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Wireless Promotions:
   Future vs. Fantasy




                                  Bill Carmody
                       Chief Marketing Officer
                                    Seismicom
        939 Port Washington Boulevard, Suite 3
                   Port Washington, NY 11050
                              (646) 867 – 2252
                         bill@billcarmody.com
Table of Contents

   Executive Summary ................................................................................................................................3

   Background ..................................................................................................................................................5

   Dispelling The Wireless Myths & Related Fantasies ..........................................................6
               1.Starbucks Discount Ringing Your Mobile Phone ..............................................................................6
               2. The Promise of the quot;Wireless Webquot; on your Phone........................................................................7
               3. 3G High-Speed Net Access Converting Voice to Data....................................................................8
               4. India, China and EU as Forecasts of U.S. Market Trends................................................................9
               5. Pushing Email Offers to Wireless Phones ....................................................................................10


   Top Five Hottest Promotion Trends in Wireless ....................................................................11
               1. Wireless SPAM & Related Legislation..........................................................................................11
               2. Pull vs. Push Promotional Messages ............................................................................................12
               3. CMR vs. CRM ................................................................................................................................14
               4. Wireless Offers at Retail ..............................................................................................................15
               5. Enhancement of All Other Disciplines ..........................................................................................16


   Leveraging Wireless Promotions For ROI Analysis ..............................................................18

   Recommended Resources..................................................................................................................19

   End Notes ..................................................................................................................................................20




   © 2004 by Bill Carmody. All Rights Reserved.
Executive Summary

   You’ve been lied to, and not for the first time. You’ve been swept into the wireless hype and are searching for a
   future that doesn’t exist. You’ve heard that in the future, a person will walk by a Starbucks and their phone will go
   off. The beeping from the phone will reveal a discount that the consumer can take into the store for an immediate
   purchase. It’s not going to happen for a number of reasons that this white paper will explain. Nor will you be able to
   “Surf the Web” from the phone the same way you do now on your computer. For that matter, you’re likely to use
   the voice side of your phone much more frequently than the data side. Oh yeah, and that rumor you heard about
   India, China and the European Union being an accurate forecaster of U.S. trends? Think again.

   Like all myths there are elements of truth to everything stated above. The truth is, with GPS embedded in your
   phone, you’ll have an enormous amount of location-based services available to you. The Web is, in fact, accessible
   from your phone—it’s just not the same Web you’re used to on your laptop. Data services are on the rise, but the
   use of voice is still the dominant service here in the U.S. Overseas, there are quite a number of interesting ideas
   that will evolve and morph themselves into something useful in the U.S.; however, the underlying technology,
   infrastructure, business interests and even societal differences will ensure different outcomes in the U.S.

   Sorry to be the one to break all this to you, but someone has to do it if we ever want to realize the true wireless
   promotions potential and to succeed.

   So what does the future look like? It’s actually very exciting and in many ways reminiscent of the dot com era—for
   good and for bad. The top futurists all see wireless technology having significant impact on the way we do business.
   While there are definitely still some technical issues to be worked out, the future is very bright.

   If you experienced all the pain (and hopefully profit) with respect to how the Internet changed your business,
   then many of the core elements contained herein will sound somewhat familiar. At present, the central issues for
   wireless promotions are no different than the central issues for the Web: Permission and Privacy. Imagine if you
   had to pay ten cents for every piece of SPAM email you received in your inbox. I currently average about 100 to 200
   SPAM emails per day. That translates into $10 to $20 per day, or $3,650 to $7  ,300 a year! With this example, you can
   see why not only do all the same SPAM issues from email marketing apply, but why they are financially much more
   critical to solve.

   To smart marketers, however, this should be a no-brainer. If you abuse the trust of your customers (offline, online
   or via wireless), you’re going to lose them… period. But with wireless, there are some new things to think about.

   “Pull” versus “Push” for example, will force marketers to rethink the kinds of wireless strategies they employ.
                         ,
   “Push” programs follow the traditional “one to many” mass marketing noise we’ve all been trying to get past.
   It’s where a marketer creates a “one size fits all” message and figures out a way to shove it down the customer’s
   throats. “Pull” messages, on the other hand, are much more highly relevant to the consumer and, more to the
   point, the situation in which they find themselves. A “Pull” message would be one whereby a consumer requests
   the nearest retail location to where they are currently standing. Or, a request for an account balance, offer, entry, or
   any other promotional tactic you can think of. The consumer initiates the request and, if the marketer has done their
   homework, they can easily provide what the consumer is looking for.




                                                                                                                         3
   © 2004 by Bill Carmody. All Rights Reserved.
Executive Summary

   This leads us to an invaluable insight from Carat Interactive. We need to change the “CRM” to the “CMR” Forget  .
   “Customer Relationship Management” and start thinking in terms of the “Customer Manages the Relationship.            ”
   It’s not that CRM isn’t valuable. It’s definitely a step in the right direction, but to succeed in wireless promotions,
   we need to be dyslexic with this acronym. We need to begin with the idea that the consumer, not the marketer, is
   in the driver seat and manages the relationship. This is the reality in all marketing, but becomes painfully apparent
   in wireless programs that do not follow this golden rule.

   From there, we rally around the marvels of what we can currently do in the retail environment and get a sneak
   peak at what’s to come. The bottom line is that the marriage of retail and wireless couldn’t be a more perfect match.
   Yes, there are still some technical issues that will be worked out over time, but the reality is clear as day. Retail
   programs, integrated with wireless components are here to stay.

   To that end, wireless promotions should be viewed in the context of the larger marketing mix. That is, just like
   any promotion that is integrated into multiple mediums and disciplines, wireless promotions are most successful
   when they are integrated. More to the point, wireless promotions can enhance the other promotional marketing
   disciplines such as Sponsorships, Events, Online, Retail, and Direct Response. Because of the ubiquity of the
   wireless device, consumers can become more engaged and respond to the kinds of offers and promotions that
   appeal to them.

   Adding wireless components to your existing promotional marketing programs can further help you track Return
   on Investment (ROI). This is particularly true with the drive to retail programs, but also applies to e-commerce
   promotions and any promotion that leverages tracking codes as part of the response mechanism. This even works
   well in the sponsorship world. AT&T Wireless, for example, was able to liquidate part of their Olympics sponsorship
   by selling Olympic ring tones, screen savers and other content downloads (not to mention signing up new
   subscribers via exclusive Olympic phone offers).The more the wireless phone promotion is connected to purchase
   experience, the more directly you can track and analyze thepromotion’s ROI.

   By the conclusion of this white paper, it should be evident that by integrating wireless marketing into your next
   promotion, you will be able to quickly create (and cost effectively deliver) complementary offers that will increase
   your response rates. Mobile programs will further allow you to test various offers and strategies in a timely and
   cost-effective manner. As with any “first mover” promotional marketing programs, the marketers that work towards
   building the future of promotional marketing programs today are likely to gain market share and a leg up against
   their competitors.

   Recommended resources are included so that you can have a good idea of the kinds of companies that are
   currently available to promotional marketers. Each of these companies have their own thoughts about the future
   of wireless promotions and are likely to be interested in answering any further questions you may have.




                                                                                                                             4
   © 2004 by Bill Carmody. All Rights Reserved.
Background

   What’s exciting about the future of wireless marketing in general and wireless promotions in particular is that we
   are on the brink of a significant shake-up in our industry; the likes of which have not been witnessed since the
   World Wide Web was introduced in the early ‘90s. Believe it or not, this is not one of the “myths” covered in this
   white paper. The fact is, there are many significant reasons why this is the case. Let’s begin with an excerpt from
   Paul Saffo, a director of Institute for the Future and a technology forecaster studying long-term information technology
   trends and their impact on business:

              The Internet and the Web have barely touched our lives. The Web arrived on the one piece of
              real estate we’ve been trying to get away from for the last 20 years: our desktops. It didn’t get
              any further. This is what makes wireless and broadband so important. Wireless delivers the
              Internet in general and the Web in particular, to where we actually live and work and play. That
              has profound implications for our life and also for the medium. The Web on wireless going to
              personal appliances is not the Web as we know it. It is something else.1

   According to PROMO Magazine, there were an estimated 1.3 billion mobile phone subscribers around the world, who
   sent some 3.66 billion SMS messages in 2002. The number of worldwide users has nearly doubled in two years to
   2.6 billion in 2004. Specifically in the U.S., there were 165 million mobile phone subscribers by June of 2004.2

   Carat Interactive goes as far as to call wireless devices, “The most powerful medium yet. And points out that
                                                                                           ”
   “Wireless devices are the most powerful communication devices with respect to immediacy, interactivity and
   mobility, and therefore can act as the most powerful marketing communications devices, if used appropriately. 3
                                                                                                                ”

   In essence, wireless devices deliver on the true mobility that was promised by laptops. These devices are highly
   personal and are kept closely within reach regardless of time of day. Wireless devices keep us in touch with the
   rest of the world and allow us to quickly gain information on demand. When integrated with the Web, these same
   wireless devices have the ability to deliver extremely relevant content, information, offers, and promotions. The trick
   is understanding the medium well enough in order to leverage these components without abusing the trust and,
   more importantly, the permission consumers must provide in order to participate in wireless promotions.

   In order to accomplish successful wireless promotions, the record must be set straight so that there is far less
   confusion about what’s to come in the wireless future versus the myths and fantasies that are likely to steer
   promotional programs in the wrong direction.




                                                                                                                          5
   © 2004 by Bill Carmody. All Rights Reserved.
Dispelling The Wireless Myths & Fantasies

   There have been entire volumes written on how myths get started and then blur the lines with the true facts that
   surround the myths. Many of these authors have concluded that within all myths there are elements of truth. This
   is no different when it comes to examining the fabrications that surround the wireless promotions industry.



   Starbucks Discount Ringing Your Mobile Phone
   Perhaps the best myth example is the one about how walking a short distance from a Starbucks would trigger an
   automatic SMS text message to be sent to your phone offering you discount on their coffee. Carat Interactive does
   a fabulous job dispelling this myth:

              This will never be practiced for the following reasons:

              1. Starbucks would never attempt this annoying tactic, as it would receive tremendous customer
                 backlash such that would not be outweighed by increased sales from the promotion.

              2. In the same vein, Starbucks is an established brand and will not risk tarnishing itself with such
                 a controversial effort. They will, on the other hand, invest in a locator device that will allow
                 customers to locate (pull) the nearest retail shop through a locator database, ultimately
                 leveraging location-based technology.

              3. In the event that any user wanted this “service” they would opt-in by signing up with the coffee
                                                                 ,
                 shop or a provider such as Vindigo. By definition, these subscribers would be some of your
                 best customers (probably most profitable), so Starbucks would have little need to offer them a
                 discount—these customers are Starbucks regulars and will react to media such as signage.

              4. Based upon the fact that there are thousands of Starbucks retail outlets nationwide, ones
                 wireless device would be in constant notification mode when a user was driving through any
                 major metropolis. Again, this is the roll of signage.

              [Instead] Starbucks… will invest in a service to allow their customers to locate the nearest outlet,
              and have already announced the ability to take pre-orders from wireless devices. Use of pull
              marketing will allow users to determine when they are interested in interacting with the coffee
              chain on their terms.4

   And, should Starbucks attempt such a “push” marketing tactic without getting the permission of the casual user
   walking down the street, they would not only face incredible consumer backlash (because of the wireless SPAM
   issue), but legal liability as well. The CAN-SPAM Act of 2003 went into effect on January 1, 2004 and incorporated
   many of the components originally outlined in the Wireless Telephone Spam Protection Act of 2001.

   Specifically, section 14 of the CAN-SPAM Act requires the FCC, in consultation with the FTC, to promulgate rules
   to protect consumers from unwanted “mobile service commercial messages. (The Act defines “mobile service
                                                                                ”
   commercial message” as a “commercial electronic mail message that is transmitted directly to a wireless device
   that is utilized by a subscriber of commercial mobile service… in connection with such service. )5
                                                                                                 ”




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   © 2004 by Bill Carmody. All Rights Reserved.
Dispelling The Wireless Myths & Fantasies

   The truth is, with GPS embedded in your phone, you’ll have an enormous amount of location-based services
   available to you. Perhaps you’ve heard of “Flash Mobs?” This is when an email or text message is sent to a
   pre-registered group of individuals telling them a specific place to meet at a specific time to do a specific task…
   just for fun. The example I use is imagine if you joined a group of 500 people that were notified to go to New York’s
   Central Park at exactly 2:15pm on Saturday and play the city’s largest game of “Duck, Duck, Goose. Believe it or
                                                                                                         ”
   not, these things are happening right now.

   Enter enhanced wireless applications such as “Dodgeball” and “SpotMeeting” Hollywood executives might describe
                                                                                    .
   Dodgeball as “Friendster goes wireless. It takes the incredibly hot social network aspects of Friendster and adds
                                             ”
   the all important ingredient of location and “on demand” meetings. In Dodgeball, members can send messages to
   their pre-registered friends (and even friends of their friends) simply by sending a time and a location. “Roy’s
   Restaurant at 6:00 p.m. would locate any friends within a 10-block radius and alert them with a message such as,
                            ”
   “Bill is at Roy’s Restaurant. You know him through Kathleen. 6 ”

   “We call it a location-based service” says Dennis Crowly, creator of New York City-based Dodgeball in a recent inter-
                                       ,
   view in Event Marketer Magazine. The article went on to say:

              Already the wired crowd is referring to the service as MoSoSo (mobile social software). User phones
              or PDAs must be less than two years old and GPS-enabled. If available, senders can also attach pictures
              to Dodgeball alerts so recipients can see photos (or in your case, perhaps a logo) of who’s pinging them.
              Users set options when they register as to whether others can blindly contact them or if they must be
              on the sender’s buddy list to receive pings…

              Privacy is not an issue, as Dodgeball doesn’t collect or disseminate last names. The service is currently
              available in Atlanta, Austin, Boston, Chicago, Dallas/Fort Worth, Denver, Los Angeles, Miami, New York,
              Philadelphia, Portland, San Diego, San Francisco, Seattle, and Washington, DC.7

   SpotMeeting is similar to Dodgeball, but focuses more on the dating scene. SpotMeeting CEO Chester Yeum
   explains, “SpotMeeting is a revolutionary service for singles that lets them find a date instantly, and usually within
   walking distance. Other available online dating sites are limited in their reach because they are missing the key
   ingredient—location. Many of these wireless-dating services (including Match.com) even include pictures of the
                       ”
   potential person so the impromptu blind date…well, isn’t.8

   So while the Starbucks myth is worth avoiding, it’s clear that the underlying principle of location-based, contextual
   promotions is quite appealing. Assuming, that is, that the consumer initiates the action or request and that the
   response is relevant and meaningful. Mass marketing is dead. Long live permission-based, relevant marketing.


   The Promise of the “Wireless Web” on Your Phone
   Will your phone have access to the Web? Absolutely. Will it simply be the same content only served via wireless?
   Not a chance. This is a huge misconception, and one that needs to be corrected. As stated earlier in the background
   section, the Web via wireless devices is not the Web as we know it. It can’t be for the following reasons:

              1. Screen Size – Even with the PDA hybrid phones, you’re still looking at the web through a much smaller
                 screen and in most cases with much lower resolution. Large images from the Web become impossible
                 to see through such a small screen. The original Web simply wasn’t designed with smaller hand-held
                 devices in mind.




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   © 2004 by Bill Carmody. All Rights Reserved.
Dispelling The Wireless Myths & Fantasies

              2. Bandwidth – Dial-up for your home computer was bad enough, but now trying to download large
                 amounts of data from the Web onto your phone is miserable. As more and more people get DSL or
                 Cable Modems for their homes, they won’t tolerate these incredibly slow speeds for downloading
                 content onto their phones.

              3. Not a Laptop… Yet – The phone, while looking more and more like a powerful computer in the palm
                 of your hand, still has a ways to go before it has the processing power of today’s computer. Lower
                 processing power means slower data transfers and a slower overall Web experience.

              4. Serves a Different Purpose – Most people are not doing research from their phones. People want the
                 headlines instead of the whole story. They want their account balances from their banks, but not to do
                 complete online banking (at least at the present time). The phone gives you immediate and relevant
                 information, but the “deep dives” are still going to come from the computer be it work or home.

   Let me be clear that the Web on your wireless phone doesn’t suck. I am by no means disparaging the fact that
   you can get Web access from your phone. In fact the screen resolution has improved dramatically, as has the
   overall experience since launch.

   What I am saying is that there is a separate version of the Web that has been created specifically for the mobile
   phone (and other wireless devices) and is in a constant state of evolution. This mobile Web is much less graphic
   (and copy) intense. It allows you to get the stock quotes of the companies you’re interested in and the sports
   scores of your favorite teams. You can go deeper into the content, but the top-level has been specifically designed
   to provide you with the highlights of what you need… quickly.

   The mobile Web will continue to evolve to meet the needs of advances in technology. Next generation phones
   already support a mobile version of Java and there are many rich applications that allow phones to play MP3 music
   files and even record video. Eventually, the mobile Web may feel similar to today’s PC-based Web, but we have a
   long way to go and need will ultimately drive what the mobile Web becomes.



   3G High-Speed Net Access Converting Voice to Data
   At the beginning of the new millennium, businesses were convinced that the next stage of wireless was 3G (or
   third generation high-speed Internet access technology). It was all the rage in Europe and Asia, and the U.S. was
   seen as “behind” the curve when it came to the data side of phone applications. The promise was intoxicating
   (not unlike the dot com era), and wireless carriers truly believed that the voice calling side of the wireless business
   would quickly give way to the data side.

   This had all sorts of promise for wireless marketers. If consumers used their wireless phones primarily for data
   applications versus voice, it would significantly change the dynamics of how the businesses communicated with
   their customers.

   Just as the economy was cooling down, the wireless carriers decided to focus on increasing the quality of their
   service and instead of focusing on 3G, they refined their “2.5G” technology such as GPRS. And while the data side
   of the wireless business provides incremental revenue for the wireless carriers, voice still to this day dominates the
   wireless phone market.




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   © 2004 by Bill Carmody. All Rights Reserved.
Dispelling The Wireless Myths & Fantasies

   This doesn’t mean that data applications aren’t valuable or important. It’s just a misnomer that the data side of
   wireless phones would quickly out-pace the use of voice calling on the phones.

   When asked about the future of the wireless phone applications, David Steinberg, CEO of InPhonic stated that,
   “Today, email and instant messaging are the premier data applications poised to move the wireless market.
   Integrating such widely accepted “wired” applications allows users to make a comfortable, natural progression
   toward accessing data services wirelessly. 9
                                            ”

   This is the “horseless carriage” approach used to introduce automobiles. That is, when the first cars where
   introduced, they were more widely accepted when they were explained as and referred to what was known at
   the time: a horse and buggy. The wireless data application equivalent is email and instant messaging. Once
   people understand that they can use the same applications on their phone, their comfort level with using
   data applications will increase as will their usage.

   However, it’s clearly not 3G that’s the magic bullet. Instead, the U.S. has seen WiFi technology take off, filling the initial
   void that 3G has filled in Europe and Asia. Given that WiFi is not regulated by the government the same way that 3G
   would be, it’s likely that WiFi will continue to flourish in the U.S.—possibly to a point where 3G will not make financial
   sense to the phone companies who would be required to purchase expensive licenses from the government.

   It’s unclear at this point which technology will eventually allow high-speed Internet access for wireless phones, but
   it is clear that (at least in the U.S.), it’s going to take some time before the data services of the phone out pace the
   voice calling services.


   India, China and EU as Forecasts of U.S. Market Trends
   Of all the myths with respect to wireless marketing and promotions, this one is the most understandable and, to
   some extent, excusable. There is no question that India, China and the EU are far ahead of the U.S. in terms of the
   number of wireless phones as well as the application usage of these phones. Because of the leadership position of
   these countries in the wireless space, it’s understandable why so many companies used these growth markets as
   future (predictive) models for the U.S. market.

   However, the mistakes are associated with the very distinct technological as well as sociological differences. To
   understand the absolute boom of the wireless market in these countries, as well as their corresponding adoption
   of various technologies, you must first understand the significant differences to the U.S. market:

              1. Lack of Legacy Infrastructure – In the U.S., the penetration of the “wired” or landline telephone is
                 estimated to be 90% or greater. That is, the vast majority of people who want a telephone in their
                 homes have one. This is nowhere near the same situation in China or India. In these countries, the vast
                 majority of the population have limited to no access to a “wired” phone, so the wireless phone is their
                 first phone.

                 In Europe, the “wired” phone challenges for credit card authorization and verification at retail were so bad
                 that out of necessity, applications such as smart cards and RFID devices were launched much earlier than
                 in the U.S. That is, merchants demanded faster and more reliable means of getting credit card authoriza-
                 tions than using dial-up phone lines. This is why smart cards (i.e. chips embedded onto credit cards) were
                 embraced much earlier than in the U.S. and to this day are much more successful in Europe.




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   © 2004 by Bill Carmody. All Rights Reserved.
Dispelling The Wireless Myths & Fantasies

              2. Wireless Phone as Primary Device – In India and China, much of the population sees the wireless
                 phone as their primary device to “stay connected. In these countries the wireless phone is the primary
                                                                  ”
                 device being used to access data and receive direct response information from marketers.

              3. 3G is a Reality – Unlike the U.S., China and much of Europe already has the third generation wireless
                 phone technology, which allows high-speed Internet connections for wireless devices.

              4. Caller Pays – Here a novel idea: What if the person making the call or sending the text message is the
                 only one paying for the call or message? That’s how it is overseas, but in the U.S., both parties pay. This
                 added expense must be taken into account when marketing programs are conceived.

              5. Compatible Networks – Do you remember when you needed an AOL account to speak to people on
                 AOL and another account from Prodigy to speak to them? If this was before your time, then just think
                 Instant Message. Your AOL screen name can’t talk to Yahoo! or MSN. In many respects, this is how it
                 is in the U.S. between carriers. Overseas, they have agreed upon standards and no difficulty deploying
                 applications across carriers. Not true in the U.S.

              6. Social and Cultural Differences – While the world is getting smaller by the year, there are still very
                 distinct social and cultural differences that do not transfer to the U.S. The way in which the wireless
                 phones are used by their nature is an extension of these social and cultural differences.

   For these reasons, assumptions must be challenged when looking at forecasts from these countries and comparing
   them to the U.S. market. The issue is not necessarily that the ideas from these countries won’t work in the U.S.; it’s
   just that these ideas must be filtered through the technological and cultural differences to ensure assumptions are
   correct. Assuming that because 3G was popular in China and Europe it would be the same in the U.S. was clearly
   false—at least in the timeframes being considered. The same goes for the use of the data side of the wireless phone.
   It’s not that we won’t eventually come to a similar place, but we have a number of steps before we get there.


   Pushing Email Offers to Wireless Phones
   In some respects, this myth is a subset of the previous one. The good news about the previous myth is that it also
   explains why today’s SPAMers can’t push their SPAM onto your wireless phone. The idea that you can deploy email
   marketing campaigns to all of your wireless customers is false; at least not with the serious help of a wireless
   aggregator and, in most cases, the approval of various wireless carriers.

   The reason is that in the U.S., the wireless carriers are operating in what is referred to as a “closed network. ”
   That is, each carrier has the ability to control what’s happening inside their network. In a recent Wall Street Journal
   article, Jeffrey Nelson, a spokesman for Verizon Wireless put it this way, “Once something is knocking at the door
   of our network, we can let it in or not. On the landline, the messages just travel. There isn’t a gate, if you will. 10
                                                                                                                      ”

   The article went on to describe how carriers can impose SMS message volume limits, which help weed out
   SPAMers. That is, until the networks are no longer closed, and then we face the exact same issues as our
   overseas colleagues.




                                                                                                                           10
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   As 2004 winds down, there have been a number of advancements in wireless technology, legal legislation and the
   overall approach to leveraging wireless promotions in the overall marketing mix. In this section, the focus is on the
   macro trends—that is, the broad, sweeping trends—that directly affect the kinds of wireless promotions that are
   driving the promotions industry.

   These top trends are the ones that promotional marketers need to be aware of in order to be able to launch and
   manage wireless promotions effectively.



   Wireless SPAM & Related Legislation
   When comparing one of the hottest trends in wireless promotion to the Internet, the issue of Permission and
   Privacy will sound quite familiar; however, there is a brand new financial twist that makes Wireless SPAM a much
   more serious issue.

   Imagine if you had to pay ten cents for every piece of SPAM email you received in your inbox. I currently average
   about 100 to 200 SPAM emails per day. That translates into $10 to $20 per day, or $3,650 to $7,300 a year! With this
   example, you can see why not only do all the same SPAM issues from email marketing apply, but why they
   are financially much more critical to solve.

   In October of 2002, an iBrief aptly titled, “The Future of Wireless SPAM” was released from Duke Law & Technology
                                                                           ,
   Review that illustrated just how bad the wireless SPAM issues were in Japan:

              It is estimated that of the 950 million emails exchanged daily in Japan, 84 percent are sent out at
              random. At a cost to DoCoMo [Japan’s largest cellular provider] of over $200 million, both the
              company and the industry need a solution.

              Japanese Parliament enacted two anit-spam bills in April 2002. On July 1, cellular consumers and
              providers in Japan may have found a lasting solution when the two new laws regulating wireless
              commercial solicitations—cell phone spam—came into effect… It provides cellular users with an
              opt-out option, requiring senders of email ads to attach messages telling receivers how to reject
              future ads.11

   Similarly to Japan, the European Union’s Parliament passed the Directive for the Protection of Personal Data and
   Privacy in the E-communications Sector. However, unlike Japan’s bill, the EU adopted an opt-in approach as part of
   their legislation. That is, marketers must get permission to send advertisements before they send them, whereas in
   Japan marketers are not required to get permission ahead of sending messages just as long as they honor requests
   to be removed from future communications.

   In the U.S., the problem of wireless SPAM is not nearly as great… so far. The Duke article explained the issue
   this way:

              Cell phone spam [in the U.S.] is hindered by the same limits in technology, in particular the differ-
              ent technology standards, which have rendered American cell phones antiquated as compared to
              phones in Asia and Japan. Unlike the United States, Japanese and European carriers, as required
              by their governments, have adopted uniform technology standards.12




                                                                                                                      11
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   As stated earlier in the “Pushing Email Offers to Wireless Phones” section, the reason is that in the U.S., the
   wireless carriers are operating in what is referred to as a “closed network. That is, each carrier has the ability to
                                                                                  ”
   control what’s happening inside their network. In a recent Wall Street Journal article, Jeffrey Nelson, a spokesman
   for Verizon Wireless put it this way: “Once something is knocking at the door of our network, we can let it in or not.
   On the landline, the messages just travel. There isn’t a gate, if you will. 13
                                                                             ”

   The article went on to describe how carriers can impose SMS message volume limits, which help weed out
   SPAMers. That is, until the networks are no longer closed, and then we face the exact same issues as our
   overseas colleagues.

   “Every campaign in the U.S. is opt-out enabled” says Paul Cushman, Director of Business Development at m-Qube.
                                                    ,
   “Being a late adopter has enabled the U.S. to learn from the mistakes of others and create policies that solve these
   problems in advance. For example, blanket opt out is part of the Code of Conduct of the Mobile Marketing
   Association. Mr. Cushman went on to explain that the process of setting up short codes has built in anti-SPAM pro-
               ”
   tection as well. “The Common Short Code process and the extablishment of aggregators by the carriers to ensure
   that they have visibility and approval of campaigns before they go live. 14
                                                                          ”

   Fortunately for consumers and marketers alike, the CAN-SPAM Act of 2003 went into effect on January 1, 2004
   and incorporated many of the components originally outlined in the Wireless Telephone Spam Protection Act
   of 2001.

   Specifically, section 14 of the CAN-SPAM Act requires the FCC, in consultation with the FTC, to promulgate rules
   to protect consumers from unwanted “mobile service commercial messages. (The Act defines “mobile service
                                                                                ”
   commercial message” as a “commercial electronic mail message that is transmitted directly to a wireless device
   that is utilized by a subscriber of commercial mobile service…in connection with such service. )15
                                                                                                ”

   Smart promotional marketers should not need this kind of legislation to understand that unsolicited messages—be
   they SMS text or email—are not welcomed by their consumers. Without getting the express and explicit permission
   of consumers, wireless promotions are doomed to fail. Moreover, because of the cost implications, consumer
   advocacy groups are likely to ensure that unwanted wireless SPAM will not go unnoticed—this means negative
   publicity at the very least and could include significant fines and a class action lawsuit.

   The underlying message here is: think twice before sending out messages to your consumer’s wireless phone.
   Which brings us to the next wireless promotion trend.


   Pull vs. Push Promotional Messages
   Mass media is dead. Proctor & Gamble was the first to say this publicly, and most recently Larry Light, Global
   Chief Marketing Officer of McDonald’s made this proclamation at the AdWatch: Outlook 2004 conference and was
   featured on the front-page article in Ad Age on June 21, 2004. Fortune 500 companies are no longer satisfied with
   the declining returns of mass media, nor the antiquated systems used to track, report, and analyze their marketing
   and media spend.




                                                                                                                      12
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   Think of Push marketing as outbound marketing (company pushing messages to consumers), while Pull marketing
   is inbound (consumers requesting information from the company). Push messages are defined as a single, mass-
   marketing message that is intended to interrupt consumers from what they were intending to do and deliver a
   marketing message. Pull marketing, by contract, is defined as contextual, need-based messages that are delivered
   to consumers only when they are requested.

   In the early days of television, Push marketing made the most logical sense. In television and radio, it’s the 15, 30,
   or 60-second spots that interrupts consumers from the program they were watching or listening. The objective of
   Push marketing is to literally interrupt consumers from what they were intending to do and push out an advertising
   message to convince them to buy a company’s product or service. Push marketing will never go away completely,
   however, because of the significant volume of noise that is currently out in the marketplace, the trend is for the
   target audience to ignore these messages.

   Pull marketing takes a different approach. Pull marketing anticipates the interests, needs and desires of targeted
   consumers and crafts marketing messages and offers that are likely to appeal to consumers who take the time to
   request the information. An example of Pull marketing is a consumer’s ability to go online or call an 800 number to
   check the balance of their checking account or the status of their airplane flight, or to get a recipe for dinner. The
   company’s marketing messages are integrated into the specific needs of their consumers.

   Perhaps the easiest distinction between Push versus Pull marketing messages are in the context of online
   advertising. An example of Push marketing would be the standard banner advertising that attempts to divert you
   from what you planned on doing online to what the marketer would like you to do.

   An example of Pull marketing would be paid search results on Google or Overature that are contextual marketing
   messages to the very thing about which you went online to find out more information. Rather than trying to
   interrupt, Pull marketing is contextual to what the consumer is already interested in doing and offers and easy
   way to provide a solution to their problem.

   In the wireless world, this issue becomes of prime importance. Push messages in the context of wireless would be
   things like wireless alerts, SMS message announcements, and outbound telemarketing. As it currently stands in the
   U.S., consumers bear the cost of these potentially unwanted messages. As a result, consumers are unlikely to put
   up with paying for Push marketing that interrupts them from what they were doing.

   By definition, consumers will welcome pull messages. This is because they only receive the marketing messages
   they specifically request. “Would you like to know if your plane is running late? Then send a SMS text message to
   XXXXX and we’ll notify you of any delays. United Airlines has already started this program and the consumers who
                                             ”
   sign up for these alerts swear by them. What better way to reinforce brand loyalty than by letting your passengers
   know well in advance that there’s likely to be a delay?

   Banks can reduce the number of calls they receive by allowing you to text in your account number and get back the
   balance. The same goes for your credit card company. CPG companies can use text messaging to offer discounts on
   future purchases. “Want to get a coupon off your next purchase? Send a text message to XXXXXX and we’ll send
   you the discount.
                   ”

   The idea is that companies can use their existing product packaging, bill statements, and other assets that are
   already widely accepted by their customers to build loyalty and future purchase behavior. If new customers are
   needed, pass along offers can be developed so the core audience can provide offers of real value to their friends.




                                                                                                                       13
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   Word of mouth has always been a powerful component of marketing. The challenge has been how to encourage,
   track and measure this aspect. In the online world this challenge was initially solved through tell-a-friend email
   components, and then evolved further into affiliate marketing, incentives and rewards programs. The same will
   hold true to wireless marketing given that the offers are compelling and worth talking about.

   The bottom line is that Push marketing messages will be fought by your customers because they have to pay for
   them. Pull marketing messages, however, can create a much more intimate, loyal, and “on demand” relationship
   with your customers. Just as in the online world, your customers must always be in control of the relationship, and
   this brings us to the next section.


   CMR vs. CRM
   From the beginning of the wireless marketing revolution, there has continued to be the debate over, “Who owns
   the customer?” Do the service carriers such as AT&T Wireless, Cingular, T-Mobile, Nextel, Sprint, and Verizon own
   the customer? Or do the hand set manufactures such as Ericsson, Palm, Motorola, Nokia, Samsung, and Sony
   own the customer? Or could it be the content partners such as AOL Time Warner that own the customer just on
   a different device?

   The answer should be obvious: None of the above! If you truly believe in permission marketing, then you should
   know that it is the customer him or herself, not any particular company, that owns the relationship. At any point, the
   customer can opt-out of the relationship and start fresh with a competitor. The customer has choice and in this day
   and age, they will exercise their options to find a solution that works best for them.

   This leads us to an invaluable insight from Carat Interactive. We need to change the “CRM” to the “CMR” Forget  .
   “Customer Relationship Management” and start thinking in terms of the “Customer Manages the Relationship. 16         ”
   It’s not that CRM isn’t valuable. It’s definitely a step in the right direction, but to succeed in wireless promotions,
   we need to be dyslexic with this acronym. We need to begin with the idea that the consumer, not the company,
   is in the driver seat and manages the relationship. This is the reality in all marketing, but becomes painfully apparent
   in wireless programs that do not follow this golden rule.

   With most of your customers having a wireless phone with them wherever they go, CMR becomes a very intriguing
   idea. Consumers have the ability to let you know what they want, when they want it, and even where they want it.
   They are always “on” with their wireless devices and so this can be the ultimate tool for cultivating the relationship.
   The key is to have the right people and systems in place to allow for a two-way communications medium (not just
   the Push, mass-marketing messages).

   “Amazon.com created a very good business using purchase behavior, emails and recommendations to increase
   repeat traffic and increase sale frequency and amount” noted Paul Cushman, Director of New Business at m-Qube.
                                                           ,
   “Without mobile, this would be nearly impossible to do in the retail world. However, with mobile devices, retailers
   can fill this gap, enabling them to take advantage of the successful online strategies in the real world. For more on
                                                                                                           ”
   how this is done, we move to the next section.




                                                                                                                       14
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   Wireless Offers at Retail
   So far we’ve reviewed the issues with wireless SPAM, identified the types of messages to be utilized (i.e. Pull vs.
   Push), and identified the fact that the consumer needs to be in control of the relationship (i.e. CMR). Now it’s time
   to take a look at how all these components come together in the retail environment and get a sneak peak at what’s
   to come.

   Today, there are several companies that are already testing the use of wireless phones at retail. In September of
   2002, m-Qube pioneered mobile couponing in the U.S. and has since formed a relationship with NCR. m-Qube in
   partnership with NCR, allows marketers to deliver custom coupons to consumers’ wireless phones via existing
   retailer loyalty platforms. m-Qube has run successful pilot programs already at the Cambridge-Side Galleria in
   Boston, with retailers and QSRs such as Gap, J Crew, Guess, Steve Madden, Borders, Dunkin’ Donuts, and Taco
   Bell all participating.

   Paul Cushman, Director of Business Development at m-Qube explains that, “This gives us the capability to provide
   an individually coded and trackable coupon to a mobile device that can be redeemed by showing the phone at the
   POS, where the clerk enters the code and we then track results from the back end. Mr. Cushman predicts that
                                                                                    ”
   “2005 will be the break out year for couponing” and eluded to a nationwide program for the 2005 holiday timeframe
   which he believes could well be the largest Mobile Marketing program the industry has seen to date.

   The key is that companies such as NCR see the power (and the future) of wireless marketing and promotions. By
   having NCR integrate unique codes into the existing back-end infrastructure, companies such as m-Qube can deliver
   unique codes to individuals who send a request via text message. It is then up to the manufacturer if that unique
   code will be allowed to be forwarded to friends or not.

   For example, let’s say that you want to move more pairs of jeans at the Gap. You decide that, as part of a Back to
   School program, you’re offering a free pair of jeans with every $50 purchase at the Gap. You purchase billboards in
   the downtown Boston area and tell people that to get this offer, they need to text “Jeans” to XXXXXX short code.
   Consumers who send the text message get back the offer details with their own unique code.

   Now, if you want to control the redemption of this offer, you can make it such that the unique code is only valid for
   the single purchase. However, if you’re trying to get as many people as possible to come to the store and shop, you
   can allow consumers to send this electronic offer to their friends.

   The beauty of having this electronic offer is all of the detailed reporting to which you now have access. Knowing the
   estimated number of impressions from the billboard, you can determine the opt-in rate based on the number of
   people who request the offer. You can further measure the redemption rate based on the number of people who
   redeem the offer. If you’re measuring pass-along value, you can further measure the number of friends that were
   forwarded this offer and redeemed. And while this is the most popular scenario at present, there are others as well.

   DRM Labs has an interesting solution using your credit card to redeem the offer on the backend, rather than an
   offer code in store at the checkout counter. In their version, you request that offers be delivered via text message
   and register your credit card number with the wireless carrier. After the offer is delivered to the mobile phone,
   rather than showing your phone with the unique code to the retailer, you simply shop the way you normally do,
   using your pre-designated credit card. You pay full price at the retailer, but after you make the purchase, you receive
   a text message confirming that you received the discount on the backend. That is, your credit card statement specif-
   ically identifies the full purchase amount at the retailer, and then credits you the discounted amount … right on your
   credit card statement. “There are advantages to this solution, according to Jeff Mankoff, President of DRM Labs,
                                                                     ”
   “There are no retailer software and hardware POS integration costs and redeeming with a credit card is consistent



                                                                                                                      15
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

   with how consumer’s shop today. By redeeming a mobile coupon with a credit card versus a mobile phone display,
   we eliminate consumer and sales clerk fraud. Also, the DRM Labs model is wireless carrier centric, in that the cus-
   tomer opts in and registers at the carrier. And it is the carrier (not the advertiser) that delivers the offers. Thus, the
   carrier acts as the gatekeeper and avoids any appearance of Spam to the mobile phone.         ”

   While the technologies supporting these efforts will evolve over time, the bottom line is that the marriage of retail
   and wireless couldn’t be a more perfect match. Yes, there are and will be some technical issues that will be worked
   out over time, but the reality is clear as day. Wireless integrated with retail programs are here to stay.


   Enhancement of All Other Disciplines
   The connection between wireless phones and retail is by far the most exciting to those of us in sales promotion.
   At the end of the day, ROI is measured by the number of products sold as a direct result of our efforts. With
   wireless promotions, the same ROI capabilities from the online world are brought down to the mobile phone level,
   and this should be very exciting for promotional marketers.

   Driving sales at retail, however, is not the exclusive objective of every promotional marketer. This section identifies
   some of the other exciting tools that can now be leveraged using consumer’s wireless phones.

   It should be noted here that wireless promotions by themselves are unlikely to shatter any marketing or sales
   objectives. As with any promotional marketing program, integration is essential. The better you integrate your
   wireless marketing efforts into the overall marketing mix, the better your results.

              1. Activating Sponsorships: For marketers who are looking to find creative ways to extend the life
                 of their events and make their sponsorships pay, wireless promotions offer up some very unique
                 advantages including: (A) Photo Blogging, (B) Fan Polling / Voting, (C) Distribution of Electronic Offers,
                 (D) Lead Generation, and (E) Content Purchases.

                   A. Photo Blogging: This is an ingenious way to allow consumers to take their photo-enabled wireless
                      phones and tell their story at your events. By allowing your consumers to post their pictures from
                      your event, you not only give these consumers a reason to go back to your website, but also create
                      buzz and excitement at the event. If the event is hitting more than one market, photo blogging will
                      give the up and coming markets a sneak preview of what’s to come.

                   B. Fan Polling / Voting: Want to make your sponsorship more interactive and provide real-time feed-
                      back to your company? Fan polling allows consumers to tell you how they feel—what they like,
                      dislike, and things they’d like to see in the future. Voting allows them to participate and have a say
                      in the course of the events. Start thinking of wireless phones as mini polling pads that people carry
                      with them at all times. Make it fun and provide real-time feedback and they’ll be hooked.

                   C. Distribution of Electronic Offers: Got a product or service to sell at the event, but need more
                      time? Peak your consumer’s interest and have them text you for the details. Your electronic coupon
                      can send people back to a website or simply to the closest participating retail outlet to continue the
                      sales process.

                   D. Lead Generation: Truly a no-brainer. Provide something of value and consumers will gladly let you
                      know if they’re interested or not. The more you’re willing to offer up, the more leads you can pull
                      down from these events. Make your offers relevant to the sponsorship at the event and consumers
                      will be in the right frame of mind to take action—right there on the spot with their wireless phones.




                                                                                                                              16
   © 2004 by Bill Carmody. All Rights Reserved.
Top Five Hottest Promotion Trends in Wireless

                       E. Content Purchases: For the lead sponsors, liquidating the sponsorship should be as easy as
                          getting the online and wireless rights to sell meaningful content at the event and after the event
                          has concluded. From ring tones to games to wallpaper to other wireless content, leverage the
                          asset you’ve purchased and reap the rewards wirelessly. AT&T Wireless, for example, was able
                          to liquidate part of their Olympics sponsorship by selling Olympic ring tones, screen savers and
                          other content downloads (not to mention signing up new subscribers via exclusive Olympic
                          phone offers). Samsung was likewise able to liquidate part of its Warped Tour sponsorship by
                          securing the digital wireless rights to downloadable music, ring tones, screen savers, games, and
                          other content.

              2. Extending Events: With all of the above examples, it should be clear that there are many ways to
                 extend the life of your events using a combination of wireless and online technology. From photo
                 blogging to exclusive offers, it should be easy to think of interesting ways to move people from the
                 event to your website and/or retail location and continue to sales cycle.

              3. Driving Online to Offline: The reverse is also true. Creating an appealing online experience will help
                 motivate your consumers to go offline—be it to your events or retail promotions. If your event is
                 newsworthy, you can use wireless alerts to keep people posted on the most current information.
                 Sign up online and receive updates wirelessly.

              4. New Direct Response Vehicle: There will most likely be a long-term future with Business Reply Cards
                 (BRCs). That said, think of the ability to send text messages as a new direct response vehicle in new
                 advertising locations. With a SMS short code, why not make your billboards a direct response vehicle.
                 Or, for that matter, your radio (or to a lesser extend, your television) ads? With wireless, consumers are
                 always on. If you keep the offer compelling and the message simple, you can drive response from
                 media you previously never thought possible. The direct marketing companies should be thrilled with
                 this advancement in technology.

              5. Interactive Merchandise: “Take One” now becomes “Text for One” I’m not suggesting that paper goes
                                                                                        .
                 away entirely, just that there’s an easier way to “take it with you” that doesn’t leave unwanted clutter.
                 POS at retail is looking to drive purchase, but sometimes consumers need some time to think things
                 over. When that happens, wireless provides an interesting way to send the message.

              6. Real-Time Loyalty: This can literally mean anything you want it to. From the most traditional “frequent
                 flyer mileage” programs getting a wireless facelift with real-time access to account balances to brand
                 new and exciting ways to track and reward loyalty. Think “digital punch cards” where the phone acts as
                 card. However you define loyalty, chances are there are several ways to enhance customer loyalty with
                 wireless technology. From faster access to information to rewards requests, there are many ways to
                 go here.

              7. Enhancement of Collect & Win Games: For McDonald’s why not run “Wireless Monopoly” where all ,
                 the game pieces are specially coded and playable via a wireless phone? The codes already exist, so it
                 really comes down to creating a digital game board to store the game pieces. To that end, many of the
                 instant win prizes could be digital content such as ring tones, MP3 music files, games, etc.

   The bottom line is that just like online promotions enhanced all of the traditional promotional marking disciplines,so
   too will wireless promotions. They are not the “end-all-be-all” to promotional marketing, but they do provide some
   very unique ways for consumers to participate and for marketers to track real-time results.

   The next time you’re thinking about designing a promotional marketing program, ask yourself, “How could I add a
   wireless marketing component?” You’ll be surprised how quickly and easily it will come to you. And if you’re still
   struggling, send an email to bill@billcarmody.com and I’ll help you brainstorm.



                                                                                                                          17
   © 2004 by Bill Carmody. All Rights Reserved.
Leveraging Wireless Promos for ROI Analysis

   Return on Investment (ROI) in theory is incredibly simple, but in practice can be challenging if you can’t isolate the
   right information. Many companies have relied on the lift in sales data to provide the key market indicator as to the
   success (or failure) of a promotion. The challenge with this approach is that often times marketers have multiple
   programs working to stimulate demand. How do you know if it’s actually the promotion that’s ringing the cash
   register or something else?

   Wireless promotions may not completely solve this problem, but when used correctly they can certainly take the
   proper steps in the right direction. The wireless promotions dimension takes all the valuable insights learned from
   the online space and adds the missing component of mobility. That is, marketers could track how their online
   programs were doing, but it wasn’t always practical to assume that the target audience had access to a laptop
   while: (A) Watching TV, (B) Listening to the radio, (C) Reading a magazine, (D) Viewing a billboard, etc.

   With wireless promotions, we can now take the next step. We can keep all of the measurement tools developed in
   the online world and apply them to the “real world. The same electronic coupon that was delivered via email can
                                                     ”
   now be delivered to a wireless phone. The difference is, getting this coupon “on demand” in the “real world” means
   a higher likelihood of redemption. Why? Because the request for the offer can be made in route or even at the retail
   store location.

   Promotions, especially online promotions, have often been used as the glue that holds multiple mediums together.
   With a central offer, the same message can be delivered across all media and drive back to retail, online, the phone
   or to the mail. What the wireless factor does is make it incredibly easy to track response that happens via any
   and all of these components. Having separate short codes that extend the same offer is the equivalent to having
   separate URLs that track where consumers came from. The difference is that they no longer have to be near a
   computer or go online to participate.

   Measuring ROI effectively means tracking all of the right components of the promotion to ensure that the campaign
   was run as effectively as possible and provided a positive rate of return. Wireless promotions are not a “magic
   bullet” but they do provide us with new and interesting ways to oversee the progress of a promotion. With each
         ,
   message sent, each request, and each coupon redeemed, marketers are getting much more real-time information
   and have the ability to make the necessary adjustments to ensure success.




                                                                                                                       18
   © 2004 by Bill Carmody. All Rights Reserved.
Recommended Resources

  There are a number of players out there in the mobile marketing space, and all great people I might add. Below is a
  list of resources that I have pulled together from past wireless promotion programs. While this list is by no means
  comprehensive, it’s a really good place to start. As always, if you have any questions, please send an email to
  bill@billcarmody.com.



             • AT&T Wireless (Wireless Carrier Partner) Ted Mandelkorn, Consumer Promotions, SMS Offer Portfolio,
               (425) 580-5607 ted.mandelkorn@attws.com
                             ,

             • Carat Interactive (Wireless Media / Advertising) Chris Arnes, (415) 227-2122, Chris.Arens@carat.com

             • Cingular (Wireless Carrier Partner) Dave Garver, (404) 236-6000, dave.graver@cingular.com

             • DRM Labs (Wireless Coupon Provider) Jeff Mankoff, (214) 891-1800, jmankoff@drmlabs.com

             • InfoSpace Mobile (Wireless Content & Technology) Tony Wootton, (310) 481-6941,
               tony.wootton@infospace.com

             • Loeb & Loeb (Wireless Legal) Ken Florin, (212) 407- 4966, kflorin@loeb.com

             • Mobliss (Wireless Content & Technology) Brent Brookler (206) 332-1749, brent@mobliss.com

             • m-Qube (Mobile Marketing & Content Provider) Paul Cushman, Director of Business Development,
               (650) 234-8210, pcushman@m-Qube.com

             • Navio (Wireless Content & Technology) Ron Martinez, Chief Product Officer, (408) 864-7979 ext. 123,
               ron@navio.com

             • Proteus (Backend Wireless Technology Provider) Craig Shapiro, (415) 773-1475, craig@proteus.com

             • Samsung (Handset Manufacturer) T. J. Person, Business Development Manager, Wireless Terminals,
               (972) 761-7255, t.person@samsung.com

             • SanDisk (Flash Memory Partner) Dave Smurthwaite, Mobile Product Marketing Manger, (408) 548-0183,
               dsmurthwaite@sandisk.com

             • Seismicom (Brand Promotions Agency) Bill Carmody, Chief Marketing Officer, (415) 864-4000 ext. 103,
               bill@seismicom.com




                                                                                                                     19
  © 2004 by Bill Carmody. All Rights Reserved.
End Notes

        Paul Saffo, “New Fronts in the Communications Revolution” included in the book, What’s Next: Exploring The New
   1


        Terrain for Business by Eamonn Kelly, Peter Leyden, and Members of the Global Business Network, Perseus
        Publishing, September 2002, page 170.
        Kathleen M. Joyce, “Missing the Medium” in PROMO Magazine, August 2004, page 37.
   2



        Carat Interactive, “The Future of Wireless Marketing” White Paper, 2002, page 4.
   3



        Ibid, page 7.
   4



        Ken Florin of Loeb & Loeb in an email dated September 20, 2004.
   5



        Colin Gibbs, “Clubbing, SMS Style: From Virtual Girlfriends to Real Ones, Mobility Adds Social Twists” in
   6


        RCR Wireless News, September 6, 2004, page 32.
        Dan Hanover, “Palm Pilots: Dodgeball makes promoting events with email blasts seem oh so low-tech” Event
                                                                                                               ,
   7


        Marketer Magazine, August / September 2004, page 9-10. (Author’s Note: You’ll find a really cute picture of my
        newborn son on page 6).
        Ibid.
   8



        David A. Steinberg, “The future’s in the phone: the wireless world is still all about voice – CEO Perspective” in
   9


        Wireless Business & Technology, July 2003.
        Riva Richmond, “Pre-Emptive Strike: Cellphone spam isn’t a huge problem yet. And regulators want to make sure
   10


        it never is., Wall Street Journal, September 13, 2004, page R13.
                   ”
        “The Future of Wireless SPAM” an iBrief by Duke Law and Technology Review 0021, October 28, 2002.
                                    ,
   11



        Ibid.
   12



        Riva Richmond, “Pre-Emptive Strike: Cellphone spam isn’t a huge problem yet. And regulators want to make sure
   13


        it never is., Wall Street Journal, September 13, 2004, page R13.
                   ”
        For more information about the Common Short Code process, visit http://www.usshortcodes.com.
   14



        Ken Florin of Loeb & Loeb in an email dated September 20, 2004. Note: If you’d like more information on this
   15


        topic, please send an email to bill@billcarmody.com and I can send you a detailed summary along with links of
        where to go find out more information.
        Carat Interactive, “The Future of Wireless Marketing” White Paper, 2002, page 9.
   16




                                                                                                                            20
   © 2004 by Bill Carmody. All Rights Reserved.

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Wireless Promotions White Paper

  • 1. Wireless Promotions: Future vs. Fantasy Bill Carmody Chief Marketing Officer Seismicom 939 Port Washington Boulevard, Suite 3 Port Washington, NY 11050 (646) 867 – 2252 bill@billcarmody.com
  • 2. Table of Contents Executive Summary ................................................................................................................................3 Background ..................................................................................................................................................5 Dispelling The Wireless Myths & Related Fantasies ..........................................................6 1.Starbucks Discount Ringing Your Mobile Phone ..............................................................................6 2. The Promise of the quot;Wireless Webquot; on your Phone........................................................................7 3. 3G High-Speed Net Access Converting Voice to Data....................................................................8 4. India, China and EU as Forecasts of U.S. Market Trends................................................................9 5. Pushing Email Offers to Wireless Phones ....................................................................................10 Top Five Hottest Promotion Trends in Wireless ....................................................................11 1. Wireless SPAM & Related Legislation..........................................................................................11 2. Pull vs. Push Promotional Messages ............................................................................................12 3. CMR vs. CRM ................................................................................................................................14 4. Wireless Offers at Retail ..............................................................................................................15 5. Enhancement of All Other Disciplines ..........................................................................................16 Leveraging Wireless Promotions For ROI Analysis ..............................................................18 Recommended Resources..................................................................................................................19 End Notes ..................................................................................................................................................20 © 2004 by Bill Carmody. All Rights Reserved.
  • 3. Executive Summary You’ve been lied to, and not for the first time. You’ve been swept into the wireless hype and are searching for a future that doesn’t exist. You’ve heard that in the future, a person will walk by a Starbucks and their phone will go off. The beeping from the phone will reveal a discount that the consumer can take into the store for an immediate purchase. It’s not going to happen for a number of reasons that this white paper will explain. Nor will you be able to “Surf the Web” from the phone the same way you do now on your computer. For that matter, you’re likely to use the voice side of your phone much more frequently than the data side. Oh yeah, and that rumor you heard about India, China and the European Union being an accurate forecaster of U.S. trends? Think again. Like all myths there are elements of truth to everything stated above. The truth is, with GPS embedded in your phone, you’ll have an enormous amount of location-based services available to you. The Web is, in fact, accessible from your phone—it’s just not the same Web you’re used to on your laptop. Data services are on the rise, but the use of voice is still the dominant service here in the U.S. Overseas, there are quite a number of interesting ideas that will evolve and morph themselves into something useful in the U.S.; however, the underlying technology, infrastructure, business interests and even societal differences will ensure different outcomes in the U.S. Sorry to be the one to break all this to you, but someone has to do it if we ever want to realize the true wireless promotions potential and to succeed. So what does the future look like? It’s actually very exciting and in many ways reminiscent of the dot com era—for good and for bad. The top futurists all see wireless technology having significant impact on the way we do business. While there are definitely still some technical issues to be worked out, the future is very bright. If you experienced all the pain (and hopefully profit) with respect to how the Internet changed your business, then many of the core elements contained herein will sound somewhat familiar. At present, the central issues for wireless promotions are no different than the central issues for the Web: Permission and Privacy. Imagine if you had to pay ten cents for every piece of SPAM email you received in your inbox. I currently average about 100 to 200 SPAM emails per day. That translates into $10 to $20 per day, or $3,650 to $7 ,300 a year! With this example, you can see why not only do all the same SPAM issues from email marketing apply, but why they are financially much more critical to solve. To smart marketers, however, this should be a no-brainer. If you abuse the trust of your customers (offline, online or via wireless), you’re going to lose them… period. But with wireless, there are some new things to think about. “Pull” versus “Push” for example, will force marketers to rethink the kinds of wireless strategies they employ. , “Push” programs follow the traditional “one to many” mass marketing noise we’ve all been trying to get past. It’s where a marketer creates a “one size fits all” message and figures out a way to shove it down the customer’s throats. “Pull” messages, on the other hand, are much more highly relevant to the consumer and, more to the point, the situation in which they find themselves. A “Pull” message would be one whereby a consumer requests the nearest retail location to where they are currently standing. Or, a request for an account balance, offer, entry, or any other promotional tactic you can think of. The consumer initiates the request and, if the marketer has done their homework, they can easily provide what the consumer is looking for. 3 © 2004 by Bill Carmody. All Rights Reserved.
  • 4. Executive Summary This leads us to an invaluable insight from Carat Interactive. We need to change the “CRM” to the “CMR” Forget . “Customer Relationship Management” and start thinking in terms of the “Customer Manages the Relationship. ” It’s not that CRM isn’t valuable. It’s definitely a step in the right direction, but to succeed in wireless promotions, we need to be dyslexic with this acronym. We need to begin with the idea that the consumer, not the marketer, is in the driver seat and manages the relationship. This is the reality in all marketing, but becomes painfully apparent in wireless programs that do not follow this golden rule. From there, we rally around the marvels of what we can currently do in the retail environment and get a sneak peak at what’s to come. The bottom line is that the marriage of retail and wireless couldn’t be a more perfect match. Yes, there are still some technical issues that will be worked out over time, but the reality is clear as day. Retail programs, integrated with wireless components are here to stay. To that end, wireless promotions should be viewed in the context of the larger marketing mix. That is, just like any promotion that is integrated into multiple mediums and disciplines, wireless promotions are most successful when they are integrated. More to the point, wireless promotions can enhance the other promotional marketing disciplines such as Sponsorships, Events, Online, Retail, and Direct Response. Because of the ubiquity of the wireless device, consumers can become more engaged and respond to the kinds of offers and promotions that appeal to them. Adding wireless components to your existing promotional marketing programs can further help you track Return on Investment (ROI). This is particularly true with the drive to retail programs, but also applies to e-commerce promotions and any promotion that leverages tracking codes as part of the response mechanism. This even works well in the sponsorship world. AT&T Wireless, for example, was able to liquidate part of their Olympics sponsorship by selling Olympic ring tones, screen savers and other content downloads (not to mention signing up new subscribers via exclusive Olympic phone offers).The more the wireless phone promotion is connected to purchase experience, the more directly you can track and analyze thepromotion’s ROI. By the conclusion of this white paper, it should be evident that by integrating wireless marketing into your next promotion, you will be able to quickly create (and cost effectively deliver) complementary offers that will increase your response rates. Mobile programs will further allow you to test various offers and strategies in a timely and cost-effective manner. As with any “first mover” promotional marketing programs, the marketers that work towards building the future of promotional marketing programs today are likely to gain market share and a leg up against their competitors. Recommended resources are included so that you can have a good idea of the kinds of companies that are currently available to promotional marketers. Each of these companies have their own thoughts about the future of wireless promotions and are likely to be interested in answering any further questions you may have. 4 © 2004 by Bill Carmody. All Rights Reserved.
  • 5. Background What’s exciting about the future of wireless marketing in general and wireless promotions in particular is that we are on the brink of a significant shake-up in our industry; the likes of which have not been witnessed since the World Wide Web was introduced in the early ‘90s. Believe it or not, this is not one of the “myths” covered in this white paper. The fact is, there are many significant reasons why this is the case. Let’s begin with an excerpt from Paul Saffo, a director of Institute for the Future and a technology forecaster studying long-term information technology trends and their impact on business: The Internet and the Web have barely touched our lives. The Web arrived on the one piece of real estate we’ve been trying to get away from for the last 20 years: our desktops. It didn’t get any further. This is what makes wireless and broadband so important. Wireless delivers the Internet in general and the Web in particular, to where we actually live and work and play. That has profound implications for our life and also for the medium. The Web on wireless going to personal appliances is not the Web as we know it. It is something else.1 According to PROMO Magazine, there were an estimated 1.3 billion mobile phone subscribers around the world, who sent some 3.66 billion SMS messages in 2002. The number of worldwide users has nearly doubled in two years to 2.6 billion in 2004. Specifically in the U.S., there were 165 million mobile phone subscribers by June of 2004.2 Carat Interactive goes as far as to call wireless devices, “The most powerful medium yet. And points out that ” “Wireless devices are the most powerful communication devices with respect to immediacy, interactivity and mobility, and therefore can act as the most powerful marketing communications devices, if used appropriately. 3 ” In essence, wireless devices deliver on the true mobility that was promised by laptops. These devices are highly personal and are kept closely within reach regardless of time of day. Wireless devices keep us in touch with the rest of the world and allow us to quickly gain information on demand. When integrated with the Web, these same wireless devices have the ability to deliver extremely relevant content, information, offers, and promotions. The trick is understanding the medium well enough in order to leverage these components without abusing the trust and, more importantly, the permission consumers must provide in order to participate in wireless promotions. In order to accomplish successful wireless promotions, the record must be set straight so that there is far less confusion about what’s to come in the wireless future versus the myths and fantasies that are likely to steer promotional programs in the wrong direction. 5 © 2004 by Bill Carmody. All Rights Reserved.
  • 6. Dispelling The Wireless Myths & Fantasies There have been entire volumes written on how myths get started and then blur the lines with the true facts that surround the myths. Many of these authors have concluded that within all myths there are elements of truth. This is no different when it comes to examining the fabrications that surround the wireless promotions industry. Starbucks Discount Ringing Your Mobile Phone Perhaps the best myth example is the one about how walking a short distance from a Starbucks would trigger an automatic SMS text message to be sent to your phone offering you discount on their coffee. Carat Interactive does a fabulous job dispelling this myth: This will never be practiced for the following reasons: 1. Starbucks would never attempt this annoying tactic, as it would receive tremendous customer backlash such that would not be outweighed by increased sales from the promotion. 2. In the same vein, Starbucks is an established brand and will not risk tarnishing itself with such a controversial effort. They will, on the other hand, invest in a locator device that will allow customers to locate (pull) the nearest retail shop through a locator database, ultimately leveraging location-based technology. 3. In the event that any user wanted this “service” they would opt-in by signing up with the coffee , shop or a provider such as Vindigo. By definition, these subscribers would be some of your best customers (probably most profitable), so Starbucks would have little need to offer them a discount—these customers are Starbucks regulars and will react to media such as signage. 4. Based upon the fact that there are thousands of Starbucks retail outlets nationwide, ones wireless device would be in constant notification mode when a user was driving through any major metropolis. Again, this is the roll of signage. [Instead] Starbucks… will invest in a service to allow their customers to locate the nearest outlet, and have already announced the ability to take pre-orders from wireless devices. Use of pull marketing will allow users to determine when they are interested in interacting with the coffee chain on their terms.4 And, should Starbucks attempt such a “push” marketing tactic without getting the permission of the casual user walking down the street, they would not only face incredible consumer backlash (because of the wireless SPAM issue), but legal liability as well. The CAN-SPAM Act of 2003 went into effect on January 1, 2004 and incorporated many of the components originally outlined in the Wireless Telephone Spam Protection Act of 2001. Specifically, section 14 of the CAN-SPAM Act requires the FCC, in consultation with the FTC, to promulgate rules to protect consumers from unwanted “mobile service commercial messages. (The Act defines “mobile service ” commercial message” as a “commercial electronic mail message that is transmitted directly to a wireless device that is utilized by a subscriber of commercial mobile service… in connection with such service. )5 ” 6 © 2004 by Bill Carmody. All Rights Reserved.
  • 7. Dispelling The Wireless Myths & Fantasies The truth is, with GPS embedded in your phone, you’ll have an enormous amount of location-based services available to you. Perhaps you’ve heard of “Flash Mobs?” This is when an email or text message is sent to a pre-registered group of individuals telling them a specific place to meet at a specific time to do a specific task… just for fun. The example I use is imagine if you joined a group of 500 people that were notified to go to New York’s Central Park at exactly 2:15pm on Saturday and play the city’s largest game of “Duck, Duck, Goose. Believe it or ” not, these things are happening right now. Enter enhanced wireless applications such as “Dodgeball” and “SpotMeeting” Hollywood executives might describe . Dodgeball as “Friendster goes wireless. It takes the incredibly hot social network aspects of Friendster and adds ” the all important ingredient of location and “on demand” meetings. In Dodgeball, members can send messages to their pre-registered friends (and even friends of their friends) simply by sending a time and a location. “Roy’s Restaurant at 6:00 p.m. would locate any friends within a 10-block radius and alert them with a message such as, ” “Bill is at Roy’s Restaurant. You know him through Kathleen. 6 ” “We call it a location-based service” says Dennis Crowly, creator of New York City-based Dodgeball in a recent inter- , view in Event Marketer Magazine. The article went on to say: Already the wired crowd is referring to the service as MoSoSo (mobile social software). User phones or PDAs must be less than two years old and GPS-enabled. If available, senders can also attach pictures to Dodgeball alerts so recipients can see photos (or in your case, perhaps a logo) of who’s pinging them. Users set options when they register as to whether others can blindly contact them or if they must be on the sender’s buddy list to receive pings… Privacy is not an issue, as Dodgeball doesn’t collect or disseminate last names. The service is currently available in Atlanta, Austin, Boston, Chicago, Dallas/Fort Worth, Denver, Los Angeles, Miami, New York, Philadelphia, Portland, San Diego, San Francisco, Seattle, and Washington, DC.7 SpotMeeting is similar to Dodgeball, but focuses more on the dating scene. SpotMeeting CEO Chester Yeum explains, “SpotMeeting is a revolutionary service for singles that lets them find a date instantly, and usually within walking distance. Other available online dating sites are limited in their reach because they are missing the key ingredient—location. Many of these wireless-dating services (including Match.com) even include pictures of the ” potential person so the impromptu blind date…well, isn’t.8 So while the Starbucks myth is worth avoiding, it’s clear that the underlying principle of location-based, contextual promotions is quite appealing. Assuming, that is, that the consumer initiates the action or request and that the response is relevant and meaningful. Mass marketing is dead. Long live permission-based, relevant marketing. The Promise of the “Wireless Web” on Your Phone Will your phone have access to the Web? Absolutely. Will it simply be the same content only served via wireless? Not a chance. This is a huge misconception, and one that needs to be corrected. As stated earlier in the background section, the Web via wireless devices is not the Web as we know it. It can’t be for the following reasons: 1. Screen Size – Even with the PDA hybrid phones, you’re still looking at the web through a much smaller screen and in most cases with much lower resolution. Large images from the Web become impossible to see through such a small screen. The original Web simply wasn’t designed with smaller hand-held devices in mind. 7 © 2004 by Bill Carmody. All Rights Reserved.
  • 8. Dispelling The Wireless Myths & Fantasies 2. Bandwidth – Dial-up for your home computer was bad enough, but now trying to download large amounts of data from the Web onto your phone is miserable. As more and more people get DSL or Cable Modems for their homes, they won’t tolerate these incredibly slow speeds for downloading content onto their phones. 3. Not a Laptop… Yet – The phone, while looking more and more like a powerful computer in the palm of your hand, still has a ways to go before it has the processing power of today’s computer. Lower processing power means slower data transfers and a slower overall Web experience. 4. Serves a Different Purpose – Most people are not doing research from their phones. People want the headlines instead of the whole story. They want their account balances from their banks, but not to do complete online banking (at least at the present time). The phone gives you immediate and relevant information, but the “deep dives” are still going to come from the computer be it work or home. Let me be clear that the Web on your wireless phone doesn’t suck. I am by no means disparaging the fact that you can get Web access from your phone. In fact the screen resolution has improved dramatically, as has the overall experience since launch. What I am saying is that there is a separate version of the Web that has been created specifically for the mobile phone (and other wireless devices) and is in a constant state of evolution. This mobile Web is much less graphic (and copy) intense. It allows you to get the stock quotes of the companies you’re interested in and the sports scores of your favorite teams. You can go deeper into the content, but the top-level has been specifically designed to provide you with the highlights of what you need… quickly. The mobile Web will continue to evolve to meet the needs of advances in technology. Next generation phones already support a mobile version of Java and there are many rich applications that allow phones to play MP3 music files and even record video. Eventually, the mobile Web may feel similar to today’s PC-based Web, but we have a long way to go and need will ultimately drive what the mobile Web becomes. 3G High-Speed Net Access Converting Voice to Data At the beginning of the new millennium, businesses were convinced that the next stage of wireless was 3G (or third generation high-speed Internet access technology). It was all the rage in Europe and Asia, and the U.S. was seen as “behind” the curve when it came to the data side of phone applications. The promise was intoxicating (not unlike the dot com era), and wireless carriers truly believed that the voice calling side of the wireless business would quickly give way to the data side. This had all sorts of promise for wireless marketers. If consumers used their wireless phones primarily for data applications versus voice, it would significantly change the dynamics of how the businesses communicated with their customers. Just as the economy was cooling down, the wireless carriers decided to focus on increasing the quality of their service and instead of focusing on 3G, they refined their “2.5G” technology such as GPRS. And while the data side of the wireless business provides incremental revenue for the wireless carriers, voice still to this day dominates the wireless phone market. 8 © 2004 by Bill Carmody. All Rights Reserved.
  • 9. Dispelling The Wireless Myths & Fantasies This doesn’t mean that data applications aren’t valuable or important. It’s just a misnomer that the data side of wireless phones would quickly out-pace the use of voice calling on the phones. When asked about the future of the wireless phone applications, David Steinberg, CEO of InPhonic stated that, “Today, email and instant messaging are the premier data applications poised to move the wireless market. Integrating such widely accepted “wired” applications allows users to make a comfortable, natural progression toward accessing data services wirelessly. 9 ” This is the “horseless carriage” approach used to introduce automobiles. That is, when the first cars where introduced, they were more widely accepted when they were explained as and referred to what was known at the time: a horse and buggy. The wireless data application equivalent is email and instant messaging. Once people understand that they can use the same applications on their phone, their comfort level with using data applications will increase as will their usage. However, it’s clearly not 3G that’s the magic bullet. Instead, the U.S. has seen WiFi technology take off, filling the initial void that 3G has filled in Europe and Asia. Given that WiFi is not regulated by the government the same way that 3G would be, it’s likely that WiFi will continue to flourish in the U.S.—possibly to a point where 3G will not make financial sense to the phone companies who would be required to purchase expensive licenses from the government. It’s unclear at this point which technology will eventually allow high-speed Internet access for wireless phones, but it is clear that (at least in the U.S.), it’s going to take some time before the data services of the phone out pace the voice calling services. India, China and EU as Forecasts of U.S. Market Trends Of all the myths with respect to wireless marketing and promotions, this one is the most understandable and, to some extent, excusable. There is no question that India, China and the EU are far ahead of the U.S. in terms of the number of wireless phones as well as the application usage of these phones. Because of the leadership position of these countries in the wireless space, it’s understandable why so many companies used these growth markets as future (predictive) models for the U.S. market. However, the mistakes are associated with the very distinct technological as well as sociological differences. To understand the absolute boom of the wireless market in these countries, as well as their corresponding adoption of various technologies, you must first understand the significant differences to the U.S. market: 1. Lack of Legacy Infrastructure – In the U.S., the penetration of the “wired” or landline telephone is estimated to be 90% or greater. That is, the vast majority of people who want a telephone in their homes have one. This is nowhere near the same situation in China or India. In these countries, the vast majority of the population have limited to no access to a “wired” phone, so the wireless phone is their first phone. In Europe, the “wired” phone challenges for credit card authorization and verification at retail were so bad that out of necessity, applications such as smart cards and RFID devices were launched much earlier than in the U.S. That is, merchants demanded faster and more reliable means of getting credit card authoriza- tions than using dial-up phone lines. This is why smart cards (i.e. chips embedded onto credit cards) were embraced much earlier than in the U.S. and to this day are much more successful in Europe. 9 © 2004 by Bill Carmody. All Rights Reserved.
  • 10. Dispelling The Wireless Myths & Fantasies 2. Wireless Phone as Primary Device – In India and China, much of the population sees the wireless phone as their primary device to “stay connected. In these countries the wireless phone is the primary ” device being used to access data and receive direct response information from marketers. 3. 3G is a Reality – Unlike the U.S., China and much of Europe already has the third generation wireless phone technology, which allows high-speed Internet connections for wireless devices. 4. Caller Pays – Here a novel idea: What if the person making the call or sending the text message is the only one paying for the call or message? That’s how it is overseas, but in the U.S., both parties pay. This added expense must be taken into account when marketing programs are conceived. 5. Compatible Networks – Do you remember when you needed an AOL account to speak to people on AOL and another account from Prodigy to speak to them? If this was before your time, then just think Instant Message. Your AOL screen name can’t talk to Yahoo! or MSN. In many respects, this is how it is in the U.S. between carriers. Overseas, they have agreed upon standards and no difficulty deploying applications across carriers. Not true in the U.S. 6. Social and Cultural Differences – While the world is getting smaller by the year, there are still very distinct social and cultural differences that do not transfer to the U.S. The way in which the wireless phones are used by their nature is an extension of these social and cultural differences. For these reasons, assumptions must be challenged when looking at forecasts from these countries and comparing them to the U.S. market. The issue is not necessarily that the ideas from these countries won’t work in the U.S.; it’s just that these ideas must be filtered through the technological and cultural differences to ensure assumptions are correct. Assuming that because 3G was popular in China and Europe it would be the same in the U.S. was clearly false—at least in the timeframes being considered. The same goes for the use of the data side of the wireless phone. It’s not that we won’t eventually come to a similar place, but we have a number of steps before we get there. Pushing Email Offers to Wireless Phones In some respects, this myth is a subset of the previous one. The good news about the previous myth is that it also explains why today’s SPAMers can’t push their SPAM onto your wireless phone. The idea that you can deploy email marketing campaigns to all of your wireless customers is false; at least not with the serious help of a wireless aggregator and, in most cases, the approval of various wireless carriers. The reason is that in the U.S., the wireless carriers are operating in what is referred to as a “closed network. ” That is, each carrier has the ability to control what’s happening inside their network. In a recent Wall Street Journal article, Jeffrey Nelson, a spokesman for Verizon Wireless put it this way, “Once something is knocking at the door of our network, we can let it in or not. On the landline, the messages just travel. There isn’t a gate, if you will. 10 ” The article went on to describe how carriers can impose SMS message volume limits, which help weed out SPAMers. That is, until the networks are no longer closed, and then we face the exact same issues as our overseas colleagues. 10 © 2004 by Bill Carmody. All Rights Reserved.
  • 11. Top Five Hottest Promotion Trends in Wireless As 2004 winds down, there have been a number of advancements in wireless technology, legal legislation and the overall approach to leveraging wireless promotions in the overall marketing mix. In this section, the focus is on the macro trends—that is, the broad, sweeping trends—that directly affect the kinds of wireless promotions that are driving the promotions industry. These top trends are the ones that promotional marketers need to be aware of in order to be able to launch and manage wireless promotions effectively. Wireless SPAM & Related Legislation When comparing one of the hottest trends in wireless promotion to the Internet, the issue of Permission and Privacy will sound quite familiar; however, there is a brand new financial twist that makes Wireless SPAM a much more serious issue. Imagine if you had to pay ten cents for every piece of SPAM email you received in your inbox. I currently average about 100 to 200 SPAM emails per day. That translates into $10 to $20 per day, or $3,650 to $7,300 a year! With this example, you can see why not only do all the same SPAM issues from email marketing apply, but why they are financially much more critical to solve. In October of 2002, an iBrief aptly titled, “The Future of Wireless SPAM” was released from Duke Law & Technology , Review that illustrated just how bad the wireless SPAM issues were in Japan: It is estimated that of the 950 million emails exchanged daily in Japan, 84 percent are sent out at random. At a cost to DoCoMo [Japan’s largest cellular provider] of over $200 million, both the company and the industry need a solution. Japanese Parliament enacted two anit-spam bills in April 2002. On July 1, cellular consumers and providers in Japan may have found a lasting solution when the two new laws regulating wireless commercial solicitations—cell phone spam—came into effect… It provides cellular users with an opt-out option, requiring senders of email ads to attach messages telling receivers how to reject future ads.11 Similarly to Japan, the European Union’s Parliament passed the Directive for the Protection of Personal Data and Privacy in the E-communications Sector. However, unlike Japan’s bill, the EU adopted an opt-in approach as part of their legislation. That is, marketers must get permission to send advertisements before they send them, whereas in Japan marketers are not required to get permission ahead of sending messages just as long as they honor requests to be removed from future communications. In the U.S., the problem of wireless SPAM is not nearly as great… so far. The Duke article explained the issue this way: Cell phone spam [in the U.S.] is hindered by the same limits in technology, in particular the differ- ent technology standards, which have rendered American cell phones antiquated as compared to phones in Asia and Japan. Unlike the United States, Japanese and European carriers, as required by their governments, have adopted uniform technology standards.12 11 © 2004 by Bill Carmody. All Rights Reserved.
  • 12. Top Five Hottest Promotion Trends in Wireless As stated earlier in the “Pushing Email Offers to Wireless Phones” section, the reason is that in the U.S., the wireless carriers are operating in what is referred to as a “closed network. That is, each carrier has the ability to ” control what’s happening inside their network. In a recent Wall Street Journal article, Jeffrey Nelson, a spokesman for Verizon Wireless put it this way: “Once something is knocking at the door of our network, we can let it in or not. On the landline, the messages just travel. There isn’t a gate, if you will. 13 ” The article went on to describe how carriers can impose SMS message volume limits, which help weed out SPAMers. That is, until the networks are no longer closed, and then we face the exact same issues as our overseas colleagues. “Every campaign in the U.S. is opt-out enabled” says Paul Cushman, Director of Business Development at m-Qube. , “Being a late adopter has enabled the U.S. to learn from the mistakes of others and create policies that solve these problems in advance. For example, blanket opt out is part of the Code of Conduct of the Mobile Marketing Association. Mr. Cushman went on to explain that the process of setting up short codes has built in anti-SPAM pro- ” tection as well. “The Common Short Code process and the extablishment of aggregators by the carriers to ensure that they have visibility and approval of campaigns before they go live. 14 ” Fortunately for consumers and marketers alike, the CAN-SPAM Act of 2003 went into effect on January 1, 2004 and incorporated many of the components originally outlined in the Wireless Telephone Spam Protection Act of 2001. Specifically, section 14 of the CAN-SPAM Act requires the FCC, in consultation with the FTC, to promulgate rules to protect consumers from unwanted “mobile service commercial messages. (The Act defines “mobile service ” commercial message” as a “commercial electronic mail message that is transmitted directly to a wireless device that is utilized by a subscriber of commercial mobile service…in connection with such service. )15 ” Smart promotional marketers should not need this kind of legislation to understand that unsolicited messages—be they SMS text or email—are not welcomed by their consumers. Without getting the express and explicit permission of consumers, wireless promotions are doomed to fail. Moreover, because of the cost implications, consumer advocacy groups are likely to ensure that unwanted wireless SPAM will not go unnoticed—this means negative publicity at the very least and could include significant fines and a class action lawsuit. The underlying message here is: think twice before sending out messages to your consumer’s wireless phone. Which brings us to the next wireless promotion trend. Pull vs. Push Promotional Messages Mass media is dead. Proctor & Gamble was the first to say this publicly, and most recently Larry Light, Global Chief Marketing Officer of McDonald’s made this proclamation at the AdWatch: Outlook 2004 conference and was featured on the front-page article in Ad Age on June 21, 2004. Fortune 500 companies are no longer satisfied with the declining returns of mass media, nor the antiquated systems used to track, report, and analyze their marketing and media spend. 12 © 2004 by Bill Carmody. All Rights Reserved.
  • 13. Top Five Hottest Promotion Trends in Wireless Think of Push marketing as outbound marketing (company pushing messages to consumers), while Pull marketing is inbound (consumers requesting information from the company). Push messages are defined as a single, mass- marketing message that is intended to interrupt consumers from what they were intending to do and deliver a marketing message. Pull marketing, by contract, is defined as contextual, need-based messages that are delivered to consumers only when they are requested. In the early days of television, Push marketing made the most logical sense. In television and radio, it’s the 15, 30, or 60-second spots that interrupts consumers from the program they were watching or listening. The objective of Push marketing is to literally interrupt consumers from what they were intending to do and push out an advertising message to convince them to buy a company’s product or service. Push marketing will never go away completely, however, because of the significant volume of noise that is currently out in the marketplace, the trend is for the target audience to ignore these messages. Pull marketing takes a different approach. Pull marketing anticipates the interests, needs and desires of targeted consumers and crafts marketing messages and offers that are likely to appeal to consumers who take the time to request the information. An example of Pull marketing is a consumer’s ability to go online or call an 800 number to check the balance of their checking account or the status of their airplane flight, or to get a recipe for dinner. The company’s marketing messages are integrated into the specific needs of their consumers. Perhaps the easiest distinction between Push versus Pull marketing messages are in the context of online advertising. An example of Push marketing would be the standard banner advertising that attempts to divert you from what you planned on doing online to what the marketer would like you to do. An example of Pull marketing would be paid search results on Google or Overature that are contextual marketing messages to the very thing about which you went online to find out more information. Rather than trying to interrupt, Pull marketing is contextual to what the consumer is already interested in doing and offers and easy way to provide a solution to their problem. In the wireless world, this issue becomes of prime importance. Push messages in the context of wireless would be things like wireless alerts, SMS message announcements, and outbound telemarketing. As it currently stands in the U.S., consumers bear the cost of these potentially unwanted messages. As a result, consumers are unlikely to put up with paying for Push marketing that interrupts them from what they were doing. By definition, consumers will welcome pull messages. This is because they only receive the marketing messages they specifically request. “Would you like to know if your plane is running late? Then send a SMS text message to XXXXX and we’ll notify you of any delays. United Airlines has already started this program and the consumers who ” sign up for these alerts swear by them. What better way to reinforce brand loyalty than by letting your passengers know well in advance that there’s likely to be a delay? Banks can reduce the number of calls they receive by allowing you to text in your account number and get back the balance. The same goes for your credit card company. CPG companies can use text messaging to offer discounts on future purchases. “Want to get a coupon off your next purchase? Send a text message to XXXXXX and we’ll send you the discount. ” The idea is that companies can use their existing product packaging, bill statements, and other assets that are already widely accepted by their customers to build loyalty and future purchase behavior. If new customers are needed, pass along offers can be developed so the core audience can provide offers of real value to their friends. 13 © 2004 by Bill Carmody. All Rights Reserved.
  • 14. Top Five Hottest Promotion Trends in Wireless Word of mouth has always been a powerful component of marketing. The challenge has been how to encourage, track and measure this aspect. In the online world this challenge was initially solved through tell-a-friend email components, and then evolved further into affiliate marketing, incentives and rewards programs. The same will hold true to wireless marketing given that the offers are compelling and worth talking about. The bottom line is that Push marketing messages will be fought by your customers because they have to pay for them. Pull marketing messages, however, can create a much more intimate, loyal, and “on demand” relationship with your customers. Just as in the online world, your customers must always be in control of the relationship, and this brings us to the next section. CMR vs. CRM From the beginning of the wireless marketing revolution, there has continued to be the debate over, “Who owns the customer?” Do the service carriers such as AT&T Wireless, Cingular, T-Mobile, Nextel, Sprint, and Verizon own the customer? Or do the hand set manufactures such as Ericsson, Palm, Motorola, Nokia, Samsung, and Sony own the customer? Or could it be the content partners such as AOL Time Warner that own the customer just on a different device? The answer should be obvious: None of the above! If you truly believe in permission marketing, then you should know that it is the customer him or herself, not any particular company, that owns the relationship. At any point, the customer can opt-out of the relationship and start fresh with a competitor. The customer has choice and in this day and age, they will exercise their options to find a solution that works best for them. This leads us to an invaluable insight from Carat Interactive. We need to change the “CRM” to the “CMR” Forget . “Customer Relationship Management” and start thinking in terms of the “Customer Manages the Relationship. 16 ” It’s not that CRM isn’t valuable. It’s definitely a step in the right direction, but to succeed in wireless promotions, we need to be dyslexic with this acronym. We need to begin with the idea that the consumer, not the company, is in the driver seat and manages the relationship. This is the reality in all marketing, but becomes painfully apparent in wireless programs that do not follow this golden rule. With most of your customers having a wireless phone with them wherever they go, CMR becomes a very intriguing idea. Consumers have the ability to let you know what they want, when they want it, and even where they want it. They are always “on” with their wireless devices and so this can be the ultimate tool for cultivating the relationship. The key is to have the right people and systems in place to allow for a two-way communications medium (not just the Push, mass-marketing messages). “Amazon.com created a very good business using purchase behavior, emails and recommendations to increase repeat traffic and increase sale frequency and amount” noted Paul Cushman, Director of New Business at m-Qube. , “Without mobile, this would be nearly impossible to do in the retail world. However, with mobile devices, retailers can fill this gap, enabling them to take advantage of the successful online strategies in the real world. For more on ” how this is done, we move to the next section. 14 © 2004 by Bill Carmody. All Rights Reserved.
  • 15. Top Five Hottest Promotion Trends in Wireless Wireless Offers at Retail So far we’ve reviewed the issues with wireless SPAM, identified the types of messages to be utilized (i.e. Pull vs. Push), and identified the fact that the consumer needs to be in control of the relationship (i.e. CMR). Now it’s time to take a look at how all these components come together in the retail environment and get a sneak peak at what’s to come. Today, there are several companies that are already testing the use of wireless phones at retail. In September of 2002, m-Qube pioneered mobile couponing in the U.S. and has since formed a relationship with NCR. m-Qube in partnership with NCR, allows marketers to deliver custom coupons to consumers’ wireless phones via existing retailer loyalty platforms. m-Qube has run successful pilot programs already at the Cambridge-Side Galleria in Boston, with retailers and QSRs such as Gap, J Crew, Guess, Steve Madden, Borders, Dunkin’ Donuts, and Taco Bell all participating. Paul Cushman, Director of Business Development at m-Qube explains that, “This gives us the capability to provide an individually coded and trackable coupon to a mobile device that can be redeemed by showing the phone at the POS, where the clerk enters the code and we then track results from the back end. Mr. Cushman predicts that ” “2005 will be the break out year for couponing” and eluded to a nationwide program for the 2005 holiday timeframe which he believes could well be the largest Mobile Marketing program the industry has seen to date. The key is that companies such as NCR see the power (and the future) of wireless marketing and promotions. By having NCR integrate unique codes into the existing back-end infrastructure, companies such as m-Qube can deliver unique codes to individuals who send a request via text message. It is then up to the manufacturer if that unique code will be allowed to be forwarded to friends or not. For example, let’s say that you want to move more pairs of jeans at the Gap. You decide that, as part of a Back to School program, you’re offering a free pair of jeans with every $50 purchase at the Gap. You purchase billboards in the downtown Boston area and tell people that to get this offer, they need to text “Jeans” to XXXXXX short code. Consumers who send the text message get back the offer details with their own unique code. Now, if you want to control the redemption of this offer, you can make it such that the unique code is only valid for the single purchase. However, if you’re trying to get as many people as possible to come to the store and shop, you can allow consumers to send this electronic offer to their friends. The beauty of having this electronic offer is all of the detailed reporting to which you now have access. Knowing the estimated number of impressions from the billboard, you can determine the opt-in rate based on the number of people who request the offer. You can further measure the redemption rate based on the number of people who redeem the offer. If you’re measuring pass-along value, you can further measure the number of friends that were forwarded this offer and redeemed. And while this is the most popular scenario at present, there are others as well. DRM Labs has an interesting solution using your credit card to redeem the offer on the backend, rather than an offer code in store at the checkout counter. In their version, you request that offers be delivered via text message and register your credit card number with the wireless carrier. After the offer is delivered to the mobile phone, rather than showing your phone with the unique code to the retailer, you simply shop the way you normally do, using your pre-designated credit card. You pay full price at the retailer, but after you make the purchase, you receive a text message confirming that you received the discount on the backend. That is, your credit card statement specif- ically identifies the full purchase amount at the retailer, and then credits you the discounted amount … right on your credit card statement. “There are advantages to this solution, according to Jeff Mankoff, President of DRM Labs, ” “There are no retailer software and hardware POS integration costs and redeeming with a credit card is consistent 15 © 2004 by Bill Carmody. All Rights Reserved.
  • 16. Top Five Hottest Promotion Trends in Wireless with how consumer’s shop today. By redeeming a mobile coupon with a credit card versus a mobile phone display, we eliminate consumer and sales clerk fraud. Also, the DRM Labs model is wireless carrier centric, in that the cus- tomer opts in and registers at the carrier. And it is the carrier (not the advertiser) that delivers the offers. Thus, the carrier acts as the gatekeeper and avoids any appearance of Spam to the mobile phone. ” While the technologies supporting these efforts will evolve over time, the bottom line is that the marriage of retail and wireless couldn’t be a more perfect match. Yes, there are and will be some technical issues that will be worked out over time, but the reality is clear as day. Wireless integrated with retail programs are here to stay. Enhancement of All Other Disciplines The connection between wireless phones and retail is by far the most exciting to those of us in sales promotion. At the end of the day, ROI is measured by the number of products sold as a direct result of our efforts. With wireless promotions, the same ROI capabilities from the online world are brought down to the mobile phone level, and this should be very exciting for promotional marketers. Driving sales at retail, however, is not the exclusive objective of every promotional marketer. This section identifies some of the other exciting tools that can now be leveraged using consumer’s wireless phones. It should be noted here that wireless promotions by themselves are unlikely to shatter any marketing or sales objectives. As with any promotional marketing program, integration is essential. The better you integrate your wireless marketing efforts into the overall marketing mix, the better your results. 1. Activating Sponsorships: For marketers who are looking to find creative ways to extend the life of their events and make their sponsorships pay, wireless promotions offer up some very unique advantages including: (A) Photo Blogging, (B) Fan Polling / Voting, (C) Distribution of Electronic Offers, (D) Lead Generation, and (E) Content Purchases. A. Photo Blogging: This is an ingenious way to allow consumers to take their photo-enabled wireless phones and tell their story at your events. By allowing your consumers to post their pictures from your event, you not only give these consumers a reason to go back to your website, but also create buzz and excitement at the event. If the event is hitting more than one market, photo blogging will give the up and coming markets a sneak preview of what’s to come. B. Fan Polling / Voting: Want to make your sponsorship more interactive and provide real-time feed- back to your company? Fan polling allows consumers to tell you how they feel—what they like, dislike, and things they’d like to see in the future. Voting allows them to participate and have a say in the course of the events. Start thinking of wireless phones as mini polling pads that people carry with them at all times. Make it fun and provide real-time feedback and they’ll be hooked. C. Distribution of Electronic Offers: Got a product or service to sell at the event, but need more time? Peak your consumer’s interest and have them text you for the details. Your electronic coupon can send people back to a website or simply to the closest participating retail outlet to continue the sales process. D. Lead Generation: Truly a no-brainer. Provide something of value and consumers will gladly let you know if they’re interested or not. The more you’re willing to offer up, the more leads you can pull down from these events. Make your offers relevant to the sponsorship at the event and consumers will be in the right frame of mind to take action—right there on the spot with their wireless phones. 16 © 2004 by Bill Carmody. All Rights Reserved.
  • 17. Top Five Hottest Promotion Trends in Wireless E. Content Purchases: For the lead sponsors, liquidating the sponsorship should be as easy as getting the online and wireless rights to sell meaningful content at the event and after the event has concluded. From ring tones to games to wallpaper to other wireless content, leverage the asset you’ve purchased and reap the rewards wirelessly. AT&T Wireless, for example, was able to liquidate part of their Olympics sponsorship by selling Olympic ring tones, screen savers and other content downloads (not to mention signing up new subscribers via exclusive Olympic phone offers). Samsung was likewise able to liquidate part of its Warped Tour sponsorship by securing the digital wireless rights to downloadable music, ring tones, screen savers, games, and other content. 2. Extending Events: With all of the above examples, it should be clear that there are many ways to extend the life of your events using a combination of wireless and online technology. From photo blogging to exclusive offers, it should be easy to think of interesting ways to move people from the event to your website and/or retail location and continue to sales cycle. 3. Driving Online to Offline: The reverse is also true. Creating an appealing online experience will help motivate your consumers to go offline—be it to your events or retail promotions. If your event is newsworthy, you can use wireless alerts to keep people posted on the most current information. Sign up online and receive updates wirelessly. 4. New Direct Response Vehicle: There will most likely be a long-term future with Business Reply Cards (BRCs). That said, think of the ability to send text messages as a new direct response vehicle in new advertising locations. With a SMS short code, why not make your billboards a direct response vehicle. Or, for that matter, your radio (or to a lesser extend, your television) ads? With wireless, consumers are always on. If you keep the offer compelling and the message simple, you can drive response from media you previously never thought possible. The direct marketing companies should be thrilled with this advancement in technology. 5. Interactive Merchandise: “Take One” now becomes “Text for One” I’m not suggesting that paper goes . away entirely, just that there’s an easier way to “take it with you” that doesn’t leave unwanted clutter. POS at retail is looking to drive purchase, but sometimes consumers need some time to think things over. When that happens, wireless provides an interesting way to send the message. 6. Real-Time Loyalty: This can literally mean anything you want it to. From the most traditional “frequent flyer mileage” programs getting a wireless facelift with real-time access to account balances to brand new and exciting ways to track and reward loyalty. Think “digital punch cards” where the phone acts as card. However you define loyalty, chances are there are several ways to enhance customer loyalty with wireless technology. From faster access to information to rewards requests, there are many ways to go here. 7. Enhancement of Collect & Win Games: For McDonald’s why not run “Wireless Monopoly” where all , the game pieces are specially coded and playable via a wireless phone? The codes already exist, so it really comes down to creating a digital game board to store the game pieces. To that end, many of the instant win prizes could be digital content such as ring tones, MP3 music files, games, etc. The bottom line is that just like online promotions enhanced all of the traditional promotional marking disciplines,so too will wireless promotions. They are not the “end-all-be-all” to promotional marketing, but they do provide some very unique ways for consumers to participate and for marketers to track real-time results. The next time you’re thinking about designing a promotional marketing program, ask yourself, “How could I add a wireless marketing component?” You’ll be surprised how quickly and easily it will come to you. And if you’re still struggling, send an email to bill@billcarmody.com and I’ll help you brainstorm. 17 © 2004 by Bill Carmody. All Rights Reserved.
  • 18. Leveraging Wireless Promos for ROI Analysis Return on Investment (ROI) in theory is incredibly simple, but in practice can be challenging if you can’t isolate the right information. Many companies have relied on the lift in sales data to provide the key market indicator as to the success (or failure) of a promotion. The challenge with this approach is that often times marketers have multiple programs working to stimulate demand. How do you know if it’s actually the promotion that’s ringing the cash register or something else? Wireless promotions may not completely solve this problem, but when used correctly they can certainly take the proper steps in the right direction. The wireless promotions dimension takes all the valuable insights learned from the online space and adds the missing component of mobility. That is, marketers could track how their online programs were doing, but it wasn’t always practical to assume that the target audience had access to a laptop while: (A) Watching TV, (B) Listening to the radio, (C) Reading a magazine, (D) Viewing a billboard, etc. With wireless promotions, we can now take the next step. We can keep all of the measurement tools developed in the online world and apply them to the “real world. The same electronic coupon that was delivered via email can ” now be delivered to a wireless phone. The difference is, getting this coupon “on demand” in the “real world” means a higher likelihood of redemption. Why? Because the request for the offer can be made in route or even at the retail store location. Promotions, especially online promotions, have often been used as the glue that holds multiple mediums together. With a central offer, the same message can be delivered across all media and drive back to retail, online, the phone or to the mail. What the wireless factor does is make it incredibly easy to track response that happens via any and all of these components. Having separate short codes that extend the same offer is the equivalent to having separate URLs that track where consumers came from. The difference is that they no longer have to be near a computer or go online to participate. Measuring ROI effectively means tracking all of the right components of the promotion to ensure that the campaign was run as effectively as possible and provided a positive rate of return. Wireless promotions are not a “magic bullet” but they do provide us with new and interesting ways to oversee the progress of a promotion. With each , message sent, each request, and each coupon redeemed, marketers are getting much more real-time information and have the ability to make the necessary adjustments to ensure success. 18 © 2004 by Bill Carmody. All Rights Reserved.
  • 19. Recommended Resources There are a number of players out there in the mobile marketing space, and all great people I might add. Below is a list of resources that I have pulled together from past wireless promotion programs. While this list is by no means comprehensive, it’s a really good place to start. As always, if you have any questions, please send an email to bill@billcarmody.com. • AT&T Wireless (Wireless Carrier Partner) Ted Mandelkorn, Consumer Promotions, SMS Offer Portfolio, (425) 580-5607 ted.mandelkorn@attws.com , • Carat Interactive (Wireless Media / Advertising) Chris Arnes, (415) 227-2122, Chris.Arens@carat.com • Cingular (Wireless Carrier Partner) Dave Garver, (404) 236-6000, dave.graver@cingular.com • DRM Labs (Wireless Coupon Provider) Jeff Mankoff, (214) 891-1800, jmankoff@drmlabs.com • InfoSpace Mobile (Wireless Content & Technology) Tony Wootton, (310) 481-6941, tony.wootton@infospace.com • Loeb & Loeb (Wireless Legal) Ken Florin, (212) 407- 4966, kflorin@loeb.com • Mobliss (Wireless Content & Technology) Brent Brookler (206) 332-1749, brent@mobliss.com • m-Qube (Mobile Marketing & Content Provider) Paul Cushman, Director of Business Development, (650) 234-8210, pcushman@m-Qube.com • Navio (Wireless Content & Technology) Ron Martinez, Chief Product Officer, (408) 864-7979 ext. 123, ron@navio.com • Proteus (Backend Wireless Technology Provider) Craig Shapiro, (415) 773-1475, craig@proteus.com • Samsung (Handset Manufacturer) T. J. Person, Business Development Manager, Wireless Terminals, (972) 761-7255, t.person@samsung.com • SanDisk (Flash Memory Partner) Dave Smurthwaite, Mobile Product Marketing Manger, (408) 548-0183, dsmurthwaite@sandisk.com • Seismicom (Brand Promotions Agency) Bill Carmody, Chief Marketing Officer, (415) 864-4000 ext. 103, bill@seismicom.com 19 © 2004 by Bill Carmody. All Rights Reserved.
  • 20. End Notes Paul Saffo, “New Fronts in the Communications Revolution” included in the book, What’s Next: Exploring The New 1 Terrain for Business by Eamonn Kelly, Peter Leyden, and Members of the Global Business Network, Perseus Publishing, September 2002, page 170. Kathleen M. Joyce, “Missing the Medium” in PROMO Magazine, August 2004, page 37. 2 Carat Interactive, “The Future of Wireless Marketing” White Paper, 2002, page 4. 3 Ibid, page 7. 4 Ken Florin of Loeb & Loeb in an email dated September 20, 2004. 5 Colin Gibbs, “Clubbing, SMS Style: From Virtual Girlfriends to Real Ones, Mobility Adds Social Twists” in 6 RCR Wireless News, September 6, 2004, page 32. Dan Hanover, “Palm Pilots: Dodgeball makes promoting events with email blasts seem oh so low-tech” Event , 7 Marketer Magazine, August / September 2004, page 9-10. (Author’s Note: You’ll find a really cute picture of my newborn son on page 6). Ibid. 8 David A. Steinberg, “The future’s in the phone: the wireless world is still all about voice – CEO Perspective” in 9 Wireless Business & Technology, July 2003. Riva Richmond, “Pre-Emptive Strike: Cellphone spam isn’t a huge problem yet. And regulators want to make sure 10 it never is., Wall Street Journal, September 13, 2004, page R13. ” “The Future of Wireless SPAM” an iBrief by Duke Law and Technology Review 0021, October 28, 2002. , 11 Ibid. 12 Riva Richmond, “Pre-Emptive Strike: Cellphone spam isn’t a huge problem yet. And regulators want to make sure 13 it never is., Wall Street Journal, September 13, 2004, page R13. ” For more information about the Common Short Code process, visit http://www.usshortcodes.com. 14 Ken Florin of Loeb & Loeb in an email dated September 20, 2004. Note: If you’d like more information on this 15 topic, please send an email to bill@billcarmody.com and I can send you a detailed summary along with links of where to go find out more information. Carat Interactive, “The Future of Wireless Marketing” White Paper, 2002, page 9. 16 20 © 2004 by Bill Carmody. All Rights Reserved.