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Last week, Facebook was granted a patent for its news feed. Although it’s not yet clear how Facebook plans to use this patent, what is clear is that social media is growing up to be a real industry with real business sense.

With this patent, Facebook is in an excellent position to generate revenue off of its competitors’ success. But more importantly, securing intellectual property like this is a sign that the social network plans to be something much more than a place where to kill time at work.

Owning the Stream

The strange thing about Twitter’s success is that Twitter is more of a feature than a stand alone social network. That much is evident in how easily both Facebook and Google Buzz assimilated the Twitter stream format. And with the granting of this patent, Twitter might not even own the rights to itself anymore. As the patent abstract reads:

A method for displaying a news feed in a social network environment is described. The method includes generating news items regarding activities associated with a user of a social network environment and attaching an informational link associated with at least one of the activities, to at least one of the news items, as well as limiting access to the news items to a predetermined set of viewers and assigning an order to the news items.

It’s easy to see how a few social networking sites might be wondering where this leaves them. In fact, the very concept of a news feed seems to be part of what makes a social networking world go round. So now that one company owns the idea, they seem to have that whole world in their hands.

Intellectual Property & Market Share

In business, the real money is in intellectual property — it’s in owning ideas, content, and technology. And given how so many social networks are struggling with their revenue models, it makes perfect sense for these companies to start securing the rights to the basic features that make their their user experience what it is. With that in mind, there are three different things that Facebook could choose to do with this patent.

First, Facebook could decide to do nothing, and just keep this patent up their sleeve as a bargaining chip for some future negotiation with a rival. For instance, should Facebook explore some kind of search/advertising partnership with Google in the future, they could remind Google that Google Buzz is in violation of their patent, and use that to negotiate a more advantageous deal.

Second, they could decide to push out the competition by denying them the use of this feature. This will force many of Facebook’s rivals to close-up shop and users will end up spending more and more of their online time on Facebook than on some (now defunct) alternative.

Finally, and more in line with social media’s spirit of cooptition, Facebook can use this patent to charge their competition licensing fees for their news item feature. Not only would this bolster their ad revenues, but it would let them profit off of the success of their competitors.

This last strategy would also be a more sustainable one because it would give competitors a comfortable sphere of operation, and help prevent them from having to innovate entirely new ways of offering their own online user experience. Besides, users’ attentions are limited, and Facebook is probably nearing their maximum potential mind share as is, and this last approach would allow them to capture additional market share without having to capture additional mind share.

Buying Up More Than You Can Chew

Of course, winning this patent may only be the beginning (and not the end) of the intellectual property battle for Facebook. As Shevonne Polastre, a writer for Penn Olson pointed out, not only was Facebook not the first to come up with a news feed, and:

Due to the difference between Facebook’s newsfeed in 2006 and today, many of these social networking sites can have ways around it. Twitter can say that it’s a microblogging service, which has nothing to do with status updates. LinkedIn can say that it’s only tailored to business. Google can say that it’s a social aggregator, and not really providing updates on specific people.

So while it’s not quite clear what this patent is really going to end up meaning for the social media industry, what is clear is that social media is growing up. This kind of intellectual property strategy is the stuff that big industry is made of. It can be used to raise barriers to entry and put the competition out of business. It can control the competition by making them dependent on you. In the case of Facebook, the latter of the two options makes a lot more sense and seem much more likely.

More here:

The balance between security and privacy is again being tested as Google has recently requested the help of the US National Security Agency (NSA) to better secure themselves, and their users’ data, from future cyberattacks.

The request comes on the heels of a recent discovery that two Chinese schools, Shanghai Jiao Tong University and the Lanxiang Vocational School, an academic institution in China’s Shandong Province with apparent ties to the country’s military, were discovered to be the source of recent attacks against Google and 20 other large corporations. The attacks against Google were aimed at the Gmail accounts of Chinese and Western human rights activists.

The NSA’s Involvement

While both the NSA and Google at first would not confirm their new partnership, as details were being worked out, an NSA spokesperson has claimed they are working on an “information assurance mission,” that involves a broad range of commercial partners and research associates. However, when the Washington Post looked into this partnership, reporters were assured that working with the NSA does not mean that the government agency will have access to users’ searches or e-mail communications and accounts. Google will not share proprietary data either.

The Nature of the Attack

While the NSA certainly has the ability to help Google, or any company, protect themselves against a cyberattack, it is odd that a corporation with some of the top engineers and most brilliant minds would fail to take the necessary measures to prevent the type of breach that would warrant bringing in the NSA to clean up.

Even with the help of the NSA, attacks like these are nearly impossible to stop. In the case of the Google attack, users at Google, and the other targeted companies, visited malicious sites, that exploited a zero-day vulnerability in the Internet Explorer browser. The exploit downloaded an array of malware to the victim’s computer automatically and transparently. These programs then unfurled themselves into the network using sophisticated encryption to prevent detection.

Reactions

Upon learning of the proposed partnership, Marc Rotenberg, executive director of the Washington-based Electronic Privacy Information Center (EPIC), was quoted as stating that any relationship between the two would be “very problematic.”

“We would like to see Google develop stronger security standards and safeguards for protecting themselves,” he said. “But everyone knows the NSA has two missions: One is to ensure security, and the other is to enable surveillance.”

In a counter move, EPIC has filed a Freedom of Information Act request seeking NSA communications with Google regarding Google’s failure to encrypt Gmail and cloud computing services. The purpose of this, according to Rotenberg, is to find out what role the NSA has played in shaping privacy and security standards for Google’s services. This request was followed up by a lawsuit against the National Security Agency and the National Security Council, seeking a key document governing national cybersecurity policy.

In addition to concerns raised by EPIC and other privacy rights groups, the move calls into question Google’s promises made when joining the Global Network Initiative. As a member of the GNI, along with Microsoft and Yahoo!, Google has pledged to protect and advance freedom of expression and privacy despite increasing government pressure to comply with domestic laws and policies in ways that may conflict with these ideals.

Not all experts are concerned. James Lewis, director and senior fellow at the Center for Strategic and International Studies (CSIS), believes that it is unlikely this potential partnership will involve the sharing of personal data. Claiming that Google is more likely to only be interested in having the NSA take a look at its networks and help it identify potential weaknesses, “It has nothing to do with intelligence. That point appears to have been missed,” Lewis said, “I don’t have any direct knowledge, but that is my assumption in this case.”

Credit:
Google, NSA Partnership Brings New Privacy Concerns

You read that right. Today Drs. Foster & Smith, a pet medicine retailer our of Wisconsin, has shut down its entire affiliate program due to the Advertising Tax that has passed in 3 states and is being considered in many more. Oh, and it is effective immediately!

The reason stated was not that Drs. Foster & Smith didn’t want to collect sales and use tax for these states, as onerous as that may be.  Rather the reason was that Drs. Foster & Smith has been advised that it may be subject to state income tax. So rather than attempt to comply with a moving and often nebulous target they have simply decided to shut down their affiliate program.

The e-mail we received is below. I wrote more detail of the implications of this and suggestions for state legislators on my blog (italics and bold added by me for emphasis).

It is with great regret that we have to inform you that we are shutting down affiliate marketing at Drs. Foster and Smith effective immediately  February 22, 2010.  This closure is across the board in all states with all affiliates and is not related to you only as one of our affiliates.

We regret having to do this for a variety of reasons, not the least of which is that so many of you have done a great job for Drs. Foster and Smith and will be adversely affected by the loss of revenue from Drs. Foster and Smith sales.  Thank you for all you have done to promote our company on your web sites.  We apologize for the hardship and inconvenience that this creates for you.

The single reason for the decision at this time is the moving target of the ever-growing patchwork quilt of state legislatures that are considering nexus legislation relative to affiliate marketing and sales tax. It has become increasingly difficult to determine who is considering such laws, where they are in the process and what the ramifications are in each state.  What affiliates may not be aware of is that such nexus situations do not only relate to sales tax collection, but potentially state income tax for a corporation as well.

We wish there was clarity on this issue from state to state and nationally, but there isn’t.  So until this matter is cleared up nationally, we are shutting down all affiliate marketing.  We apologize for any hardships this brings to you and your team.  We have greatly appreciated the work that you have done on our behalf.  The sudden nature of the move by California to reintroduce legislation late last week and to push for a quick vote, emphasized the ever-changing nature of this issue and our need to be ahead of such votes and decisions.

With our appreciation for your contribution to our company,

Sincerely,

Drs. Foster and Smith Affiliate Marketing Team

It makes perfect sense they are concerned that if they are deemed to have nexus in various states, they will be required to file state income tax returns in all of those states. I remember as a certified public accountant doing tax returns for a company that had nexus in 19 states. It took a team of half a dozen of us months to get the returns done. I can see why the mere threat of having to file the returns is enough even if no income tax is due in those states that have changed the definition of nexus.

Affiliate marketing is about ROAS. In this case rather than hire a team of a half a dozen certified public accountants it is easier to turn the affiliate channel off and focus their advertising efforts in other channels where the threat of nexus is not an issue.

For Drs. Foster and Smith the threat was great enough that they simply cutoff affiliates with what amounts to a switch of a button.

Here is the original:
Advertising Tax Effect: Drs. Foster & Smith Shuts Down Its Affiliate Program

Politicians are slow to learn but quick to look for money. As SB660 clearly shows, Virginia is no exception to this rule. Made from the mold of other so-called Amazon Tax bills, SB660 passed a vote on the Senate floor 28-12. Its potential passage has dire consequences for Virginia affiliates.

What’s most frustrating about the seemingly never ending folly of such bills is that even their authors, Senator Emmett Hanger, Jr. in Virginia’s case, seem to know they are bad bills. Just take a look at the fiscal impact statement (pdf) published by the Senate Finance Committee of SB660:

When similar legislation was enacted in Rhode Island and North Carolina, large online retailers ended their affiliate programs. If this were to happen in Virginia as a result of this bill, there would be no additional revenue collected from the enactment of this bill. In fact, by ending affiliate programs Virginia vendors  would likely lose business and remit less Retail Sales and Use Tax to the state.

The knowledge of what happened in Rhode Island is telling since despite the fact Rhode Island collected no revenue from the tax the Virginia Senate Finance Committee went on to approve the bill to the Senate floor.

SB660 now moves to the Virginia House where it will have slightly stiffer opposition than the Senate. Affiliates still have a chance to rally in opposition. One good pressure point, as Adam Viener of Imwave pointed out, is Governor Bob McDonald who delivered the GOP response to President Barrack Obama’s State of the Union address in which he said:

“We must enact policies that promote entrepreneurship and innovation so America can better compete with the world. What government should not do is pile on more taxation, regulation, and litigation that kills jobs and hurt the middle class.”

The fight against HB1193 in Colorado serves as a great example of what a grassroots effort can do. Although the bill was not defeated it was changed significantly by the efforts of a group of around 150 affiliates. Recently Lisa Picarille, Content Strategist for the Performance Marketing Association, wrote an inspiring article covering those efforts. In the article Lisa quotes Nicki Hayes, a director at Adperio, as saying,

“Personal, specific communication also seemed to help. While organized efforts are great, the biggest response I received was by physically going to the Capitol to visit Senators (with other crusaders) face-to-face, and following up with those Senators via email. If they see you putting the time and effort into fighting the bill, they will give you the time and attention to at least argue it.”

Many people in the affiliate marketing industry consider the battle against HB1193 as a victory in that affiliates were removed as the target of the bill. It should be noted that the exact impact of the legislation if enacted is still unknown. There is some debate as to how the new changes will impact ecommerce in Colorado. Since retailers are risk adverse and Colorado did leave the ludicrous subpoena clause in the bill, those concerns are not without warrant.

That being said there is no doubt that it was the efforts of Colorado affiliates that changed the course of HB1193. They did so despite facing a one-party controlled legislature and a bill essentially introduced by Governor Bill Ritter as part of what has become  known as Ritter’s Dirty Dozen. Those are some incredible odds to overcome.

Affiliates in Virginia, and other states facing similar legislation, still have a chance to stop such bills.

For resources on how to contact and educate your local representative visit either the Performance Marketing Association here, or Affiliate Advocacy here. Both are great resources.

View original post here:
Battle Heats Up as Virginia Senate Passes SB660, Colorado Reminder of the Power of Grassroots Efforts

The recent attack on RockYou.com’s database opened many people’s eyes to a number of security flaws that exist on even some of the more popular web sites. To begin with, the RockYou social network’s database was susceptible to a Structured Query Language (SQL) injection exploit.

According to Jeremiah Grossman of WhiteHat Security, at least “16 percent of websites are vulnerable to SQL Injection” so while sad, it is not surprising. Jeremiah also sites Verizon’s Data Breach Incident Report (DBIR), which says that “SQL injection attacks, cross-site scripting, authentication bypass and exploitation of session variables contributed to nearly half of the cases investigated that involved hacking.”

More shocking is that the user account data that was stolen was stored in clear text – plain text that has not been encrypted. For a site as large as RockYou, this is unacceptable. Still, it is not the most frightening thing that is exposed by this attack.

When igigi, the hacker responsible for the attack, harvested over 32 million username and password combinations from the site, the passwords – not the usernames – were posted online for all to see. After the collection of passwords was analyzed by the Imperva Application Defense Center, the results were a bit astonishing.

Password findings

After looking at the collection of passwords, it was found that:

• 30 percent of users chose passwords whose length is equal to, or below six characters
• Roughly 60 percent of passwords came from a limited set of alpha-numeric characters
• Almost 50 percent of users used names, slang words, dictionary words or trivial passwords (consecutive digits, adjacent keyboard keys, etc)

And what were the most common passwords? The following table shows the top ten passwords in the first column. The second column shows the number of users who selected that as their password.

According to their findings, Imperva reported that in 17 minutes an attacker could compromise 1000 different accounts using a brute-force password cracking tool.

“Everyone needs to understand what the combination of poor passwords means in today’s world of automated cyberattacks: with only minimal effort, a hacker can gain access to one new account every second — or 1000 accounts every 17 minutes,” said Amichai Shulman, CTO of Imperva.

Combine this with the findings from the British firm Trusteer that “73 percent of Internet bank clients share online banking password with non-financial sites, and 47 percent re-use both their online banking user name and password” and you have a potential for disaster.

Strong passwords

While there is no excuse for the mistakes made by RockYou, any efforts made by them to protect their database would do nothing to prevent a brute-force attack from cracking some of these passwords in a matter of mere seconds.

To make things more difficult on attackers looking to steal your passwords, a few basic rules need to be followed:

• A password must be at least 8 characters
• A password needs to consist of at least 4 different types of characters – upper case letters, lower case letters, numbers, and special characters
• A password should not be a name, a slang word, or any word in the dictionary. It should not include any part of your name or your e-mail address

A common complaint about the strong password requirements is that they are impossible to remember. After all, Aghe83#Qs@ can be quite difficult to rattle off when logging in first thing in the morning. Rather than writing down a complex password like this on a post-it note stuck to the monitor, opt for a passphrase. HisBirthd@yisJune12 is pretty easy to remember and it abides by all three of the strong password rules.

See the original post here:
RockYou is Latest Reminder Not to Neglect Your Passwords

With the first round of the battle against the so-called Amazon Tax in Colorado over, Rebecca Madigan, Executive Director of the Performance Marketing Association contacted ReveNews in an effort to update readers on measures the PMA is taking in preparation as the focus switches to the Colorado Senate. The PMA is just one of many excellent groups, like Affiliate Advocacy, that is involved in the fight. We urge affiliates in every state to get involved with their industry groups and familiarize themselves with their local representatives.

What makes Colorado different than other states when it comes to the so called Amazon Tax?

So my background is not politics, but with all the grassroots battles we have fought in 2009 I’ve certainly learned a lot. The thing about Colorado that I haven’t seen in any other state is the political nature of this battle. Usually the thing that hits home and reaches state legislators is that these type of advertising tax bills will cost the state jobs. They will put small business out of business. And at the end of the day the State will still not collect any revenue from the tax. That message usually hits home.

They don’t seem to hear that in Colorado. In the House they kept saying over and over, “We have a budget shortfall and we need the money”. And they just don’t seem to hear the fact that there just won’t be any money. All they have to do is look at what happened in Rhode Island. Advertisers have control over their own business decisions and we saw almost 200 terminate relationships in other states. There is no reason why they won’t terminate in Colorado.

But what we’re seeing is this very coordinated effort by the Democrats, who happen to have control, in trying to push through all their tax bills regardless of whether the tax is sustainable, enforceable, or who it will hurt. Each individual bill doesn’t really matter to them I think. That’s my entire perspective from here, after getting beat down pretty hard yesterday (laughs).

The thing that we have to remember with politicians, the thing that I’ve learned, is that they always have some sort of higher purpose beyond the bill itself that they’re trying to achieve. In Colorado’s case the fight seems very partisan. Democrats have control of the House, the Senate, and they also have control of the Governor’s office. Bill Ritter, the current Governor, announced a couple of weeks ago that he’s not going to run for re-election. Essentially he is a lame duck governor. I think what we are seeing in Colorado is a very one sided push on legislation, sort of a rush to ram every bill through just in case the Democrats lose their majority.

On top of that, for a number of the House of Representatives in both parties this will be their last session. They are hitting up against term limits so we have a lot of lame ducks on top of the Governor. Because of that there was very little negotiation in the House from either Republicans or Democrats. Unfortunately as an industry we’re just getting dinged-up in the process.

How was the affiliate turn out during the House portion of the fight against bill 1193?

We had this amazing grassroots turnout against HB 1193 (pdf). We’ve had about 150 people actively writing letters, calling their legislators, and going to visit them at their office. We had 110 people show up at the Finance Committee Hearing last week. It’s been a tremendous show of force. I believe that’s going to make a difference. That’s the main tool that we have this tremendous grassroots participation and the citizens of Colorado showing up and expressing their dissatisfaction with this bill.

I have heard some express a little bit of frustration over lack of resources and coordination right now. Can you talk to that a little bit?

Yes, well…the PMA, as an organization, is trying to manage this, and it is taking up all of our resources, so yeah, we are a bit stretched. The issue that we face is there is a lot of activity going on in the background but we’re not necessarily telling the industry about it. That decision stems from counter-efforts we’ve been seeing from the American Booksellers Association (ABA) who are pushing heavily for this bill. For example, last week during the House hearing we heard testimony from a woman, the owner of a small bookstore, who testified she was advised by the ABA.

We had a similar problem in California. There we had a bunch of affiliates reach out to the blogosphere to say,  “We need as many people as we can to show up in Sacramento.” We used the affiliate community and all the blogs in associated industries to coordinate our presence there. Sure enough, in Sacramento ABA representatives showed up (laughs). We had announced positioning in our statements on the blogs, that we’re small business, that we are not establishing nexus; we had all these very logical arguments why this law is a bad idea. The ABA went up after us with point by point counter arguments. Like they had prepped from our announcements.

So when I heard this woman mention them, I thought, “Oh no, here we are again.  They’re already watching what we’re doing.” To counter that we’ve setup a registration form on the PMA site and we’ve asked people from Colorado to register with us so we can keep in communication with everybody via email only.

It is one thing to talk to the industry, to those involved on the ground, about the status of things; but what we don’t want to do is give the opposition the tools to out-maneuver us.

How will the House amendment attempting to “exempt” electronic affiliates impact matters?

It is a unique clause (pdf) that was negotiated at the House Finance Committee hearing. On the surface it looks like it is good for affiliates but in reality that’s just not the case. Based on the amendment, the House defines an affiliate as someone who makes a public referral to an online site or a face to face referral to an online site; specifically excluding an electronic solicitation of business.

Strangely that language essentially targets groups like the Boy Scouts, PTAs organizations, and churches who have web sites that have affiliate links as a way to raise money. I’m not at all sure about the political “logic” behind that (laughs).

But here’s the reality. By the nature of the industry model an advertiser does not know if an affiliate is physically directing traffic to their web site. They have no idea if they are referring business through online advertising or via face to face interaction. Rather than take the risk, advertisers will terminate if the bill passes.

This is particularly true in Colorado because of a particular clause in HB 1193 which is very unique. It essentially says the State has the ability to subpoena out-of-state advertisers believed to have nexus, and actually says that if they fail to comply those advertisers can be arrested. Now, there is plenty question as to the constitutionality and enforceability of that clause but ultimately advertisers are risk adverse. They will not take any chance at all and will likely terminate their affiliate relationships.

The “electronic” clause does not solve anything at all. It was a political move to pacify everyone in the room.

What is the next step in the upcoming fight in the Senate? What are some of the take-aways that we can learn from the loss in the House?

For each state that this comes up in we really need to understand what the political situation is and we need to make sure that our messaging reflects what we think might be successful with the political situation. We hope that other states aren’t quite as bad as Colorado because they’re in a real political battle that has, like I mentioned, nothing to do with the reality of the bills.

The fight in the Senate might be a little easier to manage. First of all there are fewer of them, which is helpful (laughs).  Unlike the House, in the Colorado Senate there is a much lower percentage of Senators dealing with term limits, so they have re-election on their mind which is something we can leverage.

We don’t quite know what the Colorado Senate is going to do, what their next moves are, who the decision makers are going to be, or when they’re going to have testimony. So we’re in this waiting period right now. In the meantime we are leveraging the political advisors we have access to in order to determine how to approach individual legislators.

What groups is the PMA coordinating with in Colorado?

We’re working with this group of political advisors which includes a dozen or so political experts from a lot of different companies, some very large companies like Google, Yahoo, Amazon, AOL, Microsoft, and Apple. We’ve been able to work with them and synchronize lobbying efforts. And there are other associations that have to do with internet legislation that we have been working with, organizations like Internet Alliance, Tech America, and Net Choice. We are all trying to fight these bills, maybe for different reasons, but sharing our information is the most effective route.

What would you like to see from the grassroots groups that are trying to self-organize in Colorado?

The local groups are fantastic because, of course, they know who their peers are and how to reach them. It was the grassroots groups that actually found the 150 people who have been consistently participating. We’re trying to work closely with them to create tight coordination of our efforts. There are a couple of critical reasons why we need tight coordination. One is effectiveness. The more people we can get to be on message at the same time  allows us to generate the more attention. It is very easy then to get the legislators to understand what we are talking about.

The danger is that if we don’t coordinate we risk the legislators getting confused, hearing different things that are not central to our argument, and causing them to fixate on things the opposition is saying.

For example, take North Carolina. That was a state where a similar law was passed. What we saw happen was that all of the legislators on both sides of the aisle, Representative and Democrat alike, became completely fixated on Amazon. The bill became all about “get Amazon, get Amazon, get Amazon”, and there was nothing we could do to convince them that there were small businesses that were being devastated in the process.

I am concerned the same thing might happen in Colorado if we don’t stay on point, if we don’t stay with really simple messages. There are probably a hundred reasons why this law is a bad thing, but we need to stick with 2 or 3 that we think will be meaningful and will change the minds of the legislators.

OK, so what are those 2 or 3 points?

Collectively with our lobbyists we are working to figure out what the vulnerable pieces are; where the opening in the armor is, if you will. In the House we thought small business and job loss should be enough but it wasn’t. What was really frustrating was that it wasn’t even raised by the Representatives who are supposed to be against this bill. So with this next round we are trying to figure out what is the right position.

It is something we will disseminate to the group soon. If local affiliates want to be informed we encourage them to get on our email list.

What can the local small affiliate who is worried about losing their commission, their business, and maybe their livelihood do to feel that they’re not just sitting and waiting for the other shoe to drop?

With this kind of a grassroots campaign where there’s already been a big push initially, it is common for participation to diminish quickly. It’s really hard to rally people. But here we have a core group that’s really excited, that wants to keep pushing and that core group is much larger than we’ve seen in other states.

Just to give you an example, in California there are 25,000 affiliates in the state and we got about 15 people to consistently help in terms of showing up in Sacramento (laughs).  Thankfully they were a very efficient 15 folks. There are 4,200 affiliates in Colorado and we have 150 that keep pushing really hard. It’s great to see that kind of turn out.

Obviously they can write letters to the representative in their district (here is a list of Colorado Senate districts). We will be distributing letters specifically for Colorado that LinkShare helped put together.

Beyond that it is really important to coordinate the push. Our lobbyists have been speaking with Colorado Senators since Friday. They’ve worked all weekend gathering information. We will be coordinating a campaign this week specific to the Senate.

The upcoming hearing of the Senate version of HB 1193, sponsored by Senator Rollie Heath, is scheduled for Thursday, February 4th with the Senate Finance Committee which will start consideration around 9:30 a.m.  It is vital that at this hearing we have a strong turnout.

What would you like to see advertisers do in terms of supporting Colorado affiliates in this fight?

I would like to see advertisers get involved and communicate with their affiliates as well as communicate with the Colorado State legislators. Advertisers can contact Senators directly or even better, have them work through me at the PMA and we can make sure information gets to the ears of the decision makers.

Is there anything else you want to cover in terms of messaging?

We need people to hang in there and keep fighting even if they are frustrated. This is definitely one of those marathon situations. There are so many analogies: this is a football game and we are only in the third quarter (laughs). If you live in Colorado and you haven’t heard what is going on you can register on the PMA website to get on our email list so you can hear blow-by-blow what we are doing to win the fight. We just have to keep working together and leverage the tremendous grassroots participation because I think that is going to be the most effective tool we have.

I want to thank Rebecca Madigan for taking time for today’s interview.

See the original post here:
PMA Urges Patience and Coordination in Colorado Tax Fight

It has been a long week of fighting for Colorado affiliates against HB 1193 as it moved through the House. There were strong shows of solidarity by  local affiliates organized by Brian Fox, Senior Director of Business Development at  Adperio, as well as impassioned articles asking if State representatives were putting work-at-home moms out business. There was also near Machiavellian maneuvering by the likes of Overstock and Amazon using their affiliates as bargaining chips.

What all this boiled down to was one vote. As of today, the Colorado House of Representatives has passed HB 1193 (pdf) by a 33-32 vote. The bill was introduced on January 22nd, 2010, by Colorado State Representative John “Jack” Pommer, who is also Chair of the Appropriations Committee, and Senator Rollie Heath. If fully ratified the bill is expected to commence on March 1, 2010.

The battle now moves to the Colorado Senate. Colorado affiliates can take some hope in two indicators of that the legislature is feeling pressure from affiliate activity:

1. HB 1193 was amended to include an attempted exemption (pdf) for “electronic” affiliates. While this will not keep merchants from terminating affiliates simply for fear of complying with nexus issues, a stance which Representative Pommer likened to “extortion” it does indicate that small business in Colorado will be hurt if this bill passes.
2. One Democrat voted against party lines against the bill. Considering the type of pressure Colorado is in to finding additional revenue resources, for a representative to vote non-partisan, especially when that party is the one who sponsored the bill, is indicative that the pressure being applied  is starting to work.

It is time to ramp up  that pressure in the Senate.

To find out more about HB 1193 visit either the Performance Marketing Association here, or Affiliate Advocacy here. Both are great resources. There is still time to impact the outcome of this legislation.

Read more from the original source:
Breaking News: Colorado HB 1193 Passes House, Battle Expected in Senate

Despite Overstock’s maneuvering and the local efforts of Colorado affiliates organized by Brian Fox, Senior Director of Business Development at  Adperio, the Colorado House Finance Committee has passed HB 1193 (pdf). The motion passed with a 6-5 vote and with only a slight amendment, mostly in reference to appropriation.

The bill was introduced on January 22nd, 2010, by Colorado State Representative John “Jack” Pommer, who is also Chair of the Appropriations Committee, and Senator Rollie Heath. If fully ratified the bill is expected to commence on March 1, 2010.

To find out more about HB 1193 visit either the Performance Marketing Association here, or Affiliate Advocacy here. Both are great resources. There is still time to impact the outcome of this legislation.

Here is the original:
Breaking News: Colorado Finance Committee Passes HB 1193

In a high stakes game of chicken with state legislators, Overstock is once again using the threat of affiliate terminations as leverage in a preemptive move, this time with Colorado state bill HB 1193 (pdf), as the target. The bill, introduced on January 22nd, 2010, attempts to establish responsibility for collection of sales tax for out‐of‐state retailers if those out‐of‐state retailers use Colorado‐based affiliate relationships as a method of advertising. The bill is set for a hearing in front of the House Appropriations Committee for on Wednesday, January 27, 2010 at 8:30AM.

Sponsored by Colorado State Representative John “Jack” Pommer, who is also Chair of the Appropriations Committee, and Senator Rollie Heath, HB 1193 is comprised of the same DNA as the so-called Amazon Tax that was passed by New York State in 2008 and which is currently making its way through a series of legal challenges lead by Amazon. In its’ current incarnation Colorado’s version of the bill does not stipulate a minimum amount of revenue for nexus and  mistakenly treats affiliates as a sales force rather than as publishers  engaging in a method of advertising.

While I don’t condone the way Overstock President Jonathan E. Johnson III callously uses affiliates as bargaining chips, this type of tactic worked quite effectively in California with AB 178 which was ultimately led to a veto by California Governor Arnold  Schwarzenegger. Schwarzenegger even mentioned and appealed to Overstock directly in his reasoning prior to the veto.

In an effort to display small business solidarity and put a face to those in the affiliate industry who would be hurt by Colorado HB 1193, Brian Fox, Senior Director of Business Development at  Adperio, has organized a  meeting at the Legislative Service Building, located on corner of East 14th Avenue and Sherman St., which is directly across the street from the Capital Building. You can find more about the group on Facebook here.

To find out more about HB 1193 visit either the Performance Marketing Association here, or Affiliate Advocacy here. Both are great resources.

If you wish to contact Rep. Jack Pommer you may do so through the following: email:  jack.pommer.house@state.co.us; phone: 303-866‐2780.

If you wish to contact Senator Rollie Heath you may do so through the following: email: rollie.heath.senate@state.co.us; phone: 303-866-4872.

More:
Overstock Threatens to Terminate Colorado Affiliates Over Pending Legislation

Ok so I can’t, but apparently some web loyalty firms are able to. Some at least are starting to change their business model as pressure mounts from Congress due to consumer complaints. As of January 8th, 2010, your 16 digit credit card number is now required to enroll in loyalty programs from Affinion or so says a press release from U.S. Senate Committee on Commerce, Science, and Transportation.

Why is that news? Previously loyalty programs like Affinion and Vertrue, Webloyalty, etc only needed your email address to charge a subscription to your credit card through the post-transaction pages of retailers such as Priceline, VistaPrint, Intelius, Buy.com and others. Called post-transaction marketing it is a way for loyalty programs to get consumers to agree to offers that appeared free but usually were tied to monthly subscriptions. Often the consumer would unknowingly “opt-in” to being charged by checking a box at the end of the shopping cart process. That’s when the retailer would pass the card information and subscription “request” to the loyalty program.

In a related article on Dow Jones, both Vertrue and Webloyalty admit they exceed the law’s requirements by increasing enrollment requirements in their programs in order to charge users – from just an email (early last year) to an email and the last 4 digits of your credit card (late last year).

Yes, you heard that right, as recently as of last November, as I was writing about the offers and scams, loyalty programs were exploiting their own version, and were helping firms rake in millions by charging users $10 to $20 a month for subscriptions they ‘agreed to’ without entering their credit card numbers. I mentioned the $1.4 billion extracted by these loyalty systems before, keeping up on the issue really shows how tricky, persuasive, and well engineering these programs are. Per the Senate document (pdf), approximately 30 to 35 million users were entangled into these schemes, or roughly the equivalent of 1 in every 10 Americans was suckered into these programs.

So, the basic math around this is as follows:

• $1.4 billion in receipts
• 30 million users affected minimum
• approximately $46 per person went to these programs.

Since the amount of post-sale transactions typically fell in the $10 to $20 range, that means on average, users paid into these programs for  2 to 5 months.

There are some lessons that I’ve extracted from learning about this, and maybe one of them will helpful.

1. You can be charged by just entering your email into a post-transaction offer. It’s legal, and it’s been happening for a while.
2. Read the fine print,  better yet, exercise extreme caution when presented by a post-transaction offer. I’ll skip/cancel them all myself, thank you.
3. Check your credit card statements religiously, since #1 (above) is not illegal, you can and may be charged at anytime.

But even as you try to protect yourselves, be aware that the post-transaction marketing firms are lobbying congress to protect their industry and maintain their wealth-building status quo. At stake are over $1B in revenue, and the senate report lists 19 companies making over $10 million and another 72 making over $1 million.  Money that comes from the pockets of you and I.

View original here:
Once Upon a Time I Could Charge Your Credit Card Using Your Email

When the Federal Trade Commission’s new blogger disclosure rules went into effect on Dec. 1, bloggers were not just faced with ethical exposure, they were also faced with a Web design dilemma.

With the FTC wanting to know the relationships between the writers and the products they write about, the question becomes how and where bloggers should display the information on their sites.

Because of the archival nature of the Web, every post about any product is just a Google search away, so it’s unrealistic for the FTC to expect bloggers to go back and retroactively disclose relationships on past posts. Instead, most bloggers have decided on a separate page with a list of their relationships with businesses.

Chris Brogan, the well-known blogger and social media consultant, has done just that with brief mentions of his disclosures on his site’s About page. Read it here.

Included on that list are Brogan’s affiliate relationships as well as products he has received for review.

In contrast, author Tim Ferriss is much briefer on his disclosure page, linking out to a bio of his investments. Read it here.

After Dec. 1, other bloggers decided to weave their disclosures into individual blog entries and leave it at that. Implementation of the disclosures has been inconsistent and will be even more so as social media endorsements start to gain more and more focus. How do you disclose a positive Tweet in 140 characters or less?

Bloggers need to consider what works for them best. Having these disclosures on a FAQ page seems convenient but could also become out-of-sight, out-of-mind.  For the sticklers at the FTC, top-of-mind is what’s going to quickly become the name of the game.

The rest is here:
FTC Makes Bloggers Ponder How to Disclose

In the last post I provided some background on offers and the confusion they may cause. I also pointed out the potential for scams. In this article, I’ll put a little more focus into the complexity of the offer systems and show another example of how confusing offers could lead to complaints.  For the sake of this argument, the values used in my examples are chosen for effect and are not accurate for any specific offer system.

Previously I described an offer for a free Walmart gift card.  The offer awards 21 points for participation in and promises to earn you a $1,000 Walmart gift card as well.  But what are the economics behind the offer?  How is it fiscally viable for a free survey or trial to result in you getting 21 points that would actually cost you $5 to purchase? In this case, it seems too good to be true, and it is. There are two views of the systems. First, the positive view: cost of acquisition.

In this model, when a company knows it typically takes $3 in direct and indirect advertising to acquire a customer they might decide to spend an amount less than $3 to acquire a new customer. For example, an offer may yield a $9 a month subscription to Netflix, at say a $2 cost of acquisition, and a subscriber who may or may not use the service. Typically, the offer would yield a trial customer, costing Netflix $2 in marketing, plus the gross operating costs to support that subscription, but no continuing subscription. For illustrative purposes, let’s say the trial included four discs, sent and returned, at a cash flow cost of $0.80 per disc (due to an estimated cost of $0.40 shipping each way for each disc) for a total of $3.20. The non-converting trial user cost is then $5.20 (or $2 + $3.20). Again, these numbers are estimates that may be off, but have some anchor to the real costs of the offer.

Then, there’s the negative view of the system in which advertisers get fleeced and users get scammed.

This model is comprised of two components: in point A, users take offers with no intention of spending any money with the advertisers, and (B) unknowing users sign-up for subscriptions without intending to. To illustrate point A, I encourage users to briefly visit the sites mafiawarstrategy.com or their sister site mobsterstrategy.com, both which cater to players of mafia/mobster games by Zynga, mentioned in the first part of this series, and Playdom, another large social gaming company. On these sites, and sites like them, you can find instructions on how to pick and choose offers, which offers are free, which offers to avoid due to spam, and how to manage your offers to insure you don’t get charged a penny.

My favorite part of the posts at these sites is that they carefully explain how to spot and avoid confusing offers that may never result in points. Worried about getting scammed? Well, these sites tell you what proof you need to get your points, the minimum actions needed to get your points, and what happens if you don’t do enough or don’t have proof. Be warned that you can’t access the content of these articles unless you do an offer. Of course, I make no guarantees on the quality of the offer that you’ll be shown.  And you should know that the ad network for the sites claims that publishers are paid $1 per action/offer completed.

So if you’re ready, go here. An image of the page you’ll see is below:

Note the phrasing on the page from the ad network: “These DO NOT require credit cards or trial signup offers”. Remember this screen for later in this article. If you click through or at least believe what I’m saying, you’ve already noticed that the article is all about getting points for free and not sending any money to the advertisers.

Now, on to point B and the risk users run for getting scammed. Let’s start by looking at the ‘free survey’ selections.

When you choose the IQ quiz you’re given a series of questions. The two images below  display the survey start and the first question. The IQ quiz seems harmless enough, and even better, I’m promised 21 points for answering a few simple questions.

Now, as you advance to the last quiz question, you get used to quickly clicking answers and never scrolling down. The questions are simple and nicely framed and there is no need to look below the frame of the quiz.  Once you reach the last screen, below, by rushing through the ten easy questions you’re faced with an innocuous phone number entry box and the prompt: “Enter your phone to get your results”.

The blackboard frame in the picture provides a psychological cue to stay focused on the quiz and NOT scroll down to the bottom of the page. So if you don’t scroll down and just enter your phone number, you would have just subscribed to a $4.99/month mobile phone service (see the small print). If you don’t enter your phone number, you would still have completed the survey, right? The only reason to enter your phone number was to get the results. Now, if you try to exit the survey, another page pops up trying to entice you to do another survey:

And if you close that, you end up on the article where you started, but the blocking overlay has changed:

You completed the offer by taking the “no credit card/no trial” quiz, but you did not take the final step to get your results and subscribe to the $4.99 monthly service. By the letter of the offer, you should have earned a reward; access to the article, or your 21 game points.

But the reality of the situation is that the ad network has to pay the publisher, so unless the user subscribes there’s no money to sponsor the offer. Users need to pay somehow, and these offers depend on people not reading the fine print and not scrolling down the page.

So what just happened? A user wasted his time, did not get his points, and the advertiser got nothing since the user failed to subscribe. And even if the user did subscribe they would likely unsubscribe immediately, as instructed by the article behind the offer wall.

Confused? Most people are. These offers have lead to various tech magazines citing revenues over $300 million for these types of offers, while related reward offers have been cited at $1.4 billion in a recent senate report.

So with 100 million teens and tweens looking for a leg up as well as ‘points’ to help them in games, do you really believe that they all read the fine print? Or that they will be able to find the fine print in an easy and non-confusing manner? It doesn’t take a high IQ to figure out the answer to those questions. And that’s somthing the scammers will try to take to the bank.

Excerpt from:
Virtual Goods, Offers, and Scams: Part 2

There’s been alot of hype and debate around the concepts of virtual goods and offers due to a few high flying companies which have been media darlings. The highest profile company in question is Zynga, athough other social gaming sites and social networks have employed similar tactics. All have enormous user bases and are pulling in hundreds of millions in revenue, but the debate centers around how they make earn money. There’s too much to cover in one post, so this discussion will be split into two posts, with this one providing the basis for the controversy.

By some estimates, these companies may earn 1/3 of their revenues from something called “offers”. What is an offer you say? An offer, for the purposes of this article, is an exchange of information and/or actions to earn credit spendable on a web site, virtual world, or online game. The concept is simple and particularly lucrative.

Web site visitors or game players can get in game points or currency that they can spend on upgrades, weapons, tools, or other power ups that give them an advantage. The points, often called cash, coins, or gold, can be purchased directly using several payment instruments; but for the cash strapped, unbanked, cheap, or income challenged, a more attractive mechanism is to use offers to gain these credits. Offers, up until a month ago when negative media attention from sites like Techcrunch and backlash caused Facebook to clean house, included surveys, quizzes, trials for magazines, game rentals, DVD rentals, credit cards, and more, many of which touted free trial or no cash or credit card required.

The partial list of offers (left) entices the user to enter trials, sign-up for services, or take quizzes and surveys.

What makes offers so attractive? How does “Fill out a survey and earn 19 points” sound to you? Especially when 19 points gets you a 10% boost in game income, increased character speed or other abilities? So for just a few minutes of time, you can earn the points that other gamers may spend their hard earned cash on.

For example in the popular game Mobsters, by Playdom, it would cost you $4.99 to purchase 21 points; thus taking these surveys sounds attractive since the math would suggest that if I completed a survey every 10 minutes, in an hour I would have done 6 surveys, earned 126 points, and saved nearly $50. But think about what just happened – the discussion turned from 1 survey and 19 points to a subtle assignment of a working wage for the game player, where he/she could earn the equivalent of $50/hour. Other offers include Blockbuster video trials, Netflix trials, Credit Cards sign-ups, mobile phone content trials, and more. Great deal for the end user, on the surface.

Before going forward, I need to add that many of the scammy offers have already been removed from by many of the providers due to the media attention, however, even the remaining offers by reputable companies still have issues. The risks of these offers fall on the user signing up for the offer and the merchant sponsoring the offer.

• Does the users know what he or she is signing up for?
• What quality of lead is the merchant receiving?

Problems arrise due to confusion over how to complete the offer. The Entertainment book offer button takes the user to a page with no actual mention of the offer. Are users supposed to sign-up? If so, how do they get credit?

The same problem appears for the Direct TV offer. How does the user know what to do? How does he/she earn credit?

By now you may be wondering where the deal really is. If users have to pay for subscriptions, why don’t they buy points directly? Do users always have to spend money to get their points? You’ve now hit the tip of the iceberg and are wondering if this amounts to a system for scams.

As a starter for the next post, consider the two images below.

The offer is not from Wal-Mart, but from a rewards program company, and it looks pretty good, right? Well, if you read the fine print you’ll see that to get your ‘free’ $1,000 gift card you must complete 13 offers. But click through and look at the second image: you’ll see it says you have to complete two offers to get your ‘free’ gift. How does this make sense? The user was lead to believe they had to complete one offer to get their free 21 points. This is starting to smell like the BlueHippo investigation by the FTC, where offers were supposed to get you a free PC. Yet they only shipped one. Yes one.

In my next post I’ll discuss my experience trying a few of these offers, some additional math around the business, and discussion on the even larger problem that this is revealing.

Excerpt from:
Virtual Goods, Offers, and Scams: Part 1

If the Federal Trade Commission had the intention to spark off a wave of sometimes worried, sometimes angry and often indignant blog posts and forum chatter with their “Final Guides Concerning the Use of Endorsements and Testimonials in Advertising”, they’ve certainly succeeded.

About a week ago, ReveNews contributor Andrew M. Baer, Esq, wrote “FTC Regulates Blogger, Viral Marketing Relationships: Analysis and compliance tips” stating why he’s not concerned about the FTC intentions.

The guides which come into force on 1st December, are aimed at addressing endorsements by consumers, experts, organizations, and celebrities, with the intention of holding bloggers or other “word of mouth” marketers accountable, with the enforcement mechanism of a possible $11,000 fine.

As short-sighted and ambiguous as some bloggers have painted the guides to be, many bloggers’  objections have been equal in the fear, uncertainty, and doubt camp as they accuse their detractors. Many blogs painting worst-case scenarios and posting what-if scenarios with $11,000 fines for receiving cheap paperbacks as a freebie in the mail, writing a positive review and linking it to an Amazon affiliate link.

The Interactive Advertising Bureau (IAB), which comprises more than 375 leading media and technology companies is responsible for selling 86% of online advertising in the United States and includes organizations like:
* AOL Advertising
* AT&T Internet Services
* BBC Worldwide
* Google Inc
* Microsoft Advertising
* Yahoo! Inc
* Sony Computer Entertainment America, Inc
* Harvard Business Review
* CNN.com
* FOX Interactive Media
* Nokia Inc

and other technology/internet/news heavyweights in its membership roster. IAB has come out swinging off the ropes with IAB CEO Randall Rothenberg firing off an open letter to FTC chairman, Jon Leibowitz, published on the IAB website and the Huffington Post, expressing his disagreement with the guides on the basis that they are unconstitutional and should be retracted.

In case you’re wondering if the IAB is shooting from the hip, take note that the organization has attempted to start a dialogue with the FTC since March this year, with correspondence detailing(pdf) feedback on the proposed guides. The attempt to have the industry self-regulate appears to have failed, given that the FTC has expressed its intention to keep an eye and active hand in the industry.

In a FTC arranged media call on 14th October to address reporter’s inquiries on the guides, FTC’s Bureau Consumer Protection’s Associate Director for Advertising Practices, Mary Engle, stated:

Although the [Interactive Advertising Bureau (IAB)] contends the FTC’s Endorsement Guides are unconstitutional, the Guides apply only to marketing and they attempt to illustrate some of the factors relevant to distinguishing advertising from editorial content,” says Mary Engle, the FTC’s director of the division of advertising practices, in an email statement released today. “If particular communications do not in fact constitute advertising, as the IAB appears to be suggesting, then the Guides do not apply. Where the message is advertising, however, disseminators have an obligation to ensure it is not misleading. This includes, when it is not otherwise clear from the context, identifying when the endorser has been paid for the endorsement. Although IAB may disagree with the policy, nothing in this approach is unconstitutional,” .

From FTC’s Engle terse reply, it’s unlikely to halt the IAB’s attempt to rescind the FTC’s guides.

Even with the FTC contention that the primary targets are advertisers, rather than bloggers, have failed to assuage Rothenberg.

IAB’s Rothenberg contends that even with the FTC’s intention to go after advertisers, rather than bloggers, doesn’t mean that bloggers are off the hook. By it’s “social” nature, bloggers and their blogs are the advertising medium, hence they could still be looking at $11,000 fines.

How will this play out as the December 1st enforcement date draws near?

It’s unlikely that the FTC or IAB are going to back down at the moment, but the IAB’s Washington DC Public Policy office will be keeping very busy till then.

Continued here:

At first glance, the credit report/repair niche looks highly lucrative – with high lead generation payouts and search volume at stratospheric levels – one might wonder, “What’s not to like?”. That is, until you factor in the Federal Trade Commission’s (FTC) keen interest at online marketing practices in the niche.

High search volume + high offer payouts = A perfect niche?
Is the financial niche a strong one? You betcha.

Comparing “head traffic” via a broad keyword like “credit report”, it’s not surprising that it has 7 times the search volume as another high traffic keyword phrase “internet marketing”. The phrase “credit repair” is no laggard either, posting about half the search demand as “internet marketing”.

Couple that with CPA street payouts ranging from $20 to $50 per lead and you can see why consumer credit repair is a great niche to be in.

So where has it gone wrong in the eyes of the FTC?

The key issue the FTC seems to have with the way “free credit reports” are being marketed is how rebill offers and upsells are placed ahead of giving consumers their federally mandated free credit report which is available through a centralized website, AnnualCreditReport.com.

Navigating through an advertisers site embedded with upsells, uninformed consumers may feel they are required to sign up for the CPA advertiser’s premium and/or rebilling services in order to receive their credit reports. The FTC reports in paragraph 4 of the release that they’ve received “consumer complaints about promotions for products and services that confuse and frustrate consumers as they attempt to obtain their free annual credit reports.”

The fact is few people go to these sites to “just check” their credit report.  Most people seek their credit report when they are faced with a big decision: because they want/need / or where denied a home loan, personal loan, auto loan, student loan. When a consumer pulls their report they are probably anxious about an upcoming decision or perhaps they’ve been denied a loan and are now confused about why their scores are low. In this state they arrive on a site to get an onslaught of upsells and rebill offers only to feel mislead by the site afterwards which leads to complaints.

With the FTC stepping in to address these complaints, existing credit report affiliates might feel that the FTC’s proposed disclosures are draconian in nature. An example:

“for any Internet site offering free credit reports, the Commission proposes a requirement that, before the consumer may obtain a credit report from that Web site, such site must first display a separate landing page with the required disclosure: “This is not the free credit report provided for by Federal law.”

Giving consumers the message “you don’t have to enroll for any upsells and by the way, here’s a link to your free credit report” will obviously hurt conversions in a significant way. If these measures come into effect, advertisers who provide these credit-related services will have to step up their game and offer compelling information/content that will add to the free credit report, or risk their offer going up in flames.

Think the FTC’s proposed measures lack bite?

A day later (8th October 2009), the FTC issued a media release stating that two credit repair companies and their principals settled FTC charges that they falsely claimed they could repair consumer’s credits and collected upfront fees, in violation of federal law.

Although offering a free credit report is a far step from claiming to being able to repair a consumer’s credit score, the FTC is showing its online mettle when it turns a keen eye on what’s happening in the online space.

The FTC isn’t choosing to deal with internet marketers by slapping them gently on the wrist either. Imposing fines of $8.3 million and $2.5 million against the defendants, the credit repair businesses were suspended due to an inability to pay the fines.

Impact for affiliates and marketers?

Although an affiliate or merchant with a vested interest might think the government is actively seeking and destroying the lucrative livelihoods of online marketers, it’s a stretch to come to that conclusion.

In the scenarios highlighted above, consumer complaints were the catalyst that got the ball rolling, with the resulting legal consequences. This past July, the FTC solicited public feedback on proposed amendments to the Free Annual File Disclosures Rule, also known as the “Free Credit Report Rule.”

Furthermore, the Credit Card Act of 2009 requires the commission to issue a rule by Feb 22, 2010 to prevent deceptive marketing of “free” credit reports. If advertisers are under the impression that the legislative “perfect storm” has passed, there’s going to be more bad news for them, but good news for consumers down the road.

Some advertisers within the credit report/report space have chosen to build their business model around rebills and/or offering premium upsells to uninformed consumers. It might even sound like a great business proposition. The reality as has been shown in the FTC’s recent actions, will likely result in more shady operator’s “businesses” collapsing like a house of cards.

FTC Resources:
Credit and debt related issues

Read more:
The Credit Report/Repair Niche Feels The Long Arm of the FTC