Official Response from 180solutions to Porter’s Questions

Continued from Porter’s Preface to 180solutions’ Response.

While 180solutions was a bit late in getting their responses to me they did keep their word and have provided answers to my questions. In keeping with my promise to them I will keep the comments turned off and refrain from making my own comments on their responses in this blog entry.

Without further ado here are the questions and answers kindly provided to me by Cory Magnus of 180solutions. They are unedited and I have not verified or fact checked their claims. What you see is what you get. I will leave it to readers and analysts to make their own judgements and provide feedback in their own journals.

[ScreenShot Note: I have taken the liberty of compressing the screenshots in the original Word file because the image size would have made the entry download at unacceptable rate. However I have retained image dimensions as per the paper.]

[Reader's Note Questions are in Bold Format]

1.)Why was 180solutions admitted to COAST? What did kind of promises did 180solutions make in order to get into COAST?

Part of COAST’s mission was to develop a program for software developers to join and contribute to setting standards around downloadable applications and online advertising. 180solutions strongly supports standards that will create a safer Internet, and wanted to gain membership in COAST to help create guidelines and best practices for software developers.

180solutions approached COAST in 2004 asking to work with the organization in an effort to improve our applications – ultimately ending up with even better user notification, consent, and uninstall capabilities. 180solutions proactively made changes to both the application and distribution channel and as a result was welcomed to COAST in mid-January.

More information on our relationship with COAST can be read here:

http://www.180solutions.com/pages/pressrelease.aspx?node=/Press/COAST

2. Shortly after 180solutions was admitted to COAST, that organization collapsed when its three of its anti-spyware members (Webroot, Pest Patrol, Aluria) withdrew. Why then is 180solutions still touting its admission into COAST? (e.g. There is a prominent link on the 180solutions.com home page but also the report of Duane Jeffers at SpywareInfo: http://forums.spywareinfo.com/index.php?showtopic=26327.)

As is the case with many non-profit organizations, gaining consensus can at times prove challenging. Despite COAST’s organizational issues, 180solutions is steadfast in our commitment to operating under the highest set of standards for downloadable applications. 180solutions will continue to forge relationships with industry experts and advocates to improve the online experience and consumer safety. We recognize the need for best practices to be outlined, and will continue to work with other companies to put these standards in place.

Despite the organizational issues within COAST, 180solutions has embraced the recommendations made by the founding members of COAST and has implemented changes into the application and distribution channel. In fact, Sam Curry the vice president of product management for CA’s eTrust brand told eWeek “I find it odd that 180solutions is the source of the conflict. The goal [of COAST] was to certify vendors that reformed their product. 180solutions went to great pains to make major changes. The new versions of their software conform to scorecards and standards,” Curry said.

Curry further commented that “he pinned the blame for the breakup squarely on the shoulders of Webroot and Aluria”.

3. 180 used to distribute software called nCase. I have been informed by members of your staff that you no longer distribute nCase. Why did 180 stop distributing nCase? What’s the difference between the nCase software and the 180search Assistant and Zango programs that replaced it?

All applications evolve over time and become easier to use, more efficient and more feature rich. With each update applications offer more options and controls to users. It is the company’s No. 1 priority to provide value to users and develop a long-term, positive relationship with consumers. We will continue to enhance our applications and continue to survey our user-base for input on how we can improve.

180search Assistant represents the next generation of a line of products that included nCase and goes to back to the origins of the company. 180 started as a company which developed an advertising solution that was licensed to ISP’s who wanted to provide free internet access in exchange for an advertising window being displayed to the user whenever the user was connected to the Internet. That application and service evolved to where 180 was licensing its service to software developers under the nCase name. 180search Assistant represents the next generation of nCase and features many enhancements including better performance; more user notification including labeling of the advertiser’s websites, a persistent system tray icon, as well as an easier uninstall process. Zango is an entirely new media model for sponsoring content online and is much more than a new piece of software.

4. What happened to all those older nCase installations? Did 180 upgrade them to the 180search Assistant? If 180 did that, did 180 notify those users first? If so how?

We upgraded the users at the same time we introduced the new, easier uninstall process.

5. There have been many reports of 180’s software being stealth installed on people’s computers. How did this situation happen? Are there still stealth installs going on? What is 180 doing to stop those stealth installs?

First, 180solutions cares a tremendous amount about what users think about our software from how it is distributed to how it works on a user’s machine. As our company has grown, our company has and will continue to invest heavily in user-focused initiatives. Going forward, through the use of additional staff and innovative technology, we will dramatically increase control over how our partners operate. We understand and accept the responsibility to monitor and police our partners.

Historically, 180solutions has not installed software; we relied on a network of partners to distribute our applications. Over the last year, 180solutions has placed greater emphasis on managing distribution partners as well as moving to maintain more control over how our software is installed on users’ machines. In response to public and our own concerns, we careful monitor our channels for conduct we find inappropriate. 180solutions has a stringent distributor code of conduct in place and frequently audits distribution partners. One of the reasons we were interested in working with COAST is that we hoped to develop an industry-wide distribution monitoring service as in part envisioned by Jay Cross, formerly of the The Internet Privacy Conservation Council (IPCC) and advisor to COAST.

If questionable practices are found, 180solutions investigates the situation and takes the appropriate corrective measures including legal action. As you can see we’re extremely clear in the 180 Distributor Code of Conduct:

Distributor agrees to accurately provide easy to read and understand notice and information to all end users of 180solutions products and all other applications that are bundled with 180solutions products before both initiating a download to and installing the products or applications on an end user’s computer, and to give such end user an easy and appropriate method to agree or not to agree to such installation. Distributor shall under no circumstances attempt to launch a 180solutions product executable without first displaying the above-described messaging and receiving explicit user consent for the installation. 180solutions reserves the right to approve final wording of this messaging and to require periodic changes as necessitated by changes to 180solutions products or for other business reasons. In addition, each installation of 180solutions products by Distributor must include and be subject to the then current 180solutions End User License Agreement (EULA).

Distributor will ensure that the end user may easily remove/uninstall not just the 180solutions products, but each and every other application bundled with 180solutions products by using the Microsoft Windows Add/Remove Programs menu. Distributor will also ensure that all applications bundled with 180solutions products adhere to terms no less restrictive than those contained in this Agreement follow these same codes of conduct. Other products or applications that act as program “Trojans” (installing additional applications without full product descriptions and EULA acceptance) shall not be bundled with any 180solutions product.

When we find credible and verifiable examples of installs that violate our Code of Conduct and undisclosed installs certainly would, then we take immediate action including but not limited to terminating the partner and suing them as we did last summer.

6. How does 180 distribute its software? Your web site says that you use “distribution partners”. Were some of these partners responsible for the stealth installations of 180’s software? What is 180 doing to make sure that this sort of problem doesn’t crop up again with its partners?

180solutions software is distributed on our websites and through distribution partners who promote their software and web services with support from 180.

180solutions distribution partners only install our applications once user notification and consent have taken place. 180solutions carefully screens potential distributors and rejects 9 out of every 10 who approach us. We monitor the activity of all distribution partners. Any strange or inappropriate activity is immediately investigated. Distributors found in violation of the company’s distributor code of conduct are subject to legal action. When provided with credible evidence, we will and have sued former distributors.

We are also taking steps by introducing new technology into our applications. The newest versions of our software have two important changes that we expect will provide not only ourselves protection but our users from bad actors. In addition the newest versions of our applications have been fundamentally changed in what gets distributed and how our application is installed on a user’s machine. First, we only distribute an installation file whose purpose is to verify a user’s intent to install. Then once that consent has been confirmed through a prompt like the one below, the installer file will call to our servers and download the application. This will solve any going forward issues of old code circulating in various distribution channels as well as allow us to more tightly control our distributors.

Example Prompt:

7. 180 has millions of installations of older versions of 180search Assistant. Many of those may have came from stealth installs where users didn’t know the software was being installed. What is 180 doing about those existing installations of older software? Will 180 remove them or keep them?

The notion that many of our users came from improper installs is an urban legend started in the anti-spyware community. Unfortunately there is a fair amount of public hysteria in the press these days about malicious software. The reality is that 80% of so-called spyware are harmless cookies.

As we have discussed, in cases where we find credible and verifiable evidence of wrongdoing we take many steps including terminating and even suing those distributors accused of wrongdoing. In those cases we notified users by showing this message:

We are currently upgrading all versions of our application to reflect the changes recommended by COAST. If, after the upgrades are made, we find new installs of our older product being distributed we will turn off those applications and pursue the distributor for violation of the Code of Conduct.

180solutions provides toll-free customer support so users can contact us directly with questions and concerns about our software, installation and uninstall methods. 180solutions doesn’t intend to be installed on a computer where we are unwanted, and encourage any user who feels they received our software by mistake to follow uninstall instructions.

8. There are reports the new 180search Assistant has a prompt screen that displays when the software installs for the first time. But what happens when an older version of the 180search Assistant calls the 180 servers to check for updates? Will those older versions be allowed to update to the new versions? If they are allowed to update, will the new prompt screen display?

——————————- See Response to Question 7 ———————————–

9. Could you describe the advertising that 180 displays on people’s computers? How is that advertising labeled?

All advertisements displayed by 180solutions software are opened in a second browser window and presented as a Web site, rather than an advertisement. The second browser window opens, and functions exactly the same as any other page opened in a browser. The window is clearly labeled in the title bar as either or “Brought to you by the 180search Assistant,” depending on the software installed on that machine. The page may be closed simply by clicking on the “X” in the top right corner of the page.

180solutions advertisements are all triggered real-time by keywords in the URL line. For example, if a user is searching on various search engines for Alaska cruises, a Web site for one of our advertisers selling Alaska cruises may appear in a second browser window, offering a listing of prices to purchase an Alaska cruise. This offers the user additional information to what they are browsing for online. There is no profiling and no capture of any browsing history.

10. 180 is getting a lot of flak right now, and perhaps this flak is well deserved giving the issue of stealth installs. Why do you feel anyone should trust 180 Solutions after all the things that happened before?

If you were to visit 180’s offices you would see a bright, vibrant community of talented people who would compare well to any other well known Seattle-based companies.

180solutions enriches our trustworthy relationships with over 20 million consumers by giving away more than $1 million of premium content each month. 180solutions serves more than 5,000 advertisers, providing them with targeted traffic to their Web sites. The company has made serious efforts to create the best and safest user experience possible and protect its users’ privacy. 180solutions partners with more than 50 content providers and has acquired an instant messaging development company and local game development studio. We will continue to pursue relationships with premium content providers to offer our users the best online entertainment. In less than one year, we have become the 15th most trafficked gaming Web site.

Washington-based 180solutions is recognized as one of the fastest growing private companies in Washington and in the U.S., a best company to work for in Washington, and a high-tech leader in Washington by respected publications including the Puget Sound Business Journal, Washington CEO and Inc. Magazine. Organizations including the WSA (www.wsa.org), Venture All Stars (www.ventureallstars.com), and The Pacific Northwest Friends of FSH (www.fshfriends.com) have noted the company as a successful business leader in the community. 180solutions provides real person customer support to its users and is actively involved in bettering the Internet.

11. Are you getting taken out of anti-spyware programs so that they don’t detect your programs any more? If so, which ones?

We are in conversations with every company in this space that we can find – and we are definitely not alone in that regard. These companies have used very aggressive criteria and lists that now encompass so many types of software and technologies we feel do not justify the inclusion of our software. So far a handful has removed the latest versions of our applications.

12. What else do you think people ought to know about 180solutions and the changes it’s making to its software?

180solutions is structured and operates like any other media company. Just like NBC we are in the business of connecting advertisers to consumers, and providing entertaining, free content. One wouldn’t look at NBC and call the network “advervision” – but clearly NBC is in the business of showing advertisements that sponsor content. 180 does the same thing.

Each day we ask ourselves “what could we be doing better?” “how can we make it even easier for consumers to find what their looking for?” “what content do consumers want and how can we sponsor that?” “how can we improve our application today?”. We’re proud of our accomplishments and will continue to innovate and help shape an ideal online experience.

Our company is all about adding value to consumers, advertisers, and Web publishers. We recognize the importance of providing a positive experience for each one of these groups and continually work to enhance our application. It’s important to note that 180solutions exceeds all standards either proposed in pending legislation or in enacted laws for downloadable applications/Internet advertising. The company was the first keyword search advertising provider to put an icon on the users desktop and system tray, clearly label each add, list our application in system processes, and make it simple for users to uninstall. Unlike other players in the space, we only show on average 2-3 ads per active user per day and the vast majority of users see no ads on a given day. By showing fewer ads and making those highly relevant to what consumers are looking for we are able to create a better service for our users.

–End of Interview–

Porter’s End Note: I strongly encourage bloggers, consumers and industry analysts or other software makers to formulate their own responses and opinions and track back to this entry so we can keep a civil dialogue going and get more answers to important questions. There will be no forward movement on issues until we start to communicate and most importantly understand each other’s unique position.

Ping’s Can Be Sent Here: http://alpha.revenews.com/MT/mt-tb.cgi/515

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