On February 12, 2009, the Federal Trade Commission Staff issued a report entitled “FTC Staff: Principles for Self-Regulation of Online Behavioral Advertising,” approved for release by a unanimous Commission vote. The report details the findings of the FTC Staff’s continued review of online behavioral advertising practices and revises its proposed principles for the self-regulation of such practices.

The report and the Revised Principles themselves are crucial for any online advertiser and any operator of a website that accepts online advertising, and could foreshadow enforcement actions, possible legislative action, and further investigation of the industry by the Commission, perhaps in the form of compulsory process, all in the near term. Needless to say, 2009 will be an important year for online advertisers and their service providers. This Client Advisory includes a detailed review of the Staff Report and Revised Principles.