Advertising to Interest Groups without tracking

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@michaelkleber, can you email me at marcos at and I can help you move your repo over. Alternatively, we can spin up a new repository for you. Let us know how you would like to proceed.


Thank you. I understand that. How do we prevent multiple groups working on the same thing resulting in more complexity and difficulty for those trying to follow and contribute? This is a particularly acute problem for participants from smaller organisations.

How should we ensure that a proposal, no matter how it’s implemented in practice, provides an improvement to the web and all it’s stakeholders? A great deal of additional work is generated if a proposal is developed, only to find that it would never have achieved an improvement.

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You don’t need to follow everything. This is just an incubation… see it as a space/community that is experimenting.

When Google announced an “experiment” Criteo’s share price dropped 15.9%. Now more than ever participants need to follow “everything”. A subtle change may have significant consequences to different stakeholders. The less “everything” there is the better the engagement and eventual outcome.

Perhaps a pause is needed to enable the W3C Advisory Board to provide their advice?

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As I am a member of the W3C Advisory Board, are you asking for the AB to review this to provide an opinion? I am happy to ask them to do so, or any W3C Member can create an issue at Feel free to email me, cwilso at google, if you’d like me to file it instead.

I should preface this with: I’m a member of the AB, but not speaking for them; I’m Google’s AC rep, but not (in this instance) speaking for Google in regards to the actual proposals, as Michael is better informed. I’m a co-chair and founder of the WICG, and do have some role in speaking there, along with Marcos, Yoav and Travis.

The point of incubations is to let multiple potential avenues be explored, in the open. There have been incubations that “compete” before (conversion metrics comes to mind), there will be in the future; that’s by design. Incubations do not represent the consensus of the entire community. Community Groups and Business Groups both are not suited for representing such, as they are not do not function under the W3C consensus Process. Any incubation developed here would be expected to move to a Working Group in order to represent the consensus of the W3C (which would represent a blend of user, advertiser, developer and vendor needs).

I would point out that Michael’s expressed goal in bringing this here was to bring this area to the attention of more than just the membership of the Web Advertising BG - not to remove it from the view or engagement of the WABG. This work should eventually move into an (as yet uncreated) WG at the W3C, I would expect, and would have to do so even if the WABG had reached a complete consensus among themselves on a precise proposal.

Thank you all. I’d like to wait a bit and give Criteo folks a chance to speak up here also — my summary is already out of date, since they updated SPARROW with a new Reporting section earlier today.

@marcosc and other chairs: If the SPARROW folks also want to advance the two proposals together, I guess the obvious mechanism is to move them both into WICG independently, and then pick one as the base to update with consensus decisions. Is there anything cleverer, or any reason to look for such?

If we’re to build a more trustworthy and sustainable web, which meets all the values and goals of the W3C, we need to define what success looks like. That includes questioning and validating the anti-tracking stances of browsers which might work against the goals of an open web for all.

The anti-tracking stances of browsers are up to those browsers, and of course anything may change. But at this point I think there is considerable evidence that lots of ads are going to be shown in environments where tracking isn’t an option, for whatever reason — browser efforts, regulatory environment, user consent response, etc.

The point of this proposal is to further the state of what’s possible even if tracking individuals isn’t available. @jwrosewell I would think that a worthwhile goal, no matter what your personal opinion on browser privacy policies.

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Whilst some contributors may have the time and mandate from their employers to incumbate many parallel experiments to address the same problem, most participants do not. Establishing a common view of “success” and then evaluating competing early stage proposals, eliminating those that are weaker, will help everyone focus and use their time efficiently. This will expedite progress.

There is already sufficient information available about multiple proposals to perform an assessment of the likely impact on multiple stakeholders. As an example; in the case of TURTLEDOVE and SPARROW a major difference relates to the role of “gatekeepers” and client versus server side implementation. These proposals do not need to be developed further to identify and resolve these major differences.

I maintain that the esablished norms of governance require such a process to be undertaken. I’m struggling to understand why others think this established practice does not apply in this instance.

I would welcome @michaelkleber, @marcosc and others explaining the method they would use to evaluate competing proposals. Many other W3C participants have already provided a proposal in the form of the success criteria document being drafted within the W3C Improving Web Advertising Business Group. The feedback recieved on the most recent meeting is being incorporated into the next revision of the document for presentation next week. I hope it will better reflect the needs of browser vendors. If you can provide your methods here I will be able to consider incorporating them ahead of the next meeting.

@cwilso Thank you.This thread exposes a number of issues which I would like the W3C AB to consider holistically. I observe in the minutes of the May AB meetings some of these topics were discussed but not resolved. I believe the AB are seeking the opinion and viewpoint of a diverse set of members. I will prepare a concise summary of the issues for the AB to consider, post a duplicate here, and otherwise progress as you suggest.

On a different matter I’ve observed four of my comments have been flagged. Having read the community guidelines I’m failing to find any cause and therefore have no remedy available to me. Could you advise on the explicit reason or remove the flag?

The flagging was automatic (new users that post a lot of similar links are flagged by the system). I believe it is now resolved.

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Is there anything cleverer, or any reason to look for such?

Moving both sounds fine to me.


SPARROW contributor here.

We’re happy to move forward with WICG as long as the criteria to reach consensus are explicitly shared and acknowledge by all parties and reflect the interest of the open web ecosystem and their users.


Curious meta question: is Brave involved with this? I feel they would definitely at least be interested, as this is basically their entire business model.

Brave’s Pete Snyder expressed interest during this past week’s meeting of the W3C Privacy Community Group, noting the similarity to some of their work (minutes). Also I’ve had some conversations with ex-Braver Tom Lowenthal about variations of the idea here.

But they haven’t had direct involvement with this particular proposal; Brave is not active in the Web Advertising Business Group, which this grew out of.

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@ablanchard1138 The W3C’s process around consensus and dissent is described here:

The WICG charter says a little more on the subject, here: The charter goes so far as to consider producing two different proposals, if substantial disagreement remains. But since we’re coming in with two different ideas which we hope to unify, that’s obviously not the goal!


We’re happy to have SPARROW moved to the WICG, get feedback from and have discussions with the community.

Lionel for Criteo

@cwilso Thank you for your advice. Myself and other W3C observers / commentators opted for email to raise the more general issues of governance and trust choices.

Since first commenting the CMA have issued their final report which contemplates a common user IDs as a remedy to competition issues in the digital advertising marketplace. If the W3C were to embrace this recommendation then the need for this proposal, and all associated work would not be required. It would likely result in a focus on transparency and control proposals.

If a better method of filtering proposals at the conceptual stage existed W3C members and stakeholders would collectively save a lot of time and effort.

At RTB House we find both proposals addressing the needs of eCommerce advertising investment supporting a recognizable fraction of the web.

We would like to introduce the product-level perspective extension to both proposals backed with an estimation of a high-level impact on CTR. A detailed description of “Product-level Trutledove” can be found under this repository:

We invite all feedback, and we’re looking forward to further discussion!

We are also happy to hear what is the practice of extending current proposals on WICG

While I agree that the W3C should pay attention to the CMA report because anticompetitive issues have a history of harming the open Web, we should be cautious not to mix up remedies, and to consider who each component of the ecosystem works for.

The CMA’s report includes common user identifiers as a remedy to anticompetitive practices in electronic ad markets that trade in personal data. From that angle, their recommendation is very sensible. The manner in which electronic ad markets are currently operated by large players would be considered illegal in other electronic markets (notably finance) and I believe there is a very good case to be made that it should be illegal here. To the extent that information enters an electronic ad market, no party should be allowed to self-preference or use it for insider trading.

However, that is the perspective from competition and market policy. The question it answers is: “when information is traded, how should that trade be structured?” What it does not address, however, is the privacy side of the equation, and it does not purport to speak for users. Put differently, it does not address the question of whether a market in personal data should exist at all.

Users are, quite overwhelmingly, clear on what their preference is here. Just citing Eurobarometer, 89% of users expect their browser not to share data to third parties. It is the browser’s job — literally, it’s pretty much it’s one and only legitimate job — to be the user’s agent. That’s why it’s called a user agent: it could be argued that it has a fiduciary duty of agency with respect to the user. Web standards are equally held to this by the Priority of Constituencies which puts users first.

A default that supports third-party tracking is a user-hostile default. A browser that enables third-party tracking by default (or that uses telemetry for purposes other than its own betterment or the Web’s) is a browser that is failing in its fiduciary duties.

To return to the CMA report: when there is a market it has to be fair, but that does not mean that a market should exist. To make a comparison, to the extent that there is a market in organs it should be structured to prevent a single player from using insider information to tilt it in its favour. But that doesn’t mean that the market should exist in the first place. By the same token, if the electronic ad markets switch to trading contextual signals, it would be unfair to use advantage from a proprietary aggregation format or browser telemetry to tilt that market.

In your AB letter you claim that users should be allowed to choose to be tracked across their digital lives. I personally doubt that they would be interested, but that’s just one person’s doubts. If that statement is true, then there is a way to prove it: why don’t you develop a browser extension that users can install voluntarily, that exposes an identifier to the page, that has terms making it clear that sites cannot force users to use it (otherwise it wouldn’t be consent), and release that to extension stores? Technically, it is not a very complex undertaking. If it sees substantial uptake, it would prove your point the way no appeal to argument could.


@robin Thank you for the good feedback, specifically in relation to the important topic related to the need for a market.

I understand from an article published in May 2020 New York Times (NYT) believe a market in audience segments informed by personal data and identity should exist.

Your colleague Allison Murphy, Senior Vice President of Ad Innovation, is quoted in the article.

This can only work because we have 6 million subscribers and millions more registered users that we can identify and because we have a breadth of content.

This quote acknowledges that the barrier to enter such a market requires a large volume of subscribers and registered users. The article suggests a strategy that is independent of TURTLEDOVE, and other similar cohort based proposals. As such NYT future profits and viability are not dependent on the outcome of the proposals that centralize interest-based marketing into the browser.

Smaller publishers will need to “band together” via the use of suppliers (aka “third parties”) to operate the significant scale needed to compete in this market. If there were not value to a publisher, large or small, in such a market then why would NYT publicly endorse it?

I hope you would agree if small publishers and new entrants are excluded from such a market they will be disadvantaged. The likely outcome is that the variety of information and services available to people will diminish. Access to media will become ever more restricted. This is a key observation of the CMA report which impacts people and society.

The W3C’s purpose specifically prohibits the creation of standards that would lead to such an outcome. The W3C’s governance model needs to be modified to address this problem. The first step is for everyone to agree there is a problem. It is with this in mind the AB letter was sent.