This open letter was first published as an Appendix in the Revised & Expanded version of my book: Ponderings of a PPC Professional.

After reading the DOJ closing statement slide deck last week, I wanted to publish this letter on the ZATO blog as a continued effort to push for greater transparency and ethical considerations in decisions within the Google Ads leadership team.
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Appendix A - An Open Letter to Google Ads Leadership

To my friends at Google,

It is worth beginning by noting that I do not represent the diverse PPC community as a whole, but this letter will hopefully demonstrate some representation of concerns shared by other members of the PPC Advertising community regarding ongoing practices within Google that I believe have overall caused more harm than good to users, advertisers, and Google itself.

That being said, I think it would be remiss not to acknowledge my appreciation for Google and this industry. While this letter cannot, and will not, speak to any legal or ethical matters in regard to any past, current, or future cases brought against Google, I think it fair to acknowledge that Google has grown inits popularity in large part due to its high quality products. The innovation, creativity, and practicality of Google products are enjoyed by millions (billions?) of people worldwide, including myself.

The author of this letter values Google and its contribution to the world, and it is from this standpoint that I seek to write this plea.

 My desire as a PPCer is for the good of my industry, since my livelihood and career depends on the success of Google. This letter is not intended to be an attack from an external force, but a plea for self-examination by someone within the industry for which I care so deeply.  

I also value the people who compose Google’s nearly 140,000 person payroll, and this letter is not intended to disparage any single individual and their contribution to our industry. It has largely been the author’s experience that Googlers are a people who care deeply about leaving a positive mark on the world and doing the best they can to help businesses through Google’s advertising products. I acknowledge this, and am thankful for these individuals, in particular Ginny Marvin (current Google Ads Liaison) who has made such a positive impact on Google-advertiser relations.

Decrease in Advertiser Trust

With this in mind, I would like to address the overriding purpose for this letter: to present a list of concerns to Google (as a singular entity) which I hope will highlight the trust I believe you have lost with the advertising community and will continue to lose without a change in direction and behavior.

While the advertising community is never short on complaints regarding platform behavior, I believe there looms a larger, more ominous threat to the industry that revolves around the relationship between advertisers and Google, specifically in regard to the trust Google continues to hinder. I believe this trust will continue to degrade without a change in behavior by Google and will eventually impact the overall health of the industry as future innovation undoubtedly offers alternative solutions.

It is this trust for which I hope to make a case, as well as offer suggestions within the remainder of this letter.

Stated Concerns

There are at least six primary trends that have arisen to harm advertiser trust with Google over the years.

1. Google’s place in the overall ecosystem as buyer/seller/auctioneer - While I acknowledge the complexity of the Google auction system, the amount of control Google exhibits decreases trust when paired with the lack of third party oversight into the inner workings of the auction environment.
   • Any industry would have concerned entities in a scenario where one party controls the tracking, auction, buying, selling, bidding, and then receives the proceeds from that entire process.
   • While this level of control does not itself constitute improper behavior, it certainly leaves the advertisers in a risk averse mindset, since the only option advertisers have in that scenario is to completely avoid the auction itself… a difficult decision to make when Google is one of the few primary available digital options online for advertising, and the most significant Paid Search option by a wide margin.
2. The continued product development moving towards Google-controlled automation - While I acknowledge the benefit of machine learning in the buying process and its remarkable capabilities, advertisers also recognize the reality that more automated campaign types within the Google Ads system means there are more opportunities for Google to make changes within the auction system that would be disadvantageous to the advertiser, and advantageous to Google, without any third party knowledge.
3. The decrease in reported data - While I acknowledge that some level of privacy and security is necessary in proprietary auction mechanics to prevent bad actors in the advertising world from taking advantage of the transparency to game the auction system, advertisers also experience frustration by the continued decrease in reported data back to the advertisers.
   • For example, the detailed search term reports (including helpful KPIs such as Cost data) which have disappeared from Smart Shopping and then Performance Max campaigns completely, have begun to be limited in Search campaigns. The only way advertisers can know the auctions in which to invest more aggressively (or use that information to benefit other marketing efforts such as SEO or LandingPage optimization) is if we see which auctions performed. It is challenging for advertisers to request additional budget from key decision makers if 25% or more of the search terms are hidden.
   • One thing is clear: automated campaigns that allow Google to control almost everything within the account and then report back on very little in terms of what is happening in those auctions erodes rather than supports trust. Rolling these automations changes back, or simply slowing them down, would likely strengthen advertiser trust.
4. Lack of consistency between public and private admissions of what occurs in the auctions - While I acknowledge there are hidden mechanisms to the auction that advertisers do not (and likely cannot fully) understand, advertisers also experience a significant hit to trust when hearing contradictory statements presented by Google representatives in the way their auctions work.
   • As one recent poignant example of this point, the VP/GM of Ads at Google, Jerry Dischler, responded to questions in 2015 at the SMX Conference[1]and he denied that Google was making any changes to the auctions for revenue building purposes. Then in 2023 during his testimony in front of the federal committee, Dischler himself went into detail regarding the specific mechanisms[2] Google has employed to purposefully build additional revenue into the auctions at key times in order to hit Wall Street projections. These "tuning" mechanisms include RGSP, reserve price floor surges, and Squashing.
   • The point of this letter is not to determine whether Google has broken any legal or moral obligations; it is simply to plead with Google that this behavior of contradictory public claims (as well as public claims misaligned with private practice) harms advertiser trust.
5. The impact on product quality on users when revenue goals become more important than innovation and quality - While I acknowledge that every business has the right to pursue its revenue creation goals in a healthy manner, advertisers recognize the concern that this pursuit not harm product quality.
   • In an email conversation shared during a recent DOJ hearing[3], it was revealed that the Ads (PPC) side of Google was pushing for the Organic (SEO) side of Google to make key changes to a roll-out that had already occurred, simply to increase Google revenues. To his credit, Anil Sabharwal (Product VP and GM at Google) pushed back on this request by the Ads department, and I do not know the outcome of this conversation.
   • However, surely I can agree that it harms advertiser trust to become aware of a request to roll back a product launch that had already gone through Google’s rigorous standards tests for a high quality user experience, all in order to push for more revenue.
   • This is a clear instance of at least one Google executive accepting the cost of a user product quality decrease for his primary goal of pursuing revenue. I would be naive to think this was the only case, and this process revelation causes concerns by advertisers as to whether Google product quality has been reduced over the past few years for the sake of hitting revenue projections.
6. The lack of true support from the Brand/Agency Partners program - I acknowledge that Google has no requirement to offer advertising support as the primary relationship between advertisers and Google.
   • In an open letter discussing trust, I would be remiss in not offering the suggestion that a Google Partner program that appears to be about support, but is in actuality a sales program, erodes rather than supports trust.
   • There is a heavy awareness within the advertiser community that Google representatives will be tempted to pursue their own financial objectives (Google Rep commissions based off of things like feature adoption) rather than primarily the advertiser’s best interests.
   • Admittedly, there are many good people within the Google Partner support program, but I suggest the entire system is geared towards supporting those who are better at sales than support. This is represented in the many contradictory facts received by various advertisers through different reps and shared online. It would build trust for advertisers to actually get the help they need and desire, rather than for Google to see this as primarily a new revenue opportunity.

Proposed Solutions

With these in mind, I wanted to propose suggested resolutions to help rebuild advertiser trust.

I want to first admit that I do not think the solution here is to require all proprietary algorithms to be fully transparent, as I understand the desire to prevent bad actors on the advertiser side to game this system in a way that would harm others.

I also understand that I have limitations to my understanding of how to resolve these concerns, having no knowledge of the internal product intricacies and future roadmap.

Therefore, I will outline a few suggestions, but leave this ultimately as an open-ended question to Google.

• Since there is a default from advertisers of lack of trust based on the behavioral points outlined above, what will Google do to demonstrate trustworthiness to your advertisers?
• How can brands be assured their billions of dollars will be handled in an ethical way that pursues positive and fair conditions for all (including Google) in the marketplace of the Google auctions?
• What can you do to rebuild trust with advertisers?

These are the sort of questions I do not think I as an advertiser can answer, but I would urge you to begin asking more directly within every meeting and get-together within Google.

Initial suggestions for strengthening trust with the PPC advertising community:

1. Increase transparency in auction mechanics and cease activity that unbiased entities would consider illegal or unethical. For instance, if you would like to build in a 5-15% price floor threshold to increase Google revenues in a down quarter, don’t state that you are not engaging in this behavior. Rather, please be upfront with advertisers on these CPC changes. I understand that the cost of getting access to the amazing innovations that Google puts out is Ad Revenue. At the very least, understanding when to anticipate Platform-created shifts in average CPCs will help advertisers budget more successfully.
2. Pursue product quality for Google search user experience over revenues. I believe the primary benefit to Google has always been that it is an excellent product for its end users. I would suggest refocusing on product quality over pursuing revenue growth.
3. Increase reported data to advertisers and allow for more advertiser’s control in automated campaigns… even if that at times means the advertiser account may not perform as well as Google engineers believe it can. For the reasons stated above, I believe this is a necessary step for advertiser user trust to be strengthened due to the level of control Google maintains in every part of the auction, especially as I have found that advertising and marketing are equal parts art and science. Automation can at times lean too heavily into the science aspect, believing all things can be determined by an algorithm with an expectable output… which is not always the case.
4. Transition the current Google Partner Rep program into a support system. I would strongly suggest pursuing a support-first approach to advertiser communication to help strengthen trust. You may be surprised how you are able to accomplish your revenue goals with this model as advertisers learn to trust their rep suggestions, become further educated in the skill of PPC advertising, increase advertising success in the accounts, and spend more with Google.  This is a scenario in which everyone will win.

I hope you will consider these things. It is with hope and enthusiasm I look to the future. I am optimistic that advertiser trust can be rebuilt with the right changes since I believe in the value of Google’s products and its contribution to the business world.  

I believe that, with the right changes to increase advertiser trust, the PPC industry and community can continue to grow in success and strength for decades to come.

Thank you for your time,

Kirk Williams

ZATO PPC Marketing

December 2023

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[1] Andy Taylor. @PronouncedAhndy. “Jerry Dischler in 2015: ‘Full stop, we’re not manipulating search results or manipulating the ad auction to increase profit. That’s just not what we do.’ (check the video link: https://www.youtube.com/watch?v=0m6KINWDEqs)Jerry Dischler in 2023: 'we tend not to tell advertisers about pricing changes'.” Twitter, 21 September 2023, https://twitter.com/PronouncedAhndy/status/1704861673155080362?s=20

[2] Nicola Agius, “Google denies manipulating ad auctions in resurfaced SMX Advanced clip,” article, 2023, Search Engine Land, accessed2 February, 2024, https://searchengineland.com/google-denies-manipulating-ad-auctions-in-resurfaced-smx-advanced-clip-432345.

[3] Trial Exhibit. “UPX0522: U.S. and Plaintiff States v. Google LLC.” Justice.gov, 2023, accessed 2 February 2024. https://www.justice.gov/d9/2023-09/416646.pdf?fbclid=IwAR1CTqklvMuFZg11V0Qt01pg2w_bXM3P20wUlhqxNKB3mTUSKs9alKqfuzg.

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