Rockstar Consortium US LP et al v. Google Inc

Filing 92

MOTION for Leave to File A Supplemental Brief In Response To Googles Motion To Transfer In Light Of Newly-Acquired Evidence by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Text of Proposed Order Granting Motion for Leave to File a Supplemental Brief In Response to Google's Motion to Transfer in Light of Newly-Acquired Evidence, # 2 Supplement Plaintiffs' Supplemental Brief In Response to Google's Motion to Transfer, # 3 Affidavit of Amanda Bonn In Support of Plaintiffs' Supplemental Brief In Response to Google's Motion to Transfer, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit 3, # 7 Exhibit 4, # 8 Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12 Exhibit 9, # 13 Exhibit 10, # 14 Exhibit 11, # 15 Exhibit 12, # 16 Exhibit 13, # 17 Exhibit 14, # 18 Exhibit 15, # 19 Exhibit 16, # 20 Exhibit 17, # 21 Exhibit 18, # 22 Exhibit 19, # 23 Exhibit 20, # 24 Exhibit 21, # 25 Exhibit 22, # 26 Exhibit 23, # 27 Exhibit 24, # 28 Exhibit 25, # 29 Exhibit 26, # 30 Exhibit 27, # 31 Exhibit 28, # 32 Exhibit 29, # 33 Exhibit 30)(Bonn, Amanda)

Exhibit 17

A Framework for Targeting Banner Advertising On the Internet
Katherine Gallagher and Jeffrey Parsons
Faculty of Business Administration, Memorial University of Newfoundland
St. John’s, NF, Canada A1B 3X5
{ kgallagh, jeffreyp } @ morgan.ucs.mun.ca
Abstract
Constraints that limit accurate targeting of advertising in
traditional media may not hold in cyberspace. This paper
presents a model for effectively and efficiently targeting
hypermedia-based banner advertisements in an online
information service. The model takes advantage of
information technology to micro-target banner
advertisements based on individual characteristics of users.
A simple version of the model, which has the virtue of ease
of development, is presented. Enhancements are also
proposed. These require more effort to develop, but may
lead to even more precise targeting of advertisements.
Implementation of this framework may benefit both online
advertisers and online consumers.

1. Introduction
Cyberspace is a rapidly growing new medium for
commerce. To date, a great deal of indusu3, attention has
focused on electronic transactions over the Interact.
Although rapid growth is predicted over the next few years
[10,17, 21], actual sales thus far have been only moderate:
users appear to regard the Intemet primarily as a source of
product information--when it comes time to pay, they prefer
to buy offline by more conventional means [12, 14].
Responding to consumers’ desire for information,
businesses in large numbers have developed sites on the
World Wide Web (WWW or Web). Most commercial Web
sites describe the firm and its products and/or services, and
many offer opportunities for visitors to the Web site to
provide feedback and ask for specific information. As well,
some Web sites collect information from visitors in order to
improve future offerings. Some sites also support ordering
and payment. The interactive potential of Web sites is
particularly exciting, as it facilitates relationship marketing
and customer support, eliminating the obstacles of
geography and time [14, 22]. Not surprisingly, then,
industry and scholarly research has recently focused on
making Web sites more appealing and useful to visitors [ 13].
However, a Web site can only be effective if current and
prospective customers visit it. Attracting this audience is
currently a major challenge.
1060-3425/97 $10.00 © 1997 IEEE

In this paper, we address the challenge of attracting a
defined target audience to a Web site via banner advertising.
We propose a framework for effectively targeting banner
advertising in an electronic marketplace in a manner that
benefits both advertisers and consumers. It allows
advertisers to reach consumers who are more likely to be
interested in the products and/or services offered by the
company, and exposes consumers to information about
products and services that they are likely to be interested in
purchasing. Although the fi:amework is discussed in terms
of the Intemet, we believe it will be relevant to whatever
form the "information superhighway" eventually assumes.
The framework takes advantage of the capabilities afforded
by information technology for collecting and processing data

about users. The next section examines trends in the
electronic marketplace. Subsequently, the current state of
advertising in this medium is discussed. Thereafter, a
framework for targeting banner advertising, supported by
appropriate information technologies, is proposed. Finally,
opportunities for further research are discussed.

2. Marketing and Advertising in an Evolving
Electronic Marketplace
The Interact began in the early 1970s as a US
government research project designed primarily for the
needs of the military. It expanded in the 1980s to serve the
international academic and research communities [19, 23].
In the 1990s, businesses began to appear on the Intemet.
Although accurate estimates are obsolete as soon as they are
made, it is clear that today tens of millions of people have
access to the Interact [16] through over 100,000 computer
networks in 150 countries--and the numbers continue to
increase [14]. Two types of developments are particularly
noteworthy with regard to this growth.
First, a large and ever expanding number of affluent,
educated consumers are using the Interact [11]. This
concentration of very desirable consumers has led to a surge
in commercial interest. Prior to 1990, nodes on the Interact
were predominantly academic institutions. In 1990, about
1,000 businesses had Interact connections. By June 1995,
over 21,000 businesses were online, and the growth in
commercial connectivity shows no sign of slowing [8].
Second, the emergence of the hypermedia-based WWW,
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