TURTLEDOVE (“Two Uncorrelated Requests, Then Locally-Executed Decision On Victory”) proposal attempts to enable consumer retargeting without any marketers receiving any identifier.
Google has suggested measuring the effectiveness of TURTLEDOVE proposal under the Fledge project.
TURTLEDOVE removes transparency and control from publishers, by requiring the final auction in a given ad slot to be conducted by Google. In addition to removing price transparency and introducing a time-delay to publishers in how well their websites are performing, TURTLEDOVE also impacts publishers ability to appropriately understanding and managing:
Traffic quality (TQ) - is this a legitimate request from a real user or non-human traffic?
DSP qualification - which DSPs are interested in this request?
Bid solicitation - which DSPs will place a bid on this request?
Ad Quality (AQ) - which bids are eligible given the publisher's requirements?
Valuation - which bid is most valuable to the publisher at this moment?
Another potential impact of removing this information is a degraded end user experience.
Because TURTLEDOVE mandates the browser determines the final auction and relies on Fenced Frames, publishers cannot compare in real-time the monetization of the ad slot by Google vs competing ads sourced via other mechanisms. For example, if a publisher has other demand sources, such as an internal sales team, these will need to forward their highest desirable ad to Google for it to compare against the winning ad among the context-only ad and the audience-only ad it processes within the auction.
The UK CMA noted (5.42, 5.74-75) TURTLEDOVE would give disadvantage Google's rivals for the following reasons:
- Google would have "full and unique visibility of the interest groups to which users belong"
- "Google would determine the minimum size of these interest groups and, in so doing, rival publishers and ad tech providers would not be able to compete to offer their unique value proposition to advertisers"
- Google "could have access to more granular user interest data and therefore have a competitive advantage over rivals in the provision of retargeting services to advertisers."
- Share confidential information with Google's consumer browser software, could create a conflict of interest given Google's DSP would "have visibility of its competitors' bidding strategies"
Note: Google has made no commitment that it will rely only on TURTLEDOVE to monetize its own web properties.
- What is the impact on web experiences given many client devices do not have the same processing power of the servers that currently select which content to render?
- How does the local client auction support publisher custom logic, such as factors other than price to select which ad to render?