In December 2007, the Federal Trade Commission released a paper titled "Online Behvioral Advertisement: Moving the Discussion Forward to Possible Self-Regulatory Principles" (See: Self-Regulatory Principles on Behavioral Advertising). It included four proposed principles:

The FTC called for comments and many companies and organisations sent statements (they can be found at http://ftc.gov/os/comments/behavioraladprinciples/index.shtm). The commentators agreed that the principles were a good start for the discussion, but also critized several aspects. Google said the principles are overly burdensome and too broadly defined.

As in Europe, Google sticks to its opinion that the IP adress is not a personally identifying information. The paper does not differentiate between personally identifying information and not personally identifying information.This would be a big problem: Principle 3 e.g. requires affirmative express consent for material changes to an online company's privacy policy. Google has a lot of unauthenticated users. How should they be asked for their consent?

Principle 4 would either require the affirmative consent, or simply prohibit, collection of sensitive personal data for behavioral advertising. Google criticises that "sensitive data" is not defined: ”As a result, Principle 4 would not allow Google to collect a search query for “cancer treatment” or “alcoholics anonymous” from unauthenticated users because we do not have any relationship with an unauthenticated user and we have no way to obtain that user’s consent – affirmative and express or otherwise – prior to collecting the search query."