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Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 1
Visitor ✭ ✭ ✭

Hi,

 

This post is most likely directed at MosheLTV, so thank you for your help in advance. Before you ask, this has previously been reported by a contact of mine via Adwords Support, who investigated and agreed that there was common ownership, but did nothing and hid behind the “we cannot comment on specific cases” line.

A completely clear-cut violation of the Adwords Policies has come to my attention. It involves double serving ads on the same UK-targeted SERPs on a large scale, in a flagrant breach of Google's Double Serving policy. One of the SERPs involved, "contact lenses", is displayed to c. 40,000 UK Google users per month, so this is not a small problem and must be dealt with immediately.

The violation involves the two websites: www.getlenses.co.uk and www.visiondirect.co.uk.

Google, as the largest online marketing platform, has the Double Serving Policy in order to create a fair advertising system for its customers. I appreciate that it is an extremely large platform to police, but when presented with irrefutable evidence of breaches of its policies, Google must be seen to act.

Below is a comprehensive report on the violation.

----------

Google's Doubling Serving Policy:


The Google Double-Serving policy is located here:
https://support.google.com/adwordspolicy/answer/2600168?hl=en-GB

The first part states (highlights my own):
---
To protect the value and diversity of the ads people see on Google, we generally discourage advertisers from running ads for the same or similar businesses across multiple accounts triggered by the same or similar keywords. This policy, known as "double serving", prevents multiple ads from the same or commonly-owned company from appearing on the same search results page.

To comply with this policy, advertisers should avoid running ads from different accounts on the same or similar keywords that point to the same or similar websites. Violations of this policy occur when multiple websites share Common Ownership (defined below), plus when two or more of the following factors are present:

    Common product offering: ...
    Similar pricing: ...
    Similar customer support experience: ...
    Brand: ...
---

Below is proof of violation of this policy.

----------

Proof of Violation

Proof of Common Ownership

The definition in the policy states:
---
Common Ownership

Common ownership occurs when the same entity, whether an individual or a business, owns or controls one or more of the sites in question at the time of multiple ad serving.

---

The sites (www.getlenses.co.uk and www.visiondirect.co.uk) in this violation have been very public about being commonly owned. Indeed, a search for "getlenses acquires vision direct" on Google UK brings up the following results all confirming the status of being commonly owned:

⦁    http://www.getlenses.co.uk/blog/GetLenses-aquires-Vision-Direct-to-strengthen-European-position/ (statement from GetLenses.co.uk itself)
⦁    http://www.privateequitywire.co.uk/2014/02/12/197073/octopus-backed-getlenses-acquires-vision-direct...
⦁    http://uk.prweb.com/releases/2014/02/prweb11569559.htm
⦁    https://www.facebook.com/GetLenses.co.uk/posts/10152274843792244 (statement from Getlenses.co.uk itself)
⦁    http://startups.co.uk/contact-lens-retailer-getlenses-acquires-dutch-competitors-vision-direct-and-l...
⦁    http://www.crunchbase.com/organization/getlenses-co-uk
⦁    https://twitter.com/getlenses/status/434275934313521152 (statement from Getlenses.co.uk itself)
⦁    http://www.opticianonline.net/233880/ (industry magazine)
⦁    http://www.veooz.com/news/GrP_Ne.html
⦁    https://www.bcla.org.uk/blog/in-the-news-goc-to-tackle-illegal-online-contact-lens-sales (industry body)

Other sources again confirm common ownership:

⦁    http://www.insidermedia.com/insider/yorkshire/108271-dutch-deals-getlenses
⦁    http://www.sys-con.com/node/2965925
⦁    http://www.unquote.com/uk/official-record/2328618/octopus-finances-two-bolt-ons-for-getlenses
⦁    http://www.tusmedios.es/economia_y_negocios/55656-getlenses-adquiere-vision-direct-para-fortalecer-s...
⦁    http://www.allepersberichten.nl/persbericht/22606/1/GetLenses-verstevigt-positie-in-Europa-met-overn...
⦁    http://finance.fortune.cnn.com/2014/02/11/deals-of-the-day-la-quinta-files-for-ipo/
⦁    http://www.pehub.com/2014/02/getlenses-acquires-vision-direct/
⦁    http://www.yorkpress.co.uk/business/news/11008455.Online_lens_firm_is_eyeing_expansion/

Further evidence of common ownership is available from IP Whois data.

Here is an extract of Whois data for www.getlenses.co.uk (http://whois.domaintools.com/getlenses.co.uk):
---
Domain name:
getlenses.co.uk
Registrant:
GetLenses Ltd
Registrant type:
UK Limited Company, (Company number: 6537157)
Registrant's address:
Suite 3A, Lyttelton House
2 Lyttelton Road
London
N2 0EF
United Kingdom
Data validation:
Registrant contact details validated by Nominet on 10-Dec-2012
Registrar:
Mr Michael Kraftman [Tag = MKRAFTMAN]
---

Here is an extract of Whois data for www.visiondirect.co.uk (http://whois.domaintools.com/visiondirect.co.uk):
---
Domain name:
visiondirect.co.uk
Registrant:
GetLenses Group Ltd
Registrant type:
UK Limited Company, (Company number: 5124086)
Registrant's address:
Suite 3A, Lyttelton House
2 Lyttelton Road
London
England
N2 0EF
United Kingdom
Data validation:
Registrant contact details validated by Nominet on 05-Feb-2014
Registrar:
Mr Michael Kraftman [Tag = MKRAFTMAN]
---

Both of these sites are registered to the exact same address and the exact same Registrar name, Michael Kraftman, whose Linkedin profile (http://uk.linkedin.com/in/mkraftman) lists him as the Chief Executive for both Getlenses.co.uk and Vision Direct.co.uk.

The only difference in the Whois data is the Registrant company name the sites are registered to. However, Getlenses Ltd (the company www.getlenses.co.uk is registered to) is a subsidiary of Getlenses Group Ltd (the company that www.visiondirect.co.uk is registered to). This is proved by checking the list of shareholders at Companies House, which shows the entirety of the shareholding of Getlenses Ltd is owned by Getlenses Group Ltd. Therefore, Getlenses Ltd is a fully owned subsidiary of Getlenses Group Ltd.

Based on the above sources, it is undeniable that these two website fall under Google's definition of common ownership, and are owned and controlled by the same parent company.

Proof of Common Product Offering

The definition in the policy states:
---
Common product offering: For physical goods being sold, the sites share products in common such that a user browsing the site would perceive little difference in inventory between the sites.
---

Visits to Getlenses.co.uk and Visiondirect.co.uk will make it immediately obvious "a user browsing the site would perceive little difference in inventory between the sites". In fact the inventory is almost completely identical. An irrefutable piece of evidence is the site maps for the two sites, which show almost identical product lists:

⦁    http://www.getlenses.co.uk/site-map
⦁    http://www.visiondirect.co.uk/site-map

Based on this evidence, it is undeniable that these two websites fall under Google's definition of having a common product offering.

Proof of Similar Pricing

The definition in the policy states:
---
Similar pricing: When pricing is available on the sites, there's a price difference between the sites of 25% or less for substantially the same product or service. When two or more sites solicit contact information from users in order to provide a custom quote, they will be considered to have zero price difference.
---

Visits to Getlenses.co.uk and Visiondirect.co.uk will make it immediately obvious that "there's a price difference between the sites of 25% or less for substantially the same product or service". Pricing is almost identical. Here are the prices for the three most common contact lens products on both sites, together with the links to the product pages (popularity judged by GetLenses.co.uk's page: http://www.getlenses.co.uk/contact-lenses/top-10-contact-lenses.html)

1-Day Acuvue Moist 30 lenses:
⦁    GetLenses.co.uk: £15.99 (http://www.getlenses.co.uk/1-day-acuvue-moist.html)
⦁    VisionDirect.co.uk: £15.98 (http://www.visiondirect.co.uk/1-day-acuvue-moist)
⦁    Price differential = 0.06%

1-Day Acuvue Moist for Astigmatism 30 lenses:
⦁    GetLenses.co.uk: £22.99 (http://www.getlenses.co.uk/1-day-acuvue-moist-for-astigmatism.html)
⦁    VisionDirect.co.uk: £22.48 (http://www.visiondirect.co.uk/1-day-acuvue-moist-for-astigmatism)
⦁    Price differential = 2.27%

1-Day Acuvue Trueye 30 lenses:
⦁    GetLenses.co.uk: £19.99 (http://www.getlenses.co.uk/1-day-acuvue-trueye.html)
⦁    VisionDirect.co.uk: £19.98 (http://www.visiondirect.co.uk/1-day-acuvue-trueye)
⦁    Price differential = 0.05%

All price differentials are well below the 25% threshold, and this is the case for all products on the sites. Contact lenses are commodity products and therefore consumers will receive the identical product whichever site they order from, hence they are receiving the "same product" for the price they pay.

Based on this evidence, it is undeniable that these two websites fall under Google's definition of having similar pricing.

Proof of Similar Customer Support Experience


The definition in the policy states:
---
Similar customer support experience: The sites offer the same or similar type of product or service for which the customer can expect to receive the same or similar level of Support (defined below).
...
Support
Support occurs after the purchase of the product or service. The sales process isn't considered part of support delivery. Support levels may be considered distinct in the case of self-service vs. dedicated support models. A dedicated support offering will provide a single named point of contact for the service, such as a dedicated customer service representative or advisor. Call centre availability and online help are classified as self-service offerings. The use of different online tools to deliver support is not relevant in the identification of a distinct support offering.

---

Although the policy is somewhat vague in the definition of a Similar Customer Support Experience, in my view these two sites do offer the same customer support experience.

A self-service model is present on both sites. Consumers order contact lenses on the site, enter details required for purchase, checkout and receive their lenses via Royal Mail.

The telephone customer support is available at the same times (8am - 8pm, 7 days per week), as shown here: http://www.getlenses.co.uk/contact-us and http://www.visiondirect.co.uk/contact-us. I have called the number on both sites and talked to the same person, so it is the same call centre that is serving both sites.

The live chat support feature that is available on both sites is identical, and on starting chats on both sites simultaneously, both customer service representatives that have responded were called "Angela". This, again, is because both sites are served by the same call centre.

I also believe that all orders for both sites are dispatched out of the same distribution facility in York.

Based on this evidence, it is extremely likely that these two websites fall under Google's definition of having a Similar Customer Support Experience.

Proof of Ads Appearing Simultaneously on the Same SERP


In order for the violation to occur, ads from both sites need to be displayed on the same SERP simultaneously. Google will have the data on this, but I am doing real-time searches at the time of writing and I have seen ads from both sites being served on the following SERPs (searching from Google.co.uk):


contact lenses

1 day acuvue moist

acuvue moist

air optix

buy contact lenses online

buy contact lenses online uk

cheap contact lenses

cheap contact lenses uk

colour contact lenses

contact lens

contact lense

contact lenses by post

contact lenses online

contact lenses online uk

contact lenses uk

dailies aquacomfort plus

daily contact lenses

lenses online

next day contact lenses

next day delivery contact lenses

focus dailies

order contact lenses online

order contact lenses online uk

Due to the variety of search terms there will be thousands of SERPs that Google is currently double serving ads for these sites on.

Summary Confirming Double Serving Violations are Occurring

The policy states:
---
Violations of this policy occur when multiple websites share Common Ownership (defined below), plus when two or more of the following factors are present:
    Common product offering: ...
    Similar pricing: ...
    Similar customer support experience: ...
    Brand: ...
---

Violations are occurring as:

1) The websites share Common Ownership, as proved by the evidence above.
2) The websites have a Common Product Offering, as proved by the evidence above.
3) The websites have Similar Pricing, as proved by the evidence above.
4) The websites have a Similar Customer Support Experience, as proved by the evidence above.
5) The websites are double serving ads on the same SERP, as proved by the evidence above.

It is undeniable, that according to Google's Double Serving policy, these websites are in violation by double serving ads on the same SERP. The websites share common ownership, and have three of the factors required to meet the requirements to fall under the Double Serving Policy, when only two are required for a violation of the policy.

----------

Penalty for Double Serving Violations

The policy states:
---
This policy, known as "double serving", prevents multiple ads from the same or commonly-owned company from appearing on the same search results page.
...
What happens if I violate this policy?
Google will notify advertisers if they violate this policy. Multiple violations may result in penalties, including account suspension.

---

These websites have been double serving ads on multiple SERPs for a considerable length of time and may have been previously been warned. Their activities must be stopped by Google immediately.

 

Please let me know if any further information is required for MosheLTV, or any other forum member, to be able to pick this up with Google, and I will gladly oblige.

 

Thank you in advance for the help of the forum in stopping this abuse of Google’s system.

 

Alan

2 Expert replyverified_user

Re: Clear-Cut Double Serving Violation

Top Contributor
# 2
Top Contributor

Hello Alan;

My colleague  Jon (aka @Cobnut) drew my attention to this thread;

It seems that you have done quite an extensive and intensive research.

I  looked at the sites and the (complete and detailed)  information you provided.  I do agree that this is a double serving, if both ads are shown simultaneously on the same SERP.

 

I don't know why no action has been taken by Google. I will refer the case to Google. As said, you have done intense / exceptional (and time consuming)   job proving  the case.  Having said that,  for the case to be complete (and) to be submitted to Google, through our channels, could you upload some screenshots showing the ads simultaneously, On the same SERP. (3-4 would doConsidering the work you have put - this should be a minor task...)

 

Thank you!

Moshe, AdWords Top Contributor , Twitter | Linkedin | Community Profile | Ad-Globe
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Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 3
Visitor ✭ ✭ ✭

Nice catch... I think they are your competitor or enemy... Smiley Very Happy BTW good research done by you.

Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 4
Visitor ✭ ✭ ✭
Hi MosheTLV,

Thank you very much for picking up my post. Sorry it was so long, but I like to make sure that my evidence is concrete before posting anything. I am glad you agree that this is double serving, but then again not surprised as it is such a clear-cut case.

Thank you also to @Cobnut for alerting you to this thread.

I had difficultly uploading screenshots through the reply editor, so I have uploaded them to a third-party website, which allows viewing via the link.

I have included five screenshots from the google.co.uk SERPs listed in my original post to show that both www.visiondirect.co.uk and www.getlenses.co.uk are shown on the same SERP (these were all taken today, showing that the abuse is ongoing). Here they are, along with the SERPs they are from:

1. "contact lenses" - https://www.anonimg.com/img/7fbe2b779897a318ba27e012dbf3be43.jpg

2. "contact lens" - https://www.anonimg.com/img/ae8ba3bd960ad86a21fb9f08e8267d6e.jpg

3. "cheap contact lenses" - https://www.anonimg.com/img/12c0dc7a06a3663bc81b6e74f0b75410.jpg

4. "buy contact lenses" - https://www.anonimg.com/img/181813f09ea6941140b3ab603ac00397.jpg

5. "1 day acuvue moist" - https://www.anonimg.com/img/545cbc341744cc84d4405a0190e48f3a.jpg

Please could you confirm that these images are suitable for your submission and that you have submitted it through your channel. Please let the forum know what feedback Google gives, as I'm sure it will be of great interest to others on the forum. I look forward to Google rectifying this situation very quickly.

Thank you again,

Alan

Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 5
Visitor ✭ ✭ ✭
Hi MosheTLV,

Thank you very much for picking up my post. Thank you also to @Cobnut for alerting you to it.

Sorry that the post was so long, but I like to make sure that my evidence is concrete before posting. I am glad that you (as the expert) agree this is double-serving, but I am not surprised, as the case is so clear-cut.

I had trouble uploading the images via the editor, so I have uploaded them to an image sharing service. Here are five examples from today of SERPs on Google.co.uk (taken from those listed in my original post) where ads for www.visiondirect.co.uk and www.getlenses.co.uk are being double served.

- "1 day acuvue moist" - https://www.anonimg.com/img/545cbc341744cc84d4405a0190e48f3a.jpg
- "buy contact lenses" - https://www.anonimg.com/img/181813f09ea6941140b3ab603ac00397.jpg
- "cheap contact lenses" - https://www.anonimg.com/img/12c0dc7a06a3663bc81b6e74f0b75410.jpg
- "contact lens" - https://www.anonimg.com/img/ae8ba3bd960ad86a21fb9f08e8267d6e.jpg
- "contact lenses" - https://www.anonimg.com/img/7fbe2b779897a318ba27e012dbf3be43.jpg

Please could you now submit this through your channel. Please let me know if there is anything else you need provided.

I think it would be very useful for other members of the forum if you could let us know what Google say about this case, as I am sure a lot of people will be interested.

Thank you very much for your help and I look forward to seeing Google stopping this clear case of abuse.

Alan

Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 6
Visitor ✭ ✭ ✭

Hi MosheTLV,

Thank you very much for picking up my post. Thank you also to @Cobnut for alerting you to it.

Sorry that the post was so long, but I like to make sure that my evidence is concrete before posting. I am glad that you (as the expert) agree this is double-serving, but I am not surprised, as the case is so clear-cut.

I had trouble uploading the images via the editor, so I have uploaded them to an image sharing service. Here are five examples from today of SERPs on Google.co.uk (taken from those listed in my original post) where ads for www.visiondirect.co.uk and www.getlenses.co.uk are being double served.

- "1 day acuvue moist" - https://www.anonimg.com/img/545cbc341744cc84d4405a0190e48f3a.jpg
- "buy contact lenses" - https://www.anonimg.com/img/181813f09ea6941140b3ab603ac00397.jpg
- "cheap contact lenses" - https://www.anonimg.com/img/12c0dc7a06a3663bc81b6e74f0b75410.jpg
- "contact lens" - https://www.anonimg.com/img/ae8ba3bd960ad86a21fb9f08e8267d6e.jpg
- "contact lenses" - https://www.anonimg.com/img/7fbe2b779897a318ba27e012dbf3be43.jpg

Please could you now submit this through your channel. Please let me know if there is anything else you need provided.

I think it would be very useful for other members of the forum if you could let us know what Google say about this case, as I am sure a lot of people will be interested.

Thank you very much for your help and I look forward to seeing Google stopping this clear case of abuse.

Alan

Re: Clear-Cut Double Serving Violation

Top Contributor
# 7
Top Contributor
@Alan;
Why did you delete the post with screenshots?
Moshe, AdWords Top Contributor , Twitter | Linkedin | Community Profile | Ad-Globe
Did you find any helpful responses or answers to your query? If yes, please mark it as the ‘Best Answer’

Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 8
Visitor ✭ ✭ ✭
Hi MosheTLV,

I didn't. I have no idea why it is no longer here. The images were posted on anonimg dot com which Google perhaps automatically removes. I will post again.

Thank you.

Alan

Re: Clear-Cut Double Serving Violation

Visitor ✭ ✭ ✭
# 9
Visitor ✭ ✭ ✭

MosheTLV - Here is the post that mysteriously disappeared posted again

 

---

 

Hi MosheTLV,

Thank you very much for picking up my post. Thank you also to @Cobnut for alerting you to it.

Sorry that the post was so long, but I like to make sure that my evidence is concrete before posting. I am glad that you (as the expert) agree this is double-serving, but I am not surprised, as the case is so clear-cut.

I had trouble uploading the images via the editor, so I have uploaded them to an image sharing service. Here are five examples from today of SERPs on Google.co.uk (taken from those listed in my original post) where ads for www.visiondirect.co.uk and www.getlenses.co.uk are being double served.

- "1 day acuvue moist" - https://www.anonimg.com/img/545cbc341744cc84d4405a0190e48f3a.jpg
- "buy contact lenses" - https://www.anonimg.com/img/181813f09ea6941140b3ab603ac00397.jpg
- "cheap contact lenses" - https://www.anonimg.com/img/12c0dc7a06a3663bc81b6e74f0b75410.jpg
- "contact lens" - https://www.anonimg.com/img/ae8ba3bd960ad86a21fb9f08e8267d6e.jpg
- "contact lenses" - https://www.anonimg.com/img/7fbe2b779897a318ba27e012dbf3be43.jpg

Please could you now submit this through your channel. Please let me know if there is anything else you need provided.

I think it would be very useful for other members of the forum if you could let us know what Google say about this case, as I am sure a lot of people will be interested.

Thank you very much for your help and I look forward to seeing Google stopping this clear case of abuse.

Alan

Re: Clear-Cut Double Serving Violation

Top Contributor
# 10
Top Contributor

Got you; It Could be filtered by the spam filter since you linked it to an outside platform;

I'll bring it back

@RachelM; - Could you release the posts by Alan from the spam filter; 

Moshe, AdWords Top Contributor , Twitter | Linkedin | Community Profile | Ad-Globe
Did you find any helpful responses or answers to your query? If yes, please mark it as the ‘Best Answer’