Policy Post 12.15: Fight Against Spyware Progressing, but Challenges Remain



(1) Fight Against Spyware Progressing, but Challenges Remain 
(2) Advertisers Knowingly Support Nuisance Adware 
(3) State and Local Law Enforcers Make Major Strides 
(4) Spyware Incidents Decline, but Problem Remains Epidemic
_______________________________________________ 

(1) Fight Against Spyware Progressing, but Challenges Remain 

For those engaged in the ongoing fight against spyware and nuisance
adware, the last few months have brought some promising signs, as
well as a few clear indications that much work remains to be done. 

Consumer Reports' annual State of the Net study noted a decline in
the incidence of spyware but also noted that that the problem remains
at "epidemic" levels in the United States. The Consumer Reports
findings suggest some of the same conclusions that anti- spyware
advocates drew from the most recent America Online/National Cyber
Security Alliance Online Safety Study -- namely that while spyware
mitigation efforts are having the desired effect, the rate of
infection remains far too high. 

On the positive side, it is clear that the combination of political,
legal and most importantly, technological tools being employed to
help users take back control of their computers are making an impact.
A recent CDT study found that state and federal authorities are using
a broad range of laws -- some new and some 
old -- to go after the most egregious spyware offenders. Their
aggressive efforts have paid dividends. On the technological front,
anti-spyware vendors continue to work individually and
collaboratively to strengthen the technological defenses against
spyware. As more users take advantage of the broad range of powerful 
and improving anti-spyware programs on the market, the incidence of
spyware infection will continue to fall. 

On the negative side, spyware continues to cost American companies
and Internet users .6 billion each year, causing nearly a million
users to throw away their computers in frustration, according to the 
Consumer Reports study. One of the lead factors in that exorbitant
cost is that despite education and enforcement efforts, distributing
nuisance adware and spyware continues to be a very profitable 
business model for online scammers. Two recent CDT studies found that
a major driver for that profitability came in the form of legitimate,
well-known national companies knowingly and unknowingly buying ads 
from adware companies known to have engaged in unfair and deceptive
practices. 

CDT's "Following the Money" series tracks the origin of ads served by
unscrupulous adware distributors in an effort to educate legitimate
advertisers about where their ad dollars are going. In attempting to
work with unethical adware distributors CDT has learned that as long
as they have a financial incentive to prey 
on consumers with deceptive practices, they will continue to use
their well-worn scams to the detriment of the larger Internet
community. 

All told, the mix of encouraging signs and continued challenges
should inspire those in the anti-spyware community to redouble their
efforts to crack down on this online scourge and further empower
Internet users to protect their computers and identities. 

_______________________________________________ 

(2) Advertisers Knowingly Support Nuisance Adware 

In March, CDT released the first of its "Following the Money"
studies, which detailed the complex path that advertising dollars can
take from legitimate companies into the coffers of unscrupulous
adware distributors. The study identified major national brands that
were knowingly or unknowingly advertising through an adware
distributor accused by consumer advocates of engaging in unfair and
deceptive trade practices. The aim of Following the Money I was to
send a message to advertisers that they needed to be more careful
about policing their advertising spending, in order to avoid having
their brands tarnished by association with unwanted adware products. 

Earlier this month, CDT released Following the Money II, which
thought to further untangle the complex web of intermediaries that
operate between legitimate advertisers and nuisance adware
distributors. 

The study arrived at some surprising findings. Although ads placed by
the largest, most visible national companies tended to travel through
multiple intermediaries before being displayed by nuisance adware, 55
percent of nuisance adware ads were placed directly by the companies
being advertised. Another 5 percent of the ads on nuisance adware
were placed by intermediaries that had no say in where the ads were
placed, meaning that fully 60 percent of the ads displayed by the
nuisance adware distributors targeted in the study were placed
knowingly by the companies being advertised. 

In light of the extensive media attention and public education
efforts that have been devoted to the spyware problem, it is
surprising that so many companies are willing to do business with
companies engaged in clearly unethical, and in some cases illegal
behavior.

The findings in Following the Money II were based on a sample of 380
ads served by Zango and Direct Revenue -- both of which have been
shown to engage in deceptive distribution practices. CDT researchers
identified the source of the ads and traced the path they took from
the advertisers to the nuisance adware providers. 

Following the Money II urges companies to get serious about
establishing and enforcing policies to prevent their ads from
appearing through nuisance distributors, and to be more careful about
choosing affiliate partners. 

Following the Money II http://www.cdt.org/privacy/20060809adware.pdf 

Following the Money I http://www.cdt.org/privacy/20060320adware.pdf 

_______________________________________________ 

(3) State and Local Law Enforcers Make Major Strides 

Earlier this summer, CDT undertook a survey of how state and federal
law enforcers were using available laws to crack down on spyware and
nuisance adware distributors. The results of that survey were
encouraging. 

In March 2004, CDT President Jerry Berman testified about spyware
before the Senate Commerce Committee, highlighting the fact that
several existing federal laws -- Section 5 of the Federal Trade 
Commission Act, the Electronic Communications Privacy Act (ECPA), and
the Computer Fraud and Abuse Act (CFAA) -- could be used to target
the tactics of malicious spyware distributors. He urged the Congress
to provide law enforcement officials with the necessary resources to
use these laws in prosecuting spyware offenses. He also noted that
many states had long-standing fraud statutes that could be brought to
bear on spyware distributors, and that neither the federal nor the
state laws had yet been used to take action in the spyware space. 

CDT's survey found that since then, law enforcement officials have
increasingly applied statutes -- some long-standing, some relatively
new -- to spyware cases. Leading the charge has been the FTC, which
to date has brought six cases under its unfair and deceptive
practices authority. The Department of Justice 
has actively pursued spyware purveyors under the CFAA and the Wiretap
Act, with 11 cases to date. And three attorneys general at the state
level have filed spyware lawsuits under state fraud and consumer
protection laws, with two more cases initiated under new state
spyware statutes. 

The states are in a unique position to make a great impact in the
broader spyware fight. With a relatively small investment in consumer
outreach and technical training, states can contribute towards
broadening and diversifying the pool of law enforcement officials who
are actively combating the spyware problem. 

In the survey, CDT urges more states to join the effort by:
establishing consumer complaint Web sites where computer users can
submit complaints about suspected spyware; developing forensic
capabilities so that consumer protection enforcement agencies can
investigate spyware complaints; and training investigators and
prosecutors in identifying the attributes of spyware that violate
existing laws. 

In a related development, the FTC publicly indicated that it will
soon be announcing a new round of spyware cases and settlements. 

CDT Spyware Enforcement Report 
http://www.cdt.org/privacy/spyware/20060626spyware-enforcement.php 

_______________________________________________ 

(4) Spyware Incidents Decline, but Problem Remains Epidemic 

Earlier this month, Consumer Reports issued its annual State of the
Net report, which details how threats like spam, viruses and spyware
are affecting consumers and estimates the monetary damage caused by
those threats. 

The results for spyware were a bit of a mixed bag. The incidence of
spyware declined from 2005 -- likely a result of a range of
anti-spyware efforts and increased use of anti-spyware technology --
but the rate of infestation remained disturbingly high. One in eight
people had "major, often costly" problem with spyware, 
according to the report, which estimated the average consumer cost of
a spyware incident to be . Nearly a million people discarded their
computers because of spyware incidents, according to the study.
Overall the report estimated the monetary damage caused by spyware
nationally to be .6 billion per year. 

The decline is promising, but those numbers are obviously far too
high. Continued effort to undercut the financial support for spyware
and nuisance adware, strengthen the legislative framework, educate 
users, penalize the bad actors and improve the tools consumers can
use to protect themselves, are necessary to protect the online public
from this global problem. 

State of the Net Summary
http://www.consumerreports.org/cro/electronics-computers/online-protection-9-06/state-of-the-net/0609_online-prot_state.htm


_______________________________________________ 

Detailed information about online civil liberties issues may be found
at http://www.cdt.org/. 

This document may be redistributed freely in full or linked to
http://www.cdt.org/publications/policyposts/2006/15 

Excerpts may be re-posted with prior permission of dmcguire@cdt.org 

Policy Post 12.15 Copyright 2006 Center for Democracy and Technology 
-- 
To subscribe to CDT's Activist Network, sign up at:
http://www.cdt.org/join/ 

-- 
Michael Clark, Grassroots Webmaster 
PGP Key available on keyservers 

Center for Democracy and Technology 
1634 Eye Street NW, Suite 1100 
Washington, DC 20006 
http://www.cdt.org/ 
voice: 202-637-9800 
fax: 202-637-0968 





================== HURIDOCS-Tech listserv ===================== 
Send mail intended for the list to <       >. 
Archives of the list can be found at: 
http://www.hrea.org/lists/huridocs-tech/markup/maillist.php


[Reply to this message] [Start a new topic] [Date Index] [Thread Index] [Author Index] [Subject Index] [List Home Page] [HREA Home Page]