Attribution API issues

[Tim-Cowen]

Movement for an Open Web (“MOW”) is an action group founded to advocate for a competitive, open internet. Many members were involved in the Competition and Markets Authority (CMA) Online Platforms and Digital Advertising inquiry in 2020. MOW is the chief complainant in Google’s Privacy Sandbox case, and we initially applied to the CMA for interim measures to prevent Google’s proposed changes to the browser. Whistle-blower protections are recognised in law the world over and play a vital role in helping the authorities gather necessary evidence from key witnesses, whose identity must be protected to reduce the likelihood of retaliation. We note that the CMA’s Privacy Sandbox case team have agreed to protect the identity of our members.

We are submitting the following issue in the W3C forum at the request of the CMA and Google’s recommended procedure for filing issues with their Privacy Sandbox, according to section 12 of Google’s Commitments.

Google’s slide deck presentation, entitled ‘Attribution Measurement Use Cases’ for the benefit of the Private Advertising Technology Group shows that larger companies are better equipped to differentiate the signals from noise. Google’s Commitments require it not to self-preference its own Ad Systems by continuing to retain access to input data that it restricts from rival ad technology providers. Given attribution matches marketer outcomes on their properties to prior ad exposures across publisher properties, Google should address in its Design how it envisages rival ad solution providers to generate attribution reports.

We welcome responses from @apasel422, @csharrison, @johnivdel, @jyasskin, @palenica, @cwilso, @hostirosti, @miketaylr, @Paul-Ki, @mthiesse, @davidvancleve, and @michaelkleber, or any other representative from Google in this forum. We would also appreciate Google addressing this issue in their next quarterly update report.