But competitor 24/7 Media already has a database of about 20 million people's names and personal spending habits, which it sells to advertisers. And it hasn't provoked the suspicions of the FTC. David Moore, the president and CEO of 24/7, says the key to avoiding trouble is asking permission. 24/7 Media's information is based on opt-in marketing, and Moore, 47, who got his start in advertising selling ads for Turner Broadcasting and Lifetime Television Network, says his goal is to get everyone with an e-mail address to agree to receiving targeted e-mail and ads.

The FTC is investigating DoubleClick, your competitor. Are you concerned about an FTC investigation?

I'm more concerned with the way DoubleClick has handled themselves. For the leader of the marketplace to go and change its privacy policy -- that's not the way we'd do things. It has driven scrutiny of our industry, and privacy is definitely a hot-button issue right now.

We are part of the Network Advertisers Initiative, TRUSTe, all those organizations, that are working to try and craft a set of privacy guidelines. I met yesterday with Sen. Robert Torrecelli, [D-N.J.], who's crafted what's probably the most onerous privacy bill, to try and open the dialogue -- to see if there's a win-win situation. You won't see legislation on this issue tomorrow. We can come up with something that will do a good job protecting people's privacy.

What makes your business different from other ad networks?

We have the largest opt-in e-mail database -- people who have agreed to receive targeted advertising via e-mail.

Are you concerned about contributing more spam?

We don't do any spam -- it's all opt-in, and we're very conscious about not sending people too much e-mail. If you opt in, and I'm sending you a new advertisement every single day, you're going to say, "Get me out of here!" and we'll lose you. But if we send you an e-mail once a week, every seven to 10 days -- and it's on target, I'm going to have you as a customer for a long time. It's a delicate balance, but if they don't want the stuff they are getting, they can always opt out.

If we're not targeting properly, people are going to be irritated. But if you give them something valuable, it becomes a service, as opposed to an advertisement. Let me tell you, I got some e-mails around Valentine's Day that saved my skin. They sent me offers, I went and bought some stuff -- I was a hero!

How do you go about collecting these e-mail addresses?

Let's take FastWeb. This is a hot college site, we manage their e-mail list. So they ask their visitors, would you like to receive a newsletter each week, and learn about new updates to our content -- and would you like to receive promotions about products that we think you'd be interested in. That's how we get the addresses.

Are these separate options? Do you have to accept promotions as a condition of getting the newsletter?

We try to do both, but this is up to the individual sites. And the sites decide how they want to deal with us. In our 24/7 Mail Alliance, you contribute the data on a blind basis and we'll sell it along with the data from our other contributors. We own the data they contribute and pay them a royalty -- of the 20 million names, 11 million are in the alliance. The other 9 million we have a contract for, as the exclusive manager of the lists.

We also just acquired a company called Exactis, they send out a million newsletters a day to a list of users, so we also have those users now. Exactis also gives us a way to manage those users. Here's a theoretical example: Say American Express wants more users. We can do an e-mail and banner campaign to attract new cardholders.

Then we can say [to American Express], what would you like to do with them? And they say, we'd like them to take a trip, or to use their card at a restaurant. So then we can take those people who we know have American Express cards and serve them up different ads -- offer them additional services. We couldn't do this before -- we couldn't manage the customers in a discreet and secure manner before.

Next page | Moore's plan is to get you to sign up for targeted ads and e-mail