ADOTAS

With the launch of Apple’s iPad 2 and Amazon’s Kindle, the tablet market continues to expand into a more competitive marketplace, with each new product offering something unique. Despite all the bells and whistles, tablets and smart phones share one feature: web browsing. With so many of these mobile devices getting into the hands of consumers, search marketers should be considering how to better target users of tablets or mobile devices who browse and search the web.

Just as mobile users search differently than laptop and desktop PC users, consumers on tablets have some interesting habits when it comes to how they use the web. An independent study conducted by the Covario Paid Media Services team found that tablet users have a higher level of engagement in online video viewing than smart phone users. The study found that tablet viewers watched videos 28 percent longer than those on desktops and mobile devices. Also, tablet users were more than twice as likely to watch a complete video compared to those on a desktop, and 30 percent more likely than those on other mobile devices.

With such behavioral differences in tablet users, search marketers would be wise to take certain steps when setting up tablet- and smartphone-targeted campaigns.  Here are some best practices to reach and optimize search campaigns for the mobile consumer.

• Set up separate mobile-specific campaigns. This provides more control over bids and budgets, allowing for separate reports to track results. It also enables the use of separate optimization techniques to drive campaign performance.

Separate campaigns provide further opportunity to test alternative messaging strategies for various mobile platforms, with strong calls to action and relevant ad formats.  At my company, Covario, we have found click-to-call and store-locator campaigns to be particularly effective for mobile campaigns.

Google AdWords allows you to target different carriers and devices for mobile.  It also offers associated tracking metrics.

• Develop a mobile keyword list. Similar consumer search behaviors exist between mobile and desktop queries, although mobile skews higher on local queries with cities or ZIP codes. Common misspellings are important considerations in keyword strategies for mobile campaigns, given the smaller screen and/or lack of a keyboard, depending upon the device.

Desktop users are more likely to use long-tail keywords, whereas tablet or smart phone users might feel restricted with a touch-screen keyboard. With more mobile devices offering voice search, consumer behavior will eventually shift towards longer phrases and long-tail keywords when searching. For now, however, keeping keywords short — inclusive of misspellings and local derivatives as appropriate — is crucial to campaign success.

• Create compelling ad text. Creating text relevant to mobile users is critical to boosting click-through rates. Consider including an acknowledgment that the consumer is on a mobile device and an immediate call-to-action, i.e. a click to call. Adding local-specific ad text is also crucial, given that one in three mobile search queries have local intent, according to a study by The Kelsey Group. Local mobile advertising reaches consumers who are close to point-of-sale and ready to purchase.

• Bid and budget for mobile search. Create a separate bid strategy for mobile devices. Mobile devices have limited ad spots available compared to desktop search results. In addition, for display, mobile-optimized sites and mobile apps typically have fewer ad slots to display ads.

With respect to mobile search budgeting, it is vital to deeply understand your target audience and allocate your media budget based on when your audience is searching. Further, as mobile media consumption continues to increase, using analytics to identify and track target consumers is critical to mobile marketing success.

A recent Google study indicates that mobile search compliments desktop search. Time-of-day usage peaks for desktop search during the day when many consumers are behind a computer at work. Mobile search behavior peaks toward the end of day into the evening when consumers are home after work, typically consuming other media. Dayparting search campaigns may be a smart strategy, depending upon the target audience and product/service offering.

• Separately track your mobile performance. Setting up separate campaigns for tablets and smart phones allows you to easily track campaign performance and evaluate the ROI of your mobile programs by device  based on clear campaign metrics. Use the same discipline with mobile campaigns that is typically used with desktop initiatives, by refining keywords, adding negative keywords, using various match types, adjusting bids to reach CPA or ROAS targets, and pausing under-performing ad groups.

• Optimize your mobile site. You will increase conversions and improve the user experience with a mobile-optimized landing page or site. Effective landing pages with the right level of content and strong, clear calls to action are the ticket to successful conversions and mobile campaigns.

The important thing to realize is that mobile search and devices are here to stay and will continue to evolve. The sooner you develop, test and implement a mobile strategy for your search campaigns, the faster you will reap the benefits and rewards.

As I was outlining the first 90-day SEO Action Plan to a new client the other day, the client asked me why I was not following best practices. Having thought I missed something in my plan, I asked the client to explain his question. He asked why I did not include an XML Sitemap in my Action Plan. Apparently he read on Google Webmaster Tools that every site should have an XML Sitemap and that not including one goes against SEO best practices.

I informed the client that in general Google Webmaster Tools is correct. It is a best practice to have an XML Sitemap. In fact, depending upon the content a website could have several types of sitemaps including video, mobile, news, etc. However, in this specific situation creating and uploading an XML Sitemap was not advisable.

It turns out my client’s eCommerce website was “over indexed” in Google. With most clients over indexing happens more with MSN than Google, but not this time. In my client’s case, Google was reporting that it indexed 50,000 pages. My client has about 7,600 products. With the integrated blog and other pages, the site only has about 10,000 pages.

After analyzing the situation, Google was over indexing the site due to a quirk in my client’s content management system (CMS). The CMS appended a few sections of the website with an extra parameter giving the appearance that the website has more web pages (content) than it really has. Worse yet, my client’s website has top rankings for several of the keywords that are included in this over indexing.

It turns out if I implement an XML Sitemap, I am essentially telling Google they have made a mistake in over indexing and they will flush roughly 40,000 pages from the index. Almost overnight this will drop the existing rankings for my client because the site is not as relevant for a given set of keywords.

Instead of losing rankings and thereby revenue for my client by blindly following a “best practice”, I’ve elected not to follow a best practice. Once the client is able to replace the website with equivalent content – I will then create and upload an XML Sitemap.

This is not the first time I have not followed best practices in my 9 years of SEO. Last year I inherited a website that has 25 doorway pages. Doorway pages are intended only for the search engines and are not intended for people to access.

We discovered the doorway pages during the initial audit. Our analysis suggested these pages were contributing to the site rankings. Upon finding these pages the client wanted me to immediately delete the pages but I advised against it to preserve existing rankings and revenue stream. Instead I decided to slowly remove a few pages a month and replace them with real content. This was a painstaking process but it was successful. Today my client has first page rankings and no doorway pages.

Rankings and traffic are key metrics that SEOs should measure. However, an SEO’s job should not end there. We are also responsible for return on investment from the campaign. As a result we must understand and appreciate the business side of SEO – cash flow, revenue and profitability. Yes, my Bachelor of Science degree is in business administration and management. From time to time, I will not let SEO best practices get in the way of business.

So trust me – I am a professional …SEO.

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You may recall in an earlier piece my anecdote about a Chinese businessman who proclaimed that he was turning white hat. He had offered his assistance in identifying fraudulent publishers from China, and, of course, he wanted money in return for the intel he provided.

Editor’s note: This is the last in a series from Dianna Koltz, director of best practices and email marketing at Memolink, on how to use business standards to combat online fraud. She can be reached at dkoltz@memolinkcorp.com

Readers have been reaching out to me asking “Why didn’t you take him up on his offer?” One of three things would have happened as a result of my taking advantage of this pseudo-opportunity: We potentially could have been doubly duped, the fraudsters could have collected more information about our process, or the tactics could have changed as soon as we received the information.

First, the deal that was proposed did not guarantee any legitimacy of the information. I may have negotiated a payment method that allowed me to stop payment, but I doubt that he would have agreed to providing me information without first having money in hand. We would have been in perpetual deadlock.

The gentleman could have conducted deuce diligence, a term my team has coined to describe the process a fraudster uses to reverse engineer our due diligence process. It is an intense cat and mouse game. Or, discovering that their buddy had sold them out, the fraudsters may have immediately changed tactics. The patterns of fraud we had been tracing would mark a dramatic shift and become more aggressively covert.

Beyond my hypothesis of what might have happened had I gone that route, let me tell you a secret: His secrets are anything but secret. Sshh, don’t tell anyone.

How does my team identify the fraudulent publishers from China and elsewhere? My compliance analysts make the difference in the process; they are experts at what they do. The people are what set a great due diligence program apart from a good due diligence program, and we are extremely disciplined with the execution of The Best Practice Approach.

What does my team analyze in order to identify the fraudulent publishers? Here are a few data points and current trends that we monitor:

1. International criminals are recruiting U.S.-based individuals via industry web forums to act as their front men. The U.S.-based identity-for-hire will register a website in his or her name, then sign up for advertising networks. The fraud operation is handled by the international business associate and the identity-for-hire sits back and receives a 50% cut. What this means for you: All of the information in the publisher application will appear legitimate, and he or she most likely will pass all of the other checks you do.

2. Identity theft is the number one complaint online according to the FTC, and it ranks toward the top of our list too. What this means for you: In order to validate identity you may need to request additional sensitive information, like a social security number or a government-issued ID. Anytime you are dealing with personal information, privacy is a concern. Make sure you have someone on staff that is trained on how to handle this type of data appropriately.

3. It is not uncommon to find that a telephone number provided to you by a prospective partner is the number for “Big John’s Rib Joint.” These invalid phone numbers are easy enough to identify, but how do you know when a domestic number is forwarding to an international number? The latest trend in fraud related to telephone numbers is call forwarding, and fraudulent individuals use this tactic along with masking their IP address to fake their business location.

What this means for you: Telephone verification vendors have not developed the technology to determine if a call is being forwarded (if you know of a vendor that does, please let me know). The good news? The other checks you run will flag this publisher as fraudulent 99.9% of the time.

I have been comparing notes with representatives from other advertising networks, and many of the checks conducted are the same, but how we do what we do differs. For example, one major flaw in the process our counterparts use is the timing of their due diligence execution.

Many are waiting to identify the fraudulent individuals until after they enter the network. Would you allow a stranger into your home, sit them down in the living room, offer them a cup of tea, and then ask who they are? You would not risk putting yourself or your family in harm’s way, so why in business would you expose your partners to this kind of harm when it can be avoided?

 If you would like to join in on the dialogue, please contact me, my information is in my bio.

Advertisers may be conditioned to scream “Fraud!” instead of “Bad Quality!” like the public was trained to yell “Fire!” instead of “Help!” when attempting to attract attention.  Are advertisers crying wolf when it comes to fraud? Or, is the fraud simply bad traffic?

An advertiser’s fraud claim demands attention because chances are a liability has been created for the advertiser or the partner, or both. Whereas, an advertiser’s claim that the traffic is not backing out for them may command less of their partner’s attention. The former is an elephant and the latter is an ant.

As an advertiser,  I have experienced first-hand a lack of partner response when I have communicated quality concerns, in my case new member quality for our loyalty program Memolink.com. Here’s how those conversations would unfold:

Me: Our click to conversion rate is quite low.
Partner: Maybe your landing page needs to be optimized.
Me: The return on investment and activity level of these new members is low.
Partner: It is only my responsibility to provide you the member; it’s up to you to monetize them.

At the time, had I known that using the “F” bomb would have been a powerful enough call to action, I may have just dropped it. In this example, the traffic I received was bad, but perhaps the new members I received came from a sub-publisher three levels away and the pattern of bad traffic was actually an indication of fraud. Could I have made changes and tested landing pages to improve conversions? Yes. Could I have spent more time monetizing the leads I was receiving? Yes. Could the traffic have been fraudulent? Yes. All I really wanted from my partner was a commitment to investigate, and I did not receive that.

On the flip side, the experience my organization has as an advertising network working with advertisers has provided me with a glimpse into a bigger issue. We do not share a common definition of fraud. The following is a snapshot of new clients that were on-boarded last week and the definition of fraud each of these clients provided:

Monday’s Fraud Definition: Duplicates
Tuesday’s Fraud Definition: Invalid credit card
Wednesday’s Fraud Definition: Cancellations on orders
Thursday’s Fraud Definition: Returns
Friday’s Fraud Definition: Numbers in names, etc.

It is important that we come together as an industry and collaborate on the real definition of fraud as it relates to what we do and the challenges we face. Each lead, sale, or transaction can be placed into one of three categories: Valid, Invalid or Fraud. Too often the invalid leads are being placed in the fraud category. The way to prevent and detect fraud is to first understand what fraud is.

Many B-to-C and B-to-B companies have expanded or are looking to expand their business overseas and capture global customers and clients. The potential risks and rewards of expansion into the BRIC markets are high.

China, the most populous country in the world, is predicted by ZenithOptimedia to be the fourth largest advertising market by 2010, while Russia will rank sixth, Brazil seventh, and India thirteenth. Not only is China’s ad expenditure growing but also the country’s total number of Internet users. China surpassed the U.S. as the biggest user of the Internet last June, and last month the official China Internet Network Information Center said that the number of Internet users in China has reached 298 million. According to the U.S. Census Bureau our population was 305,762,073 on February 6.

About two weeks ago, I received an email from a businessman in one of these developing regions, an excerpt from that email follows:

“Hello, I am an affiliate from China. I know that almost all CPA network hate Chinese affiliates, because they are almost all fraud. I was also a fraud before, I earn some money from some CPA network with my fraud activity.

But now I do not want to fraud because it’s too tired, and very dirty, and the account often be terminated. Even so, there are a lot Chinese “affiliate” do the fraud activity to all CPA network everyday, and they have a lot of experience, so they can escape the punishment from the CPA network. Of course, they earn a lot of money. But it’s dirty.

So I want to cooperate with you. Every month as long as you give me a certain degree of rewards, I will reveal to you all the Chinese fraud affiliates, and every month I will reveal new ones to you. I believe that through my efforts, you and the advertiser will restore hundreds of thousands of economic losses.

So I can get clean money from you, and you can restore economic losses. I think this is a win-win model.

If you have the intention, please contact me …”

Needless to say, I did not respond. Fraudulent individuals will mask their locations and often steal a citizen’s identity from a developed country as a tactic to attempt entry into an affiliate network.

As your organization expands, how will you control the quality of your customers and clients? How will you keep fraud levels low? And how will you manage your reputation on a global stage? The Best Practice Approach will guide you through your decision-making process and help manage your reputation.

Editor’s note: This is a series from Dianna Koltz, director of best practices and email marketing at Memolink, Inc., on how to use business standards to combat online fraud

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Securing information and providing appropriate data access can help limit your risk. The Association of Certified Fraud Examiners says the five most effective fraud prevention tactics are: implementing strong internal controls; background checks for new hires; anti-fraud policies; ethics training; and surveillance.

When I first began to implement the Best Practice approach over a year ago, I focused on the first tactic the ACFE recommends and evaluated our data access controls. Much of our data was accessible by many different roles inside our organization. The lack of access variance between an entry-level employee and an executive had been carried over from the days when our organization had fewer employees.

It is common in smaller companies for an employee to have multiple responsibilities that grant him access to more information systems. Many of you in this fast-paced industry can relate: The individual who edits your website also sends out your email newsletter and invoices at the end of the month. In this scenario, the smaller businesses make the decision to absorb the risk, but how do you appropriately limit access as your company grows?

In Memolink’s case, the data access audit was conducted by asking one question and compiling the results for review: Who had access to what type of information, and for what purpose? It also helped to evaluate the audit findings juxtaposed with the goals and motivations of each department and employee. By looking at the results in this manner, I was able to remove the context for internal staff abuse.

For example, when my company separated publisher vetting and the fraud identification and reporting processes from the publisher sales and account management team, it was natural to also secure the information related to these processes. Publishers who join the CPA Storm network are interviewed by a Best Practice compliance analyst and only those who meet our standards are accepted as a business partner. We do not share the finite details of our vetting process.

If you asked any one of our account managers, “As a publisher looking to join your network, what do I need to do or say to be accepted?” not one of them would be able to tell you. The only individuals who know the details of our acceptance policy are inside the Best Practice Division or in the top two positions in our company (CEO and EVP).

I limit the information so the fraudsters cannot reverse engineer or social engineer their way into our circle. An individual looking to do harm can attempt to reverse engineer the process by going through the vetting process countless times, each time learning a detail about the technology that we use. The technology we use is home grown, and like any technology, it is not perfect, which is why we have humans who make the final decisions.

A fraudulent individual could also weasel their way in through the use of social engineering, which essentially means that an individual manipulates another person in order to get information, like a password, or confidential information about your business. This is often done by becoming “buddies.”

Many of us use LinkedIn and other social websites like Facebook to stay connected and conduct business. The potential fraudsters know this. Using myself as an example, they see my profile on LinkedIn or on my Facebook page, and are able to deduct that I enjoy watching basketball, drink a lot of Pepsi, went to Drake University (go Bulldogs!), and I worked for Meredith Corporation for several years.

They use this information to gain my trust, “Do you think that the Drake men’s basketball team will make it to the Sweet Sixteen this year?” I am put at ease by this conversation and others that follow, and then they proceed to extract whatever information they need. If I were in the role of an account manager and knew the details for publisher acceptance, I may share this with my new buddy without even realizing the potential harm. Thus, by limiting access, we have removed the risk of our sales team being in a precarious situation like the one described here.

Editor’s note: This is a series from Dianna Koltz, director of best practices and email marketing at Memolink, Inc., on how to use business standards to combat online fraud. The links of past stories are to the left.

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If you wait for your affiliates to begin the dialogue, you may be waiting a long time. Maybe your partner is waiting for you to make the first move? If we all wait on one another, when will the time come for real change in the industry?

While many corporations embrace the idea and morality behind full visibility, very few practice what they preach. The affiliate marketing industry has been known for a long tail of young, savvy, and aggressive marketers. You may have seen one at a recent conference valet parking his Ferrari. These individuals have made a pile of cash, some legitimately, and some through less ethical–and perhaps illegal–means. How can you determine which leaders and organizations have your best interests in mind and which are conflicted by their desire to earn more for themselves and their investors?

The Best Practice approach to partner vetting will help you weed out the bad. To vet means to check. Implementing a vetting program for your company is as simple as formally asking each partner a variety of questions prior to conducting business. For example:

- How long have you been in business?

- Has your company received venture or institutional money?

- How long has your current leadership been in place?

- Have you ever been the subject of a lawsuit or investigation relating to your advertising, marketing, privacy or data security practices?

- Do you have a formal due diligence procedure to vet your vendors and affiliates? (Inquire about the details of the process.)

- Who is responsible for setting compliance policy at your organization?

- Who will be my daily operational contact for fraud- or compliance-related issues?

- What are your company’s best practice standards above and beyond what the federal law requires?

Depending on your company’s risk tolerance, a quarterly or annual audit may also be appropriate to ensure that the affiliate’s practices are still in line with what was disclosed during vetting.

Who executes the vetting and auditing programs at your company may be even more important than the questions that are asked. The associate responsible for partner selection and monitoring should not receive commissions based on sales or volume goals.

Should you require your partners to disclose the details of their business relationships? In general, no; organizations should be able to keep the identity of vendors and affiliates private. In cases where fraud has occurred or a liability risk exists, it is reasonable to request full disclosure. This type of open communication during the vetting, monitoring, and incident response processes will raise the standards for online business and improve the entire ecosystem. How you choose to execute these processes will set you apart from others.

Editor’s note: This is a series from Dianna Koltz, director of best practices and email marketing at Memolink, Inc., on how to use business standards to combat online fraud. Here are the past stories.

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Meanwhile, the Internet’s footprint on the global economy and culture becomes larger every day. The expansion of fraud and the identification of this risk will create more jobs in the fields of compliance, risk management, and best practices. Who will fill these positions?

For many companies looking to take action, the initial move will be to consolidate roles. Individuals in areas such as sales and marketing will absorb fraud identification, reporting, and prevention responsibilities. This will prove to be ineffective for the following reasons:

1. The sales and marketing staffs are not trained to identify fraud and they cannot keep up with the ever-changing tactics.

2. Associates are conflicted when faced with a fraud incident. They are not motivated to report fraud and their compensation structure dissuades them from reporting incidents.

3. Business goals are not aligned appropriately, which naturally moved fraud last on the priority list for the associates assigned the additional responsibilities.

4. While the internal attempt is made, no time is spent on partner due diligence and monitoring.

Organizations will benefit in the long term by hiring dedicated staff. This tactic is one component of my company’s Best Practice approach to doing business. My dedicated team helped realign business goals and create a culture that now embraces a higher set of standards and expectations.

Staffing and training were the largest challenges I have faced in the last year. The positions were new, the skill set was specific, and as a result we received a dichotomous set of resumes. Applicants with online marketing experience had little to no experience with fraud, or they came from companies where more unscrupulous methods were used, and I was not confident those habits would be easily kicked. The applicants with fraud investigative experience had no experience with online advertising, which is the basis of our business model.

I chose to hire candidates that had no knowledge of the online industry but who had a strong background in fraud investigation. One recruit graduated with a degree in sociology with a focus in criminal justice while another has a bachelor’s degree in criminal justice. The recruits also share commonalities in past professional experience. One team member worked as a special investigator conducting field investigations for a Department of Defense contractor, and another as an investigator for the state of Massachusetts and later as an anti-money laundering analyst for a financial company.

When recruiting for your team, expect to receive a small number of resumes compared to the average you may receive for other positions. Do not worry about where to post the job description, just get it posted. In the past, Memolink has posted the compliance analyst positions on our corporate websites, Jobing.com, Monster.com, Craig’s List, and niche tech websites. In the first half of 2008, the quality candidates came from the niche tech websites, then the quality declined and the best resumes came through Jobing.com. Be patient during the recruitment process, and be disciplined with hiring decisions. The right candidates will come along.

The recruitment of online advertising newbies placed additional emphasis on the need for an excellent training program. It needed to be thorough and begin with the basics, like what the acronym PPC means, for example. I gathered product and management leaders from across the organization and asked them to participate in the training. Sharing the training served three purposes. New Best Practices team members were oriented to the culture starting on the first day, experts conducted the training for their domain, and it allowed me a few hours a day to focus on strategic planning for the Best Practice approach.

Editor’s note: This is a series from Dianna Koltz, director of best practices and email marketing at Memolink, Inc., on how to use business standards to combat online fraud. Here are the past stories.

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The online collection and use of personal information will be under an intense beacon of light in the remainder of 2008 and into 2009 with possible FTC action being taken against companies with egregious privacy practices. The industry will begin to improve the communication of privacy expectations to users, data privacy and protection awareness will grow, and a less-discussed area of data collection will influence the email marketing landscape: Unsubscribes.

An unsubscribe represents a lost opportunity for email marketers. Even though the unsubscribed address does not generate revenue, and resources are spent on unsubscribe file maintenance, attention should be given to unsubscribe files for two reasons.

First, internally a company could minimize the net loss associated to the maintenance. Second, dedicating time to improving unsubscribe handling, honoring unsubscribes, and protecting the consumer’s email address post opt-out will improve the consumer’s experience with your company and help to improve the consumer’s overall attitude toward their email address—and the email messages they receive.

According to LashBack, an email compliance company, a consumer, globally speaking, has a better than 50 percent chance of receiving email after unsubscribing.

Many unsubscribe files are transmitted in email or through unsecure FTP sites for use as a suppression file in affiliate marketing. Along with the unsecure data transfer method, these files are not encrypted and often contain additional information unnecessary for suppressing a consumer from receiving an email.

An increasing number of advertisers will protect their customer’s personal information, and provide their unsubscribe file in an encrypted format. The two most widely used email address encryption methods are MD5 Hash and SHA1.

Most email service providers and in-house mailing applications are not equipped to process a suppression file in an encrypted format. The publisher will have the option of either upgrading his email deployment system or manually preparing each suppression file before loading it into the deployment system. Email system enhancements require additional development time, and in the case of publishers who use an ESP, it will mean waiting for a new version release.

Along with email address encryption, guidelines for suppression file data standardization are needed. Publishers consistently receive advertiser suppression files in strange database formats that require clean-up and manipulation on the publisher’s part in order to make the file usable. The majority of publishers do not clearly communicate suppression file format requirements, and advertisers may not completely understand the technical nuances.

The perfect suppression file would be a text file (.txt as the file extension), have one email address per line, and contain nothing but encrypted email addresses. Advertisers can expect charges for suppression file formatting issues to be passed along to them in CPM rates if the suppression file fails to meet publisher formatting requirements. Advertisers engaged in CPA marketing can expect fewer publishers to promote their offers if the advertiser’s suppression file is a mess.

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The company was being scrutinized for its alleged use of the word “free” in various promotional online ad campaigns and whether or not the terms and conditions for receiving the “free” items were clearly and conspicuously disclosed.

The Attorney General did not make a determination that World Avenue USA violated any laws, rules or regulations, in turn ending the investigation. Dale Baker, President of World Avenue USA stated “This is the result we expected. We fully cooperated with the Attorney General’s office and after a very thorough investigation they have concluded that there was no reason to continue the investigation.”

He continued “While there are no findings of any wrong doing, we recognize this situation as an opportunity to take a leadership position in best practices by voluntarily agreeing to make certain changes to minimize the potential for any possible misunderstanding by consumers.”

Many industry watchers believe that this recent agreement is an indication of the need and progress towards standards and best practices within the promotional lead generation industry. Much like other online advertising segments, promotional lead generation and a number of leading companies like World Avenue USA, ValueClick, and AzoogleAds have been working with regulators to develop standards. The ValueClick investigation is still ongoing. Many have forecasted that these investigations would lead to the fall of promotional lead generation, but many industry analysts now expect it to be the beginning of clear standards that will lead to further growth.

World Avenue USA provides an online distribution platform that has been focusing on expanding its communications and advertising technology over the past two years. Baker said, “Our business is communication and we strive to be as clear and transparent as possible. We welcome and embrace feedback that enables the Internet to become a more effective medium for communication and commerce.” As part of its efforts to take on a position promoting the importance of standard and best practices in lead generation for online advertising, World Avenue USA, LLC will also make a $1 million contribution to the FL Legal Affairs Fund in support of the development and implementation of industry standards.