CDT Comments Before the FTC in the Matter of Dot Com Disclosures

The Center for Democracy & Technology (CDT) appreciates the opportunity to respond to the questions posed by the Commission as it considers updating and reissuing its Dot Com Disclosures. Since 2000, technological innovations have greatly altered the internet landscape and CDT applauds the Commission for undertaking a review of its Dot Com Disclosures. The past eleven years have seen fundamental shifts in the way individual ads are deployed and even in the functions they serve. These shifts call for greater transparency from advertisers about not only the messages that each advertisement conveys, but also other facets of each ad: for example, the data collection that occurs ―behind the scenes‖ as an ad is being served or the fact that the ad is being targeted at a viewer on the basis of her past activities.