With the increase in online usage over the past decade, businesses have sought to increase their exposure to consumers through online advertising. One of the latest innovations in advertising has been Online Behavioral Advertising ("OBA"). As defined by the Federal Trade Commission ("FTC"), Online Behavioral Advertising is "the practice of tracking an individual's online activities in order to deliver advertising tailored to the individual's interests."1 Businesses are now able to track information about online consumers, ranging from the relatively harmless, (e.g., gender and age), to the highly personal, (e.g., precise geographic location and Social Security number).
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