Should the FTC Investigate Word-of-Mouth Marketing?Posted by Brian Connolly
By way of background... back in early August, we contacted WOMMA to get them on the record with a comment about the FTC's upcoming hearings on Online Behavioral Advertising. On November 1-2, "the FTC will bring together consumer advocates, industry representatives, technology experts, and academics to address the consumer protection issues raised by the practice of tracking consumers’ activities online to target advertising.” Fact is, there's a lot of apparent similarity between "Online Behavioral Advertising" and WOMM. One tracks you quantitatively (cookies and such); the other qualitative. Both use analysis to spot trends in order to predict and leverage buying preferences. Both management functions are tasked with getting a better position in the marketplace on a macro level and a better position in the transaction on the micro level. Quacks like a duck? You bet! In fact, that's exactly what has WOMM all the rage. It's Behavioral Marketing on the cheap. Hell, most of the bigger PR firms and now engaged overtly in "Influence Mapping." Some of the Social Media revolutionaries even have what they are calling "Online Conversation Analysts." As one senior PR exec who's asked to remain anonymous said: "WOMM is the little sister of Online Behavioral Advertising. She's not as smart but she's learning quickly." That said, what is the FTC interested in? Apparently, some of the very practices WOMMA members are involved in. Specifically, the FTC wants to know:
HELLO!! Anyway, we've asked WOMMA to make a CLEAR distinction between what they do and what the FTC is investigating. It's been like pulling teeth. Here's how they've responded: Jim Nail, Chief Strategy & Marketing Officer, TNS Media Intelligence/Cymfony and Member of WOMMA's BOD, 8/28/07: "The more I think about it, the less I see a connection between the two issues. There are some pretty technically complex, legally thorny, touchy consumer perception issues with behavioral targeting that your readers would probably appreciate insight on. [However] I think it might be more confusing to them to introduce a whole other approach and a different set of concepts then try to explain why they aren't connected." And that's about as clear as mud. Bottom line, to paraphrase, "If I explain myself; I'll incriminate myself." Exactly. Well, maybe as PR and advertising race toward integration, WOMMA just might have to either fess up or exit stage left. Maybe sooner that they'd planned. We've learned that Peter Waldheim, Interim CEO WOMMA, is meeting with the organization's General Counsel next week to prepare a formal statement. But don't hold your breath that it will be totally transparent and actually say anything. REQUEST FOR COMMENTS Any person also may submit written comments on the topics to be addressed at the hearings. Comments may be submitted via e-mail to behavioraladvertising_comments@ftc.gov or by mail to Secretary, Federal Trade Commission, Room H-135 (Annex N), 600 Pennsylvania Avenue, N.W., Washington, DC 20580. Comments must be received by October 19, 2007. Bookmark This
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Brian,
We have ongoing discussions with the FTC about best practices in the emerging practice of word of mouth marketing. They like our approach and commitment to ethics so we look for every opportunity to share our POV with them. I haven’t had a chance to get the full details of their exploration of behavioral targeting as practiced by those in the online advertising field. But it doesn’t really involve WOMMA and here is my take as to why: The kinds of questions posed by the FTC make clear that it is focusing on issues that are germane to some forms of online marketing; but are related in only the most tangential ways to certain practices in the word of mouth marketing (WOMM) industry (if they are related at all). We begin with the premise that WOMM enables and sustains the conversations among consumers, customers and brands that drive brand growth. In this sense, our definition of “brand” is expansive, including not only corporate brands, but nonprofit and governmental activities as well. Our consistent strategic focus is on how brands can engage and enthuse customers to “talk about them” by offering quality products, great customer service, and pleasing experiences. In today’s world, of course, these “conversations” take place not only face to face or over the telephone, but by electronic means as well. We urge brands to avail themselves of the broad range of strategies, tactics, techniques, and technological capabilities that make it possible for them to establish new relationships with their consumers, and participate in conversations with them. Although the vast majority of these conversations still take place face-to-face (or over the telephone), the emergence of consumer-generated media has added a new and dynamic dimension, with great cross-fertilization between online and offline “conversations.” WOMMA is justifiably proud of the reality that we have made our Honesty ROI (Relationships, Opinion and Identity) a centerpiece of our activities, along with building a kind of organizational “neural network” to help our industry better understand best practices and issues related to measurement. If you look at the hundreds of speakers at our conferences, winners for our WOMMIE awards; presenters on our tele-conference calls, and more, you will find that we do zero work with behavioral manipulation. Our work with the online world focuses on such issues as involving people in communities, making tools available to help them spread the word, and soliciting and eliciting responses and opinions from consumers about their experiences with products and services. It is NOT on how to track consumers through cookies, or how to surveil individuals’ behavior over time (we do urge companies to listen and communicate with their consumers who post, for instance, to ratings or review sites, responding to concerns where appropriate). To summarize, WOMMA and the word of mouth marketing industry are focusing on how organizations can build better, more enduring, and more effective relationships with consumers through smart, ethical marketing. We are confident that the FTC understands this reality, as do increasing numbers of savvy and progressive marketers across the country and, increasingly, the world. Peter C. Waldheim Word of Mouth Marketing Association
Peter,
- “They like our approach and commitment to ethics so we look for every opportunity to share our POV with them.” And who might that be Peter? We’d like to speak with them. - “but are related in only the most tangential ways to certain practices in the word of mouth marketing industry.” See the feature we sent you, specifically paragraphs 3, 4 and 5. You are totally skirting the fundamentals. “you will find that we do zero work with behavioral manipulation.” What? Can you identify one C-level executive who has spent a dollar or more on WOMM who was NOT trying to otherwise influence and manipulate. Just one! That pretty much captures it. The rest of you statement is complete flatulence. You’re not answering any questions Peter, you’re writing an ad. The irony of course is that you are trying to manipulate. Sincerely, Brian Connolly Add Comment
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ABSOLUTELY! Why? Well first off, WOMMA, the trade association for the Word of Mouth Marketing industry, is acting guilty as hell. Sorry but it's human nature; obfuscation is born of something to hide. And that's exactly what they've done for about a month now. So much for that little transparency thing they claim as their cornerstone.