Abstract
This paper contains our personal observations on the CMA’s Interim Report on its Market Study on Online platforms and digital advertising (the “Interim Report”). As a starting point, we are very impressed by the quality of the Interim Report as it correctly identifies the competition issues raised by digital advertising and accurately discusses the complex mechanisms involved in digital advertising including real-time bidding (“RTB”). The CMA’s analysis is very much in line with our own research work on online display advertising, which is the area on which our comments will focus. Our observations are structured as follows. Part II contains some general observations on the Interim Report’s analysis of open display advertising. Part III discusses certain aspects of Google’s recent switch to a single unified first-price auction (the “Unified Auction”), which in our view warrant further investigation. Part IV provides our preliminary thoughts on Chrome phasing out third-party cookies. Part V concludes.
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