Submission Date: [Insert Date]
Submitted by: [Organization / Publisher Name]
Contact: [Name, Title, Email]
Website / Network: [e.g., StrongMocha News Group, ThorstenMeyerAI.com, etc.]
1. Executive Summary
Briefly outline your organization’s role (e.g., “We operate a network of independent digital publications reaching X million monthly readers”) and the purpose of your submission.
Example:
We welcome the CMA’s SMS designation of Google in general search and search advertising. Our submission highlights the need for stronger publisher controls, fair ranking treatment, and transparency over AI-generated summaries that repurpose publisher content.
AI content attribution tools
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2. Key Concerns
✅ AI Content Use & Attribution
- Publisher content increasingly appears in AI Overviews / summaries without adequate source visibility.
- Need for explicit opt-out mechanisms, clear attribution, and visibility into impression/click metrics.
✅ Ranking & Self-Preferencing
- Google’s own verticals (e.g., Flights, Maps, Shopping) often displace organic results.
- Request auditable fairness tests and disclosure of ranking factors affecting independent publishers.
✅ Choice & Competition
- Recommend choice screens and default flexibility across browsers, voice assistants, and mobile ecosystems.
- Defaults should be recurring and user-friendly to ensure meaningful competition.
search ranking fairness testing software
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3. Recommended Conduct Requirements
| Area | Proposed Requirement | Intended Outcome |
|---|---|---|
| AI-generated summaries | Mandatory opt-out and source labeling | Preserve publisher traffic & integrity |
| Search ranking | Non-discrimination and transparent metrics | Level playing field |
| Defaults | Choice screens across devices | Reduce lock-in |
| Data access | Periodic reports to publishers on usage | Build accountability |
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As an affiliate, we earn on qualifying purchases.
As an affiliate, we earn on qualifying purchases.
4. Evidence & Impact
Provide short evidence points (traffic trends, search visibility loss, etc.).
Example:
Since the introduction of AI Overviews, we’ve observed a 12% decline in referral traffic across our UK news titles despite unchanged content output and keyword relevance.
Attach or link supporting data where possible.
Digital Marketing Analytics: Making Sense of Consumer Data in a Digital World (Que Biz-Tech)
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5. Requested Next Steps
- Include publishers in CMA’s remedy design workshops.
- Ensure AI and Search remedies are synchronized across future Gemini or Assistant designations.
- Request CMA to publish annual compliance audits of Google’s CR adherence.
6. Declaration
We affirm that this submission reflects our independent assessment and is provided to assist the CMA in ensuring a fair, transparent, and competitive digital market.
Signed:
[Name, Position]
[Organization]
[Date]
