Digital Envoy Inc., v. Google Inc.,

Filing 295

Attachment 4
Declaration of Robert J. Waddell in Support of 294 Memorandum in Opposition, filed byDigital Envoy,Inc.,. (Attachments: # 1 Exhibit A# 2 Errata B# 3 Exhibit C# 4 Errata D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K# 12 Exhibit L# 13 Exhibit M# 14 Exhibit N)(Related document(s)294) (Blackman, Brian) (Filed on 9/1/2005)

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Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 1 of 6 EXHIBIT D i GC a I P * S IL G 7 Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 2 of 6 Local Search Part 3 : Google Gets Local With AdWords httpJ/3carchenginewatch .com/se=hday/"cle.php309959 1 Members Area With Excl usive Content Already a member? earn about the benents : we Dep' xrrfo Horne Starks From sEw SEW Bbg Latest Now From SENT & Beyond s& Local Search Part 3 P oogle Gets Local W Ad Words By Danny Sullivan. Editor October 28, 2003 sonvens"s a save. h such "we Watch's confe rence on march engine marketing comes to e · Amust 8 -11, 2005 Son lose . CA · OctDber 19 - 20.2005 storlchdm. Srredcn · December 5 - 8. 2005 Chle op, rL · Feixvm 27 - March 2, 2006 new York. NY · Match 30 - 31.2006 Munich. Gerrnanv · ad 255 - 26. 2006 ToroM, Canada Tokyo,3aoan SEW Forums Sea~arrht Search Engine Submission Tips Web Seardung Tips Search Engine Listings Search Ratings & Stats Search Engine Cone D/sruss Resources SeardhDay Our Daily N"Wetter- A longer version of this arti cle future regional targeting relinem with national ad competltlonr v or country-targeted ads from regions and other top available to Search Engine W e lick hare to learn mom a member 2. 2006 London England Engine Watch Marketplace Seandh Engine Report n my earlier parts of this series on local search, I covered Overture's new loca l AN Newsletters & Feeds aid listings and crawlerbase d methods from Google and Mobilemaps a s SEW Members A rea ttempts to lmprove local searching on Exduslve Content general pu rp ose search Our Monthly Newsletter an Yahool and more eo-target Your n uE0 yam ion with Mamnma .com ntwwn earch Enalne a area Search fnatne .Ranklng About The Site >> Search if Members Area G: Free Area Today, I had planned to examine new local search moves by CitySearch, as well as the great content available fro m online yellow pages. However, I'll Instead be stepping back into the world of Google, because of a new paid local product it launched on Friday . I did a short _ rite-up of the new w product in last Friday's SearchDay. Now I've had a chance to talk with Googie more about the program and have added some additional details, especially for those of you reading the version of this story for Search Engine n Watch members . I'll be moving forward with CitySearch and yellow pages next week, with the series now set to continue into a fourth part on November 6 and perhaps even a fifth part to follow the week after. Inte rn etcommerce Cheap Auto Insure PDA Reviews Laywo Reviews Search Web Hostina Auto Insurance Phone Sv4tems Data RoW ery Compare Prices Cell Phone Plans Information online bookina Hotels Desktop Computers Sea Engine Ranki n MarketPlace u Google's New Reglonal Targeting Google has tong allowed ads to b e eted on a country-specific basis . For i of 5 /6!'200512:16 PM o p t d O o> Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 3 of 6 1Y -CWIn on you r with G00e1e AdS"M example, it's easy to make your ads only be seen by those In the United Khgdom, If you want to target the audience there . Now Google has rolled out regional ttr a trng to the local level within the United States. For instance, a n ser could dose to have th eir ad "dentists" appear only In front of time searching from within the San Francisco Bay Area (San Francisco-Oakland- San Jose). Outside this region, the ad would not be seen. The change will be a real relief to some advertisers. Imagine the dentist base d In Daly City, Just south of San Francisco. They may wish to target those seekin g entists In surrounding areas. Before h is system, the only choic e was to ensure they keyword-targeted the names of nearby cities along with the word "dentists,* such as: bearm Mine ondmizatio n ~ ptintzation · san francisco dentists · oaktand dentists · daly ci ty dentists · padflca dentist s · san bruno dentists Ith the change, they can simply target the word "dentists" and restrict to the San Francisco region . Then they'll come up for any search involving the word "dentists"; by someone in the San Francisco area (assuming they don't modify from the default broad match option) . Not Solution For Everyone Regional targeting won't eliminate the need to do keyword-based local targeting for some advertisers. Google offers up the example of real estate agents who sell in one area but want to reach those in another . "You can Imagine In real estate an agent whose base Is local but they also want to attract people from outside the areas said Salar Kamangar, director o f product management at Google . 'o reach those, they need to buy the regular geographic keywords as they did before.* In other words, picture someone se t homes In the San Francisco Bay Area . By using the new regional targeting feature, it's now easy to make their ads show up for anyone In the Bay A rea sea rching for a phrase containing "new > Search Engine Newsletters iFREEI ver 150,000 nw&m depoW on our free newsletters to keep up with search anyines. To join them entersr smog below: __ . .: ~ Learn mom about the r&osletter s l,1, "Wrof t arEldeits~der ' filled With 91MOM nline Search Industry Reaaarch Get deep analysis and actionable advice f oM expert analysts 2 of5 n 9 Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 4 of 6 Local Search Part 3 : Google Gets Local With AdWords http:t/smvbea &swatch.wmtsmchday/article.php/3099591 homes ." However, a person in Dallas thinking of moving to the area would ever see these ads, if th ey did a local search such as : · san frandsco new homes · new homes in oakiand · prices of new homes In san bruno The Pr*ndw Peednation for Creative Profe"kMals Featurft S&M1tQdL Ems, aioart.can. P~14ii 4jects net, and Asps .can· Instead, the Bay Area real estate agent will still need to target all the regionally-specMlc terms, as well . Dealing With Targeting Inaccuracies Google's system works by identifying the IP address of a user, a system It has long! employed to allow advertisers to target ads to specific countries. The US targeting matches the 210 'designated market a reas' that a re used to define television markets. IP matching usually works, but it Is not perfect . I live in the United Kingdom, for j example. Occasionally In the past, GoogWs IP detection has gone haywi re and forced me to its Google Germany site because my ISP has assigned me an IP associated with a German physical address . And currently, Googie shows me ads targeted to those in the US . I connect through AOL, so it th inks I'm in the us. Googie's solution is th at if It can't identify a person's location, It will serve u p "national" or non-regionally targeted ads instead . Unfortunately, among the group It currently can't Identify are any of the millions of AOL subscribers, Google said . There's also a chance that someone's location will be misidentified, Google admits .) However, it says this is usually a case where they are shown ads for a nearby geographic area, rather than some place well removed from their location . "In those cases, often we aren't mapping them to a region like opposite coasts but, the next region over,' Kamangar said . Determining a person's geographical location is also an issue for where Google shows ads outside Its own network of web sites. For Instance, AOL and others have their own search engines that Incorporate Google's paid listings . Only at some of these will regional targeting work . At others, it will be disabled because the Go ogle, partner doesn't pass along enough information to make regional targeting accurate, Google said . AOl Sea rch is an example of one of Gaggle's syndication partners where regional targeting Is not being used, but th e company hopes this will change over time. i 'We want all th e synd ic ation partners to work with this, and generally they are very excited to do k* Kamangar said . How about local targeting outside the United States? At th e moment, Google says that IP targeting Isn't good enough for th is, but it may come If the data quality improves. Search By Location To Get Ada? As previously written, Google has a map-based local sea rch product, where results are gathered from crawling the web. Will the new regional ads be integrated Into that product, which lists web sites for free? Not Immediately because of low volume, Google says . If the Google Search By Location product were to gain traffic or emerge from beta as a tabbed service, similar to the existing Web, Images, Groups, Directory and Mewps search services, then th e issue of b ringing in ads would become more likely. The challenge Is that there's no way Googl e 's new regional targeting will allow ads t o 3 of 5 161200512 :16 PM 7 Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 5 of 6 09959 1 Local Search Part 3 : Google Gets Local With AdWords be placed on the map that Search By Loca tion creates as a centerpiece, in the way that Overture's local search product allows . This Is because Google's regionally targeted ads don't Include physical "bricks & mortar" locations. However, the regionally targeted ads could run alongside the map . 'What we'd likely do Is the same thing with a normal sea rch results page,' Kamanger said, alluding to how on a regular Google web se arch, paid listings appear above and to the side of results found f rom crawling the web. In par ticular, Google might look at the city used In a local search's address lox, such as "san frandsco," and add that tG the se arc h term used, such as "dentist," to bring back ads that target all of those words . Ironically, this means It wouldn't use the new regional targeting but rather traditional keyword targeting . Still In Betts Google stressed that its regional targeting Is still In beta . Th e program was already beta tested by about 14 advertisers over the past two months, but last F riday's release is still keeping the beta moniker because the flnai product is likely to change now that thousands of advertisers will be trying it tar the first time. 'We expect things to change, and that's why we a re tailing It beta still," Kamangar said . Corning Up Next In my next part of this se ries on local search, I'll return as planned to a close-up look at the editorial and paid products offered by Citysearch . i'8 also be recapping the excellent online yel low pages resources that are available . Many major search engines offer good, yellow page style listings already, but users may be unaware of these . I'll guide you to these options plus highlight how the search engine s themselves are I oking to make local search magically happen when It should, without the user doing anything special . A longer version of this article speculating on futLwt regional targeting refMenonts, is+pres with national ad competition, viewing regiona l or country-targeted ads from outside target r egkms and other topics Is available to Search Engine Watch members . Click hag ism mom about becoming a member Search Headlines NOTE : Article links often change . In case of a bad link, use the publication's search ; facility, which most have, and search for the headline . ValueCll ck Into or-aft . . 003 12 :57PM GM T Yahoot limns Dr Munk aftu Forbes Oct 2a 200312 :34PM GMT How to G- 099le Hack. . . WebTaiWA" Radio Oct 2a 2003 W24AM GMT Gooole Studies Creation of Book Database New York Times Oct 28 2003 6:55AN GMT AOV* Happy Secret . . . New York Times Oct 28 2003 6:54AM GMT 4 of 5 /61200512:16 PM i i s P M Case 5:04-cv-01497-RS Document 295-5 Filed 09/01/2005 Page 6 of 6 91 Motor Industtv portal draw onlin e coWaaues . . . ComPubsr Wooldy Oct 28 2003 2:07AM GMT Boggle MrAtm wkh b ibWa. . . r4lWy.com Oct 28 2003 1 :51M GMT ale Sulrw Swlnks, Ckhdw ContwMml Ad Market. . . Me& Post Oct 27 200311 :16PH GM T Ask aeeves shatys fall after Barron' reowt. . . Raat+srs Oct 27 2003 6:3bPM GMT Goooler the "Ienaea of the arooo"d IPO . . . IT-Anatysis .r:orn Oct 27 2003 3 :29PM GMT VAth caMe at Wt. who needs Napa e CNET Oct 27 2003 1:50PM GMT Yahoo Hole rme LbUOa Rev Promotion for 99-Cent moons, Aucdonbybw .com Oct 27 2003 12 :43PM GMT Tors 10: 'Portal' *]to& . . ftdmperstiw Oct 27 200312 :33PM GMT SearchDay v ob so* 1aa wamw* is a PMrs W wrbrr or pibabx~ r a "r,ch ]upitrrwW : _. . _ b JuaiberWeb. ,upte , has four divisions: rid 3uprberimem Copyright 2005 3uPiWwm to Corporation /UI RWft Rmervod . fivacy PORCY. 1m al Nsbm Ucaftno gam, a 3upite a_ Spmorate Info ! NewskIters I Tech ~stl~ I E-rmH otters 5 of 5 7/612005 12 :16 PM

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