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62 Federal Communications Law Journal 465 (2010)


In a remarkably short time, Google, Inc. has grown from two people working in a rented garage to a pervasive Internet force. Much of Google's unprecedented success stems from online advertising sales which employ behavioral advertising techniques-techniques that track consumer behavior--thereby increasing relevance and decreasing the cost of reaching a targeted audience. In the same span that saw Google's inception and explosive online dominance, the Federal Trade Commission has struggled to define not only the privacy issues involved in online behavioral advertising, but also the practice of behavioral advertising itself. Freed from the restraints of comprehensive federal laws and restrictive federal regulations, Google and its ilk have taken innovative liberties with the collection and use of consumer information. While the Federal Trade Commission ponders the subtleties of online behavioral advertising, mountains of data about consumers are being gathered and manipulated like never before, scarcely subject to legislative or regulatory privacy protections. This Note details the meteoric rise of Google before a backdrop of permissive selfregulation and argues for the establishment of baseline consumer privacy protections for online behavioral advertising.