ss effective, and therefore less profitable. Although behavioral data is essentially anonymous when collected, the FTC and privacy advocates are concerned that the amount and depth of some data could lead to personal identification of users. In addition, even if users are not personally identified, the enhanced data about them could rise to the level of an invasion of privacy. The Chitka Settlement In 2009, the FTC issued a staff report on behavioral advertising that explained the FTC's principles regarding behavioral data. The FTC believes that its deceptive and a violation of the FTC Act to fail to provide to consumers proper notice and opt-out choice regarding the collection of behavioral data. The FTC's settlement with Chitka, Inc. is the first settlement based on these principles. Chitka is an intermediary between advertisers and websites that serve ads for the advertisers. To collect behavioral data, Chitka passes a cookie on users' computers and then uses the cookie to tracks the users' online behavior. The FTC alleged in its Complaint that for over two years Chitka advised consumers that if they wanted to opt out of behavioral tracking they could click on a button titled "opt out". Clicking the button would generate a message that read "you are opted out". The catch according to the FTC is that the opt out lasted only for ten days, and then new cookies would be passed to consumers' computers resulting in tracking of behavioral data for serving behavioral ads. In its settlement with the FTC, Chitka agreed to: * delete all identifiable user information collected ineffective opt out period, * provide consumers with a new opt out mechanism that lasts for at least five years, and * notify consumers whose opt out was ineffective to opt out again. Chitka also agreed to a notice and opt out procedure that could be interpreted as a blue print for what the FTC believes is generally required for all sites that collect behavioral data. This procedure includes: * A message on the home page that reads "we collect