On 4-20-07, EPIC, CDD, and US PIRG filed a complaint with the FTC, requesting that the Commission open an investigation into the proposed acquisition, specifically with regard to the ability of Google to record, analyze, track, and profile the activities of Internet users with data that is both personally identifiable and data that is not personally identifiable. EPIC further urged the FTC to require Google to publicly present a plan to comply with well-established government and industry privacy standards such as the OECD Privacy Guidelines. Pending the resolution of these and other issues, EPIC encouraged the FTC to halt the acquisition. The three groups filed a supplement to the complaint with the Commission in June. On 9-17-07, at the National Press Club, EPIC, the CDD, and US PIRG announced a second supplement to the groups' original complaint and subsequent supplement with the FTC concerning the proposed Google-DoubleClick merger. The amended complaint detailed new facts supporting the conclusion that the FTC should block Google's proposed acquisition of DoubleClick. The FTC has made a "second request" in its review of Google's merger with DoubleClick. According to FTC Chair’s statement on the merger review process, "the majority of investigations in which the FTC issued a second request resulted in a merger challenge, consent order, or modification to the transaction, suggesting that the FTC generally issues second requests only when there is a strong possibility that some aspect of the investigation would violate the antitrust laws."On 12-12-07, the FTC approved the proposed merger without conditions in a 4-1 opinion. EPIC responded, that the unique circumstances of the online advertising industry required the FTC to impose privacy safeguards as a condition of the Google- Doubleclick merger. EPIC said that the FTC "had reason to act and authority to act, and failed to do so."
This is the second supplemental materials filing in support of the complaint.
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