submits comments to FTC on behavioral ad guidelines

0, the digital division of the National Retail Federation, is recommending that the Federal Trade Commission move slowly in attempts to set voluntary guidelines for “behavioral advertising” on the Internet, saying technology that tracks how consumers shop provides a variety of benefits, isn’t harmful and isn’t as widely opposed as critics claim. has submitted a 14-page letter to the FTC on behalf of itself and NRF commenting on plans by the agency to issue non-binding principles to guide the use of so-called behavioral advertising.

“Retailers have long understood that keeping their customers happy is the most essential part of building positive, long-term business relationships,” said Scott Silverman, Executive Director of “The FTC’s proposed guidelines could have the effect of undoing many online retail best practices and innovations that customers inherently value.”

Even though the principles are intended to be “self-regulatory,” said the guidelines “likely will be viewed by the business community not as mere suggestions but truly regulatory in nature, with perceived violations being considered ‘unfair and deceptive’ under the Fair Trade Commission Act.”

Rather than issuing the guidelines, recommended that the FTC first conduct a study outlining any consumer harm from behavioral advertising and any specific deficiencies in existing industry practices, saying it “is essential that a complete record be formed.”