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Comments to FTC 20 July 2010

Comments to FTC 20 July 2010

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Comments on Federal Trade Commission’s News Media Workshop
 and Staff 
Discussion Draft on “Potential Policy Recommendations
 
to Support the Reinvention of Journalism”
  July 20, 2010Introduction
Google Inc. submits these comments in connection with the Federal Trade Commission‘s news
media workshop regarding the intersection of journalism and technology. We also provide comments
on the FTC‘s recently released Discussion Draft on ―Potential Policy 
Recommendations to Support the
Reinvention of Journalism.‖
1
  The news industry is undergoing significant changes that present a number of challenges andopportunities. Because quality journalism matters so much to our users and to society as a whole,Google is committed to helping news organizations develop innovative ways to serve consumers andfoster revenue generation models that will sustain the continued vitality of the news industry. Thesemodels will succeed only if they meet the needs of two groups: Consumers looking for news that isrelevant to them, and advertisers who wish to reach those consumers with information about theirproducts or services. On the consumer side, Google makes it easy for users to find the news they arelooking for and to discover new sources of information. In fact, Google works constantly to providethe most relevant information through Google Search, Google News, and other products. As a result, we send more than four billion clicks each month to news publishers via Google Search, Google News,and other products. That is, every minute we send approximately 100,000 visitors to news publishersaround the world.Each click 
 – 
each visit
 – 
provides publishers with an opportunity to show users ads, registerusers, charge users for access to content, and so forth. As we discuss in detail below, how publishers
interact with users who visit them through Google is largely in the publishers‘ hands.
1
 
F
ED
.
 
 T
RADE
C
OMM
N
,
 
F
EDERAL
 T
RADE
C
OMMISSION
S
 TAFF
D
ISCUSSION
D
RAFT
:
 
P
OTENTIAL
P
OLICY 
ECOMMENDATIONS TO
S
UPPORT THE
EINVENTION OF
 J
OURNALISM
ISCUSSION
D
RAFT
 ).
 
 
 -
2-
For example, publishers may charge for their content if they choose to do so. In fact, publisherscan and do charge for content while ensuring that it is discoverable through Google
 – 
charging forcontent and availability on Google are not mutually exclusive. Indeed, Google is currently working withnews organizations that want to create online subscription services about ways to use our tools toachieve their goals.
On the advertising side, Google‘s AdSense platform helps publishers generate revenue from
their content by providing relevant advertising and improving the connection between advertisers andconsumers. In 2009 alone, Google shared more than $5 billion in revenue with AdSense partners. In
addition, many major media companies, including online newspapers, use Google‘s DoubleClick 
platforms to manage, and maximize the value of, their most valuable online advertising inventory 
 – 
thedisplay ads they sell directly 
 – 
to ensure that the right ad is placed in front of the right consumer at theright time. Google has invested significantly in these products, launching the new DoubleClick AdExchange and the upgraded DoubleClick for Publishers platform in the past 12 months.Google is also developing new formats for displaying and consuming news
 – 
such as Fast Flip,Living Stories, and YouTube Direct
 – 
which aim to improve the user experience and, consequently,increase the amount of time people spend with news on the Web.Finally, Google engages in regular conversations with news-industry trade associations, providesfinancial sponsorships and speakers for journalism conferences, and educates journalists on how to useGoogle tools to do their jobs better.In these and other ways, Google has worked productively with many individual newsorganizations and the broader journalism community. Most of these news providers share Googl
e‘s
 vision that the future lies in embracing consumer preferences and collaborating with Internetcompanies.
Business Problems Require Business Solutions Rather than Regulatory Ones
 The Discussion Draft contains several potential policy proposals designed to maximize theaccessibility of government information, and Google supports many of these proposals. Therecommendations on copyright, hot news, and antitrust, however, put forward by certain members of the news industry, will not solve the problems the news industry faces, but rather will stifle the very innovation that provides hope for its future. Our views on the specific proposals are set forth insubsequent sections.Here, we discuss a more fundamental point, which is that the current challenges faced by thenews industry are business problems, not legal problems, and can only be addressed effectively withbusiness solutions. Regulatory proposals that undermine the functioning of healthy marketplaces andstall the pace of change are not the solution. Indeed, the very innovation on the Internet that has led toso many improvements in the lives of consumers around the world is likely to be harmed by many of these proposals rather than enhanced by them.Newspapers have had periodic business model challenges since long before the Internet:Circulation by U.S. household has been on decline since the early twentieth century; the number of 
 
 -
3-
newspapers distributed peaked between 1890 and 1920.
2
Indeed, the debates over newspapers andcompetition, while less good-
natured in tone, easily fit within Yankees catcher Yoga Berra‘s famous
malapropism,
―It‘s like déjà vu all over again.‖
3
 In 1922 at the onset of the great Newspaper-Radio War, the same arguments and the samerhetoric currently being used to describe the Internet were used by newspapers about radio. ProfessorGwenyth Jackaway of Columbia University details this period in her book,
 Media at War: Radio’s Challenge 
to the Newspapers, 1924-1939 
. Professor Jackaway writes:In the battle between radio and the press, one of the most common tactics employed by print journalists in their efforts at institutional self-defense against the invasion of broadcasting was the invocation of sacred rhetoric. When making their arguments aboutthe dangers of this new technology, they frequently called upon the hallowed ideals of theculture, claiming their sacred value would in some way be endangered if radio took overthe job of journalism. Radio journalism, they warned, posed a threat to the journalisticideals of objectivity, the social ideals of public service, the capitalist ideals of property rights, and the political ideals of democracy. In the name of preserving these ideals, printjournalists argued that they, and not the broadcasters, were the only ones suited to gathernews and disseminate news in this country. Thus, as a means of defending their owninterests they invoked the interests of the nation.
4
 In 1957, newspaper editors
 – 
foreshadowing the rhetoric used by some against the Internet
 – 
 called televis
ion reporters ―parasites‖ and observed that they ―should handle their own news instead of cashing in on our brains and experience.‖
5
In 1955, newspapers vociferously objected to President
Eisenhower‘s decision to open up White House press briefings to tel
evision reporters: Famed
 New YorkTimes 
 
reporter James Reston complained that the ―press conference is an instrument vital to democraticprocesses and it is being overwhelmed by paraphernalia.‖
6
 
 After print journalists lost their ―war‖ against television
journalists in the Eisenhower era,newspaper companies fought the phone companies.
7
Indeed, as Professor Jackaway has observed, with
each communications innovation of the last 100 years we have seen a repetition of the discussion that‘s
taking place today over the future of journalism. Although the Discussion Draft suggests that the
2
 
 J
OSEPH
D.
 
S
 TRAUBHAAR AND
OBERT
L
 A
OSE
,
 
M
EDIA
N
OW 
:
 
U
NDERSTANDING
M
EDIA
,
 
C
ULTURE
,
AND
 T
ECHNOLOGY 
, at 94 (2005).
 
3
 
 Yogi is reported to have uttered this in reaction to Yankees pitcher Dave Cone hurling a perfect game against theMontreal Expos on July 18, 1999.
 
4
 
G
 WENYTH
L.
 
 J
 ACKAWAY 
,
 
M
EDIA AT
 W 
 AR 
:
 
 ADIO
S
C
HALLENGE TO THE
N
EWSPAPERS
,
 
1924-1939, at 7
 
(1995).
 
5
 
Quoted in D
 AVID
R.
 
D
 AVIES
,
 
 T
HE
P
OSTWAR 
D
ECLINE OF
 A
MERICAN
N
EWSPAPERS
,
 
1945-1965:
 
 T
HE
H
ISTORY OF
 A
MERICAN
 J
OURNALISM
, at 57 (2006).
 
6
 
Id.
at 56.
 
7
 
Id.
at 1.
 

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