly understood high entropy tag eco-system.
While Brave is both in its communication, and in the software itself going to great lengths to help users understand that Brave intends to replace regular ads with ads it guarantees to be safe, as many more users adopt Brave this point may not always get across to the user. At the same time, NAA’s members have shown little more than serious neglect to the risk of ads on their sites being used to deliver malware on to user devices. This seems like a far greater risk, and liability, for the publishers to worry about.
In any case, Brave could easily add some form of marking to ads that helps the users understand the ads are coming from Brave and not the publishers other partners.
Quality of the delivered ad needs to necessarily consider more than just the quality of the creative, such as:
In terms of safety and legality, Brave have very clearly explained how it ensures those two aspects on the publisher’s behalf. In terms of context, currently most ads are targeted based on online behavioral advertising (OBA) and do not consider the contextual placement of the advertisement. It is very much possible, depending on the approach Brave chooses, that its ads will be more contextually relevant than the ones NAA’s members’ current partners place on their sites.
Because of the widely used yield optimization practice known as the waterfall, many big publisher sites have poor quality ads shown on their sites. In the waterfall, if no buyer is found on one exchange, the request is moved to a second exchange, often of lower quality than the first one. This is repeated until a buyer is found, sometimes leading to a very poor quality advertisement being shown. Such ads come from so-called performance networks, and typically sell deceptive get-rich-quick and weight-loss products.
Other common reason for NAA’s member websites having very poor quality advertisements displayed to the users are the so-called native advertising platforms. According to a recent study by MediaRadar  70% of publishers are not following FTC’s Native Ad Guidelines.
One of the leading native advertising networks in the world, Revcontent claims that it makes 200 billion content recommendatios per month and lists as its customers Forbes, Newsweek, International Business Times, Reuters, Archant and ITV. As a point of reference, the entire programmatic ad eco-system is roughly 200 billion ad impressions per day. Revcontent CEO John Lemp has previously settled out of a whistleblower lawsuit where he was alleged “to have asked an employee to destroy incriminating information worried that it would be incriminating as part of an inquiry by the FTC”. In a separate case, under Mr. Lemp’s leadership his previous company Clickbooth paid $2 million for allegedly using deceptive claims to sell weight-loss products. Deceptive practices are not uncommon in the online advertising industry, and even Google’s DoubleClick have been sued on several occassions for use of deceptive ads, including the first-ever tech-support scam case.
Brave users are the internet users who are fed up with ads, so it seems fair to assume based on behavioral economics that Brave will be highly motivated to ensure high quality ad experience to their users. As otherwise its userbase is likely to move elsewhere in search of what they came to orginally look from Brave.
Actually what Brave does, as opposed to “destroy millions of dollars” is help the American society save time, save money and have a richer internet experience.
At the same time Brave is helping the publishers to protect their users in a way that would be virtually impossible in the current system with their 3rd and nth-party adtech partners infesting their sites. While offering them a share of ad revenue higher than any of their ad network partners historically have.
More than anything else, Brave is helping the publishers to “buy time” while they think about what the next generation online publishing business models look like, and how to truly become relevant in the internet age. Just like their music counterparts did a decade ago.
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REFERENCES Comprehensive List of Major Publisher Reported in Malvertising Attacks  RANSOMWARE: PAST, PRESENT, AND FUTURE Online tracking: A 1-million-site measurement and analysis  Publishers Are Largely Not Following the FTC’s Native Ad Guidelines  Whistleblower lawsuit against IntegraClick CEO is settled  Marketers Behind Fake News Sites Settle FTC Charges of Deceptive Advertising  DoubleClick Sued Over ‘Diabolical’ Banner Ads