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February 02, 2009


Jim Glionna


After reading BPA’s proposals for the reporting of Digital Non-Request copies as Non-Qualified copies and the arbitrary switching of print edition copies to electronic copies, I can clearly state that I am totally against both “compromise positions”.

We publish five titles – all of which are 100% request circulation with the exception of a new title we just purchased. We are in the midst of spending thousands of dollars to convert that magazine to 100% request. Like everyone else, we are cutting costs wherever we can. However, we will not reduce the investment or compromise the quality of our circulation. We will continue to offer our advertisers the highest quality circulation we can.

If BPA adopts either of these compromise proposals, it will present publishers with the opportunity to totally dilute their databases and ultimately hurt the only customer worth pleasing – the advertiser. BPA is the watch dog of the industry. A BPA Publisher’s Statement is recognized by our advertisers and their agencies as representing the highest quality auditing standards and integrity in the industry. Why is BPA letting itself get pushed around by some publishers who are not willing to invest in their lists? It appears to me that these publishers are just looking for cheap ways (in this case zero costs) to push up their numbers with little or no concern for the quality of their lists. Is this really what BPA wants to support?

As a Publisher who has been in this game for a long time, I urge BPA to resist the pressure from these publishers and say no to the auditing of digital, non-request circulation and the conversion of qualified print subscribers to qualified electronic subscribers without their OK.

If accepted, these proposals will degrade the quality, integrity and credibility of a BPA statement and put publishers like us in the position of explaining why and how this kind of information came into being. Advertisers aren’t stupid; when they find out how this circulation was generated, they will be appalled with BPA for allowing this kind of data to appear on a BPA statement.

Jim Glionna
Newcom Business Media

mike popalardo

OK - here's a conundrum for you. I never have an opportunity to read the print copy that I dutifully requal each year. This particlar title is not totally germane to the industry but it definitely has some value.

I do however read the digital version they sent me and that I haven't requested.

What do you do with that?

b franklin

The companies our advertising agency represents are only interested in who is going to see their ad in print. If digital copies are counted it should be broken down on the BPA statement.
As far as unrequested digital copies, they shouldn't count at all. They are just junk mail.

Daniel Waldman

"Non-request digital circulation" is just a different name for spam. It's still junk mail. BPA should not recognize it.

Don Staruk

I agree with the idea that the more info the better, and let the ad buyer decide what he or she values. Track the non-requestors as well as requestors, and, at least for now, keep the digital numbers separate from the print figures. As Kuchinsky said and others seemed to agree with, “If a subscriber is qualified ..., and is from a valid source, then he qualifies regardless of how or what format the magazine reaches him..., judgment as to the quality of that subscriber should be left to the advertiser.”


There are actually several questions being debated here.
1. Should non-requested digital distribution be reported as qualified?
Yes, as long as the recipient fits within the definition of a qualified recipient. All distribution should be allowed to be reported, as long as it is labeled for what it is: Requested or Non-Requested. Qualified or Non-Qualified. We need to remember to be clear in our discussions that: Qualified does not necessarily mean "Requested".
A qualified recipient is a recipient that falls within a publication's pre-defined demographics. Therefore, if an email address belongs to a qualified recipient, and can be proved as such, the distribution of that digital edition is qualified distribution.
2. If publishers are given the ability to report non-requested digital distribution, they'll be more likely to spam in an effort to inflate their distribution numbers.
I don't think so. Someone posted a comment saying something to the effect that there's no cost disincentive to discourage a publisher from sending spam email, and I disagree.
No business wants to end up being black-listed with ISPs, especially with the economy bringing more and more buyers online.
If this is a real problem, then require all emails (regardless of commercial or informative content) to include an opt-out or specific opt-out language, for BPA purposes. No problem with that kind of rule.
Deliverability is so important. Even if the message is not considered spam by the CAN-SPAM act, it does not stop people from making spam complaints or clicking their "This is Spam" button on their email client. If you continue sending email to people who do not want it, and are not opening it, then you are not doing your business or brand any favors in my opinion.
3. Does non-requested digital distribution have value to the advertiser?
[If a “qualified” person receives the (digital) publication but doesn’t read it (or open it), it has no value whatsoever to the advertiser...the “qualified” person” never received the advertiser’s message.] (Quoted from another post)
This is true. In the same way, if a print magazine goes to a qualified person's postal mailbox, but is never opened or is put directly into the "circular file" (trash can), it, too, has no value. Yet this print distribution is reported as qualified. Because, by definition, it IS QUALIFIED distribution. AD BUYERS should consider this fact and assign value to the data accordingly, not BPA.
It is the publisher's job to determine and report the actual metrics available to us. Unlike print, with digital we have more metrics available in addition to distribution. We have click-throughs, page-views, average time spent, etc. It's the advertiser's job to determine based on all available data, which publications will be the most valuable in reaching their marketing goals.
Obviously, the value placed on the requested distribution vs. non-requested distribution will be different. But who decides? BPA or the Advertiser?
Distribution, obviously does not hold the same value to an advertiser as "Opens" would. It's not BPA's job to determine the value of the data, it is BPA's job to determine the accuracy of the data reported.
4. Should publishers be able to switch distribution types back and forth (between print and digital)?
I don't feel it makes good business sense to switch the product on a paid subscriber. If I order a book on tape, and they send me a hard copy or the book, I'm not a happy customer. In the same way, if a subscriber pays for a specific product (either digital or print) and then that product is discontinued, then offering them the option to switch would be okay, as long as they can also choose to be reimbursed if they do not choose to continue with the substitute product. If it's a free magazine, then be sure the advertisers (who are essentially sponsoring your "free" subscriptions) are aware of any changes in distribution prior to making said changes.
However, it's not BPA's role to be our business advisors. We each need to make the best decisions we can for our own business's needs. If publisher's are not providing a valuable service to their customers (subscribers and/or advertisers), they won't last long in this economy.

Dave Kalman

[What's the opinion on accepting as qualified digital circulation direct request subscribers who originally requested a print edition or a print/digital combination and have been switched to a digital only subscription?]

I'm not sure that validating such a switch would be a a good idea.

It's not a problem from a 'netiquette' standpoint. You'd have an existing business relationship and, of course, you'd have to provide an opt-out option with your first issue.

As a reader I couldn't complain too much if it happened to be a free sub. For a paid sub, switching to digital w/o request could be breach of contract (unless you offer a refund on unserved copies). Also, some too clever circulator might think it's ok to soft-offer 12 wonderful issues, ship the first in print, and then switch to digital for the remainder. If BPA allowed it, would that justify such behavior?

From an advertiser's standpoint, I'd consider it probematic if you were to lump switched-to-digital subs into your total qualified circ. If you're delivering an emedia product, I'd want emedia pricing, and accountability for views, clicks, and/or conversions. I'd certainly be asking about the percentage opened.

I can't offer a definitive answer to the original question; however, it does speak to the need to make sure every offer specifies in the terms:


In that case, I'd say you're covered.

Valerie Tickle

What's the opinion on accepting as qualified digital circulation direct request subscribers who originally requested a print edition or a print/digital combination and have been switched to a digital only subscription? If you can switch someone from digital to print without any penalty why not the other way round? With full disclosure in paragraph 11 as to the how many and when, why not? Advertisers will buy or not buy based on that information and Publishers will have greater flexibility on how they serve the subscriptions.

Dave Kalman

It's surprising to see any support for non-requested digital distribution. Spam is spam.

And while it's not technically illegal under Can Spam (a publication's "primary purpose" is informational vs. commercial), it falls in the category of Barely Legal. You can do it, but it just seems wrong.

Also, many major advertisers would object if they knew they were subsidizing spam. Read those agency contracts carefully. They may very well preclude unrequested delivery.

That all said, there are marketers who have no problem with unrequested delivery. That doesn't mean that BPA should encourage them.

Consider the risk of backlash. If BPA validates unrequested emailing, the result could be a legislative push-pack worse than "Do Not Call."

Just my two cents (and sorry I'm late to the discussion).

p.s. Print and electronic are NOT equivalent, a fact which is enshrined in law. The law recognizes that an email communication -- like a fax memo (remember fax marketing?) -- consumes the recipients' resources and clogs the Internet.

See http://www4.law.cornell.edu/uscode/15/usc_sec_15_00007701----000-.html

Glenn Hansen for a publisher who wishes to remain anonymous

I have scanned the responses to the blog posting and see that the passions on the subject run very strong and seem more than a little slanted by the cost-cutting measures many are taking in response to the recession.

I think it’s a tremendous mistake to open the door to non-direct-request electronic editions being passed off as legitimate circulation. Those who keep drawing the parallel to this being the same thing as directory copies in print are missing a number of very important differences:

The ability of BPA to monitor a directory source and monitor its relevancy to be considered qualified is in an entirely different league than attempting to wade through an e-mail database and even track the address to source, much less gauge whether each individual record is meaningful. For example, on paper, sample copy requests could be argued to be a valid indication of business interest in the subject matter. Yet we routinely get print sample copy requests with legitimate street addresses that specify an e-mail address like MickeyMouse@aol.com. Would serving these e-mails really be valid circulation?
The process of acquiring a directory and serving it with a printed edition involves hard costs that place a very effective governor on any spurious intentions a publisher may have for making inflated claims. If they want to build a circulation argument based on, say, 50,000 directory copies, it’s going to cost them dearly to do so. E-publishing provides no such built-in “bullshit barrier.” Serving 50,000 copies costs no more than serving 5.
The notion that readers place the same value in electronic editions as they do in print, raised by several blog respondents, is nonsense. If that were the case, then why would the industry average for print subscribers choosing a digital edition when given a choice consistently fall in the 3-5% range? Why would publishers—even those who have been more successful in transitioning their audiences from print to digital editions—universally decline to reveal their open rates?

We have a competitor who has merged several print titles into one, slashed the combined print distribution from 65,000 to 25,000, and is trying to build the case they reach the same audience as before by making up the difference with unrequested digital editions. For the moment they can do so with no threat of publicity violation because the new title isn’t audited, and they are taking full advantage of that, even sending out supposedly certified circulation statements designed to look like BPA’s. I would hate to think, at a time we are going to great pains to point out the value of requested circulation to our advertisers, that BPA would give implicit approval to the same strategy our competitor is pursuing.

Erin Hnath

Digital publications should be included in an audit only if it is requested. The distribution, digitally or print, is designated by the person in the way they want to receive the information. A non-requested digital edition provides little value in selling your publication to an advertiser. Your quality circulation, justified by a BPA statement, along with your editorial are your core selling tools. If you want to promote your entire measurable reach, invest in the print and interactive audit. Personally, I don't care about the extras, including pass along circulation. Someone who is selling me additional circulation that was not requested is wasting my time.

Anonymous audience development director

The question about non-requested digital delivery can best be thought about by breaking it up into its two distinct components: what is the nature of a customer's relationship ("wantedness") with a publication, and how is that publication delivered to the consumer.  Advertisers have an interest in knowing the answers to both of these questions, so publishers statements and audit rules should clearly provide that information.  But the two questions are distinct, so for BPA to say that a certain method of acquiring customers (non-requested lists, for example) is only valid under certain delivery methods (printed on paper and mailed by the post office) crosses the line from "objective, accurate and transparent" reporting into the grayer area of "subjective evaluation".

In my 20+ years experience, I have worked on many publications that had different business models, so I know there is no one-size-fits-all approach to circulation -- different B2B and B2C audiences behave and act differently, and the strategy used by each magazine to build its total circulation is shaped by the market it serves.  Advertisers rightly question the approach used by each magazine, and are entitled to form their own decisions about whether they feel the strategy used merits spending their ad dollars to reach that audience.  How much public place distribution a magazine has, or how old the lists are, or what percent of the customers fit a business industry classification code are valid and important discussions in the ad sales arena.

Method of delivery is similarly a valid topic of discussion in that arena, since consumers react to mail differently than to email.  That reaction has and will continue to change over time: consumers today interact with electronic media much differently than those same consumers did 10 years ago -- so imagine how much more different it will be 10 years from now.  So how can we suppose that one is better than the other?  Or that one is "wanted" by the audience more, and will therefore is more likely to be read rather than ignored?

Those questions can only answered in context.  For instance, a B2B publication serving java-savvy webmasters would be more likely to be read if it arrived digitally than if it did in print (whether or not that programmer requested it).  Similarly for a newspaper serving a fast-paced, young, urban, tech-savvy audience.  Or a consumer magazine serving an audience concerned about the ecology and the depletion of natural resources used to put ink on paper.  The opposite (that digital delivery would be ignored) may be true for other publications serving different audiences (a glossy fashion magazine with beautiful spreads of photo shoots, for example).  And for many publications in the middle of these extremes, the behaviors of our consumers is changing rapidly, so what is right yesterday or today may not be tomorrow.  For example, I have been reluctant to read my newspaper on my iPhone, but am becoming more adjusted to it ever since the newsstand in my apartment building lobby closed.  Did I request that digital copy of the newspaper?  I did touch the icon on the screen.  Whether I did or not, I still desired the content.  I already read many B2B publications that serve my professional needs electronically.  How soon will I be ready to do the same with other media?

And while it may be appealing to BPA to set up threshholds (non-requested digital delivery can be counted only up to a certain percent of total circulation), that too is a subjective decision best left to the advertisers.  Another audit bureau attempted that several years ago, and look at the trouble they got into (with so many rule changes and format changes to their publishers statments that even their own auditors couldn't keep track of which rules applied to which periods of time).  

The ad sales arena is the right place for the dialog about what is an appropriate strategy for buidling an audience ("why does so much of your circulation receive publications electronically -- some of the non-requested copies aren't even being read -- consumers probably think of it as spam").  The audit bureaus' responsibility is to objectively report the circulation in an accurate and transparent manner, so that the the buyer can subjectively question its appropriateness before buying an ad in a particular publication ("caveat emptor").

Caroline Riby

Keeping the opt-in is key for me in determining the value of a publication. In this day and age where anyone can send an e-mail with the click of a button, I fear that sending electronic magazines without user permission could get out of control. Furthermore even if electronic magazines are reported without the opt-in, it adds one more element for media folks to analyze. And in this economy, with the limited time we are given to analyze media, the process becomes more open for interpretation.

At least with opt-in we have insights into an audience and we know they want the product.


If the email has been requested, and deliverability has been proven, then it should count as qualified. The email is a better unique identifier than a print subscription going to just a title at an address.

MICHELLE: In reply to your comment, yes, this is the issue, was the email (or digital copy) requested or not. If not, should we at least allow it to be reported as NON-QUALIFIED?
Glenn Hansen

Cimarron Buser (Texterity)

And what about "site licenses"? Currently, BPA requires that a contract must require the administrator of the license to notify all individuals of the availability of each issue. Licenses are reported only for a specific number of seats -- and a global or corporate-wide agreement cannot be reported. What about combining the corporate-wide agreement model with a tracking/reporting 'usage' report (i.e., the number of readers per month). Perhaps we can use the new BPA/Nielsen system as a way to report these to advertisers? As a technology provider, Texterity has the means to provide IP range and "domain" content protection and authorization for any publisher, and has already incorporated the BPA/Nielsen tracking for our customers. But we need help on the best way to implement the reporting through the BPA rules that works for publishers and advertisers!

William Hindman, media buyer

We have enough problems now getting people to use the BPA Statement and I feel that if we allow non-requested electronic distribution of a publication to be classified as “qualified” (even if it can be proven the copies are going to a qualified individual), we are only cheapening our statement’s value. If a “qualified” person receives the publication but doesn’t read it (or open it), it has no value whatsoever to the advertiser...the “qualified” person” never received the advertiser’s message.

Patti Mo

I agree that BPA should consider non-request digital circulation as qualified circ, if publishers can prove that the digital recipients meet the DRQ and Field Served. Print or digital is only a medium of distribution, providing logfiles to prove successful delivery should be treated the same as print edition's mailing proof. Meanwhile, I don't think that we need to verified clicks as qualified digital circ, same as we won't be able to verify if print recipients have opened the mail and read the copy in order to be considered as qualfied circ. Print and digital should have the same auditing criteria. With the data fully disclosed, the value of digital and print circ can be left to users to evaluate.

Patti Mo
Director, Publishing Services
Reed Business Information Asia

James Vick, Publisher

I'd allow all the non-request a publisher wants to add but carefully qualify it as "non qualified" that could be upgraded once it's qualified by whatever means and language would accomplish that. Competitively I'd just dismiss it as JUNK and critical of the publisher engaging in it.

Reason I'd allow it is that it's sort of a digital forced free trial...a legit method of building qualified circ. Publishers need all the efficient tools today to maintain and build circ as possible and digital copies are quite legit...but only once properly qualified.

Bill McMillan

Since print and digital versions distribute the same content to the same audience I believe they are the same value proposition to readers and advertisers so should be treated equally in all respects.

Media and information business executives should be as free to define their business models today and tomorrow as the have been since 1731.

Circulation audit bureaus should monitor the integrity of data its members disseminate to advertisers by continually modernizing its rules and auditing techniques such as proposed in this blog.

I submit a related and perhaps more impactful rule change also be discussed.

I believe allowing members the immediate option of serving digital versions to all requesters for which they have a deliverable e-address, regardless of how the
"Do you wish?" question may have been asked, would significantly benefit most BPA media members.

Publishers should be free to decide which requesters receive print or digital based on any combination of geographic destination, demographics, economics or requester preference.

As I believe print and digital are equal value, I suggest reporting versions separately on BPA statements contributes to a misperception they're different
values or one is superior to the other.

BILL: My comment to yours...I am not sure a majority of buyers and sellers see an email with a hyperlink as a copy of a magazine. For this reason, digital may not be regarded as the same as delivered print. We need to focus on getting the majority to treat the two as the same. How does that get accomplished? I have some ideas, but I would like feedback. Glenn Hansen

Nick Pomeroy

I agree with Eric Rutter in that BPA should measure print and digital in the same manner - it is requested or not requested. If a source is taken from a directory, then this should be reported as such, regardless of the publication format. Advertisers and agencies should then be allowed to measure circulation quality on their own, or allow sales people to demonstrate such competitive advantages that may exist.

However, with the lower barriers to entry for digital circulation, it could create mis-leading scenarios. As such, the overall percentage of total non-requested digital qualified circulation should be restricted (5 or 10%), or the total click-through rates should be reported. Therefore, publishers with a high quality digital product are not penalized but through complete disclosure, the waters cannot be “muddied”.

As a publisher that does not have the benefit of USPS, Royal Mail or other national distributors that have an acceptable standard of delivery, digital products are an important way for us to reach new and existing readers. However, this still needs to be made clear to advertisers and agencies which may have a lesser view of digital formats in terms of advertising effectiveness.

Glenn Hansen for a publisher who wishes to remain anonymous

We feel pretty strongly this is a massively retrograde step for our industry. Qualified requested digital copies, though, are definitely worth the experiment.

Personally I think it would be a mistake to allow anything other than requested digital copies at this stage because:

- Digital copies are relatively new and media buyers need to gain confidence in requested copies before we risk alienating them with unrequested ones.

- At least there is a cost penalty for publishers to send out unrequested print copies but barely any for digital. Even with the possible provisos limiting them to 5-15%, this will still allow weak competitors to claim respectable overall levels of circ (and muddy waters versus our sales stories) when the best result is that the weak don’t survive this crisis.

- We must establish the highest levels of credibility with our customers and allowing unrequested digital copies will not help. Certainly there can be no question of allowing them into qualified counts.

Drew Lawler

That sounds a bit too generous. I can see if someone goes to your website and clicks on the tab to open up an issue –and counting that – as legit circ but the idea of counting it as legit circ if is it is spammed is entirely different than mailing them an issue without requesting it. At least when you mail them an issue, you know that have seen it. With spam, it can be deleted without being opened as you know…Just my thoughts…..

Niel Hiscox

I’m very uncomfortable with measuring email distribution and equating it with digital edition receipt or engagement.

A few years ago CLB Media moved our downloadable digital editions to Web-based digital editions. This enabled us to offer a much richer picture of audience interaction. We now report digital edition metrics that are similar to website metrics, which I believe offer a much better gauge of digital edition engagement than counting emails we’ve distributed that contain either a digital edition file or a link to a Web-based version.

As such, I think a solution that tries to present digital edition “circulation” alongside print circulation is going down the wrong path. I think it is more appropriate to equate digital edition measurement to website measurement. In my view, it would make sense for BPA to measure digital edition traffic with the Nielsen Online tool now being rolled out for website measurement.

This would also reinforce the visibility and value of the Nielsen Online tool, drive increased publisher adoption of it and further leverage the value of the agreement with Nielsen Online.

Staff and media buyer training is also an issue in any change BPA makes. Bringing digital edition and website measurement together under a single tool would help in that regard as well.

Yes, this would require web-based rather than downloadable digital editions, and I’m sure there are technical challenges I’m not aware of.

However, if we really want to make digital editions a valued and valuable part of our product portfolios, I think we need to steer clear of any grey areas.

BPA has committed to differentiating what it measures in print and on the Web; distribution (not engagement) in print; but engagement on the Web. I believe BPA should maintain a consistent approach in the digital space. Let’s extend the BPA Web model to our digital editions and give them the best chance at legitimacy we can.

Marlin C. Martin, III

Electronic, non-request, deliveries should BPA require an opt-in for future deliveries which could then be categorized and counted for circulation purposes. BPA required opt-out should accompany the opt-in message, so that folks will not be continually spammed. Kind regards, Marlin

Valerie Tickle

BPA should absolutely allow non request digital circulation to be counted as qualified circ. Many publishers already use names from their own audited titles as non request for related titles for print so this is no different. Spam shouldn't be an issue as any message going out must have clear opt-out language anyway. BPA must adapt quickly to the changing publication landscape or risk becoming irrelevant to Publishers

Glenn Hansen

Tim: I agree to a certain extent, which is why we introduced web measurement of the magazine brand included with every circulation audit.


However at this point, digital copies are being sold as circulation and not based on open rates nor the activity of the reader...all of which we are set up to measure and report.

If publishers were doing it this way, this entire subject would not be an issue.

Glenn Hansen

Tim Lloyd

I think this debate is in danger of overlooking the key point: that the value of e-communications is their measurability. Print publicatons rely on audited circulation because once the recipient receives his/her copy, it is difficult to accurately measure its impact or effectiveness.
Digitial communications allow you to monitor click-through and recation rates, therefore circulation should be less of an issue. Any publisher with a valuable e-product will not be depending on circulation as a USP to sell space within it, therefore I believe the BPA should be setting alternative parameters to measure effectiveness, rather than straight forward circulation.

Jim Wessel

Non-request digital circulation should absolutely be accepted as qualified circ! Quoted from James Zammit below.

Auditing procedure: Exactly the same as Qualified Digital. Request and non-request is audited the same on the print side.

ALL my publications are 100% requested circulation and have been for years. It started over 10 years ago with a competitor having 100% requester and I had 20% directory. Little did they know this great directory produced 30% postal returns every year and didn't help sell much advertising. We went to 100% requester and have become very successful because more people are responding to our advertisers. Our sales people are well trained to sell against those that are not 100% requester!

Our company focus for new acquistion and growth is digital and on-line adventures. We will maintain our shrinking print numbers as best as possible. I can say we are experiencing digital growth on all our magazine products and qualified print is shrinking.

Many of us for years have used qualified print subscriber names from one title and have placed them on related titles as non-request qualified circulation. We should all have that oportunity on the digital side if we choose.

I see a huge potential for those involved in associations. We are all bound by the Can Spam Act on the digital side and USPS on the print side to help keep some of the garbage out. If you don't like Digital, I'm sure your sales can sell against it.

The economy has changed and is REAL. One of our markets has colapsed and is off more than a million in print revenue, but is experiencing double digit growth on the digital/on-line side. Try to flushing a million in expenses. The cheese has been moved from a popular book. We must move quickly to find more before someone else finds new cheese. THIS CHANGE NEEDS TO BE MADE NOW AND EFFECTIVE FOR THE MAY 2009 STATEMENTS! It could make the difference for many Publishers faced with the same problem I am.

Jim Wessel

Kerry Knudsen

I do not agree the purpose of a BPA audit is to sell advertising. The purpose is to verify circulation. Verification is needed, because publishers have earned an unfortunate reputation for exaggeration of market coverage.
Currently, electronic communication, whether via publication on the internet or e-mail, has a poor reputation for credibility — also earned.
It is my opinion that my competitors will do absolutely anything to get away from the simple facts of our relative circulation numbers. As a publisher, the ONLY value a BPA audit has is to help my advertisers differentiate. BPA's throwing a bunch of virtual sand in my advertisers' faces with e-whatevers will not earn my business.

norman dolph

this is a slippery slope. Either the guy WANTS your magazine or he doesn't. Either your mag is vital to his business or it isn't. Either he is valuable to an advertiser or he isn't. the whole point in BPA is to separate the wheat from the chaff.
AUDIT WHEAT. let the chaff - chaff.
an opt'd in digital subsubscriber is a true and real subscriber. the rest is spam - you know that, I know that - the advertisers know that. If you are going to go loosey goosey, why bother with BPA


I support the addition of the non request e-circ but with limitations like what we have for print non request. These emails also need to be tracked and proven so spam is not counted as qualified.

James Cowart

Most publishers should support your second position. BPA needs to provide better consistency to what it allows publishers to report in this area of circulation, and if publishers can send print copies to these other channels, they should be able to do the same with digital copies as long as they disclose those other sources in a manner similar to how they do for print circulation when counts exceed 5% and 10%.

Publishers, advertising agencies and advertisers should already follow BPA’s guidance that it prints on every BPA statement cover. “No attempt has been made to rank the information in this report….” As such, the value of any content that a publisher prints in a BPA statement should be left to the user to determine its value. Restricting digital copies from getting reported prevents advertisers or advertising agencies from knowing that this type of circulation exists or could exist, which likely impedes the opportunity to grow this audience for all parties.

Cathy Donahue

I agree with James Zammitt and others who support the second proposition.

Why should we have to relegate qualified nonrequest digital circ to Par.11* Additional Data, when we can report qualified nonrequest print circ throughout the statement? Aside from the delivery mechanism, how do they differ in any significant way?

As long as we follow the CANSPAM rules and provide some sort of documentation, just as we would with print sources, I don't see this as the top of a slippery credibility slope for publishers or BPA. And, if clear rules are in place, I don't see this creating a problem for media planners either, whatever their level of experience.

*(I assume in the proposal you meant Par. 11 Additional Data and not Par. 9, which is Five Calendar Year Analysis?)

John Wengler

I agree with Eric Rutter that BPA should treat digital in the same manner as print - if publishers can prove that the digital recipients meet the DRQ and Field Served, they should be considered qualified. If BPA wants to limit the allowable circulation in certain sources (ie, business directories) that allowable percentage should carry for either print or digital.

Most, if not all digital delivery systems can provide reports showing number mailed, and number delivered, and I have no problem accepting the "delivered" number as the qualified circulation for a particular issue. This information is more efficient and auditable than postal delivery, and so should be sufficient for everyone to provide for audit.

Roy Beagley

The whole point of a BPA statement is to sell advertising. Ad sales managers tell me "that digital issues do not impress most ad buyers, so why anyone would think adding non-requested digital into the mix is a good idea is beyond me." (Publisher's quote; not mine.)

Just because we can; does not mean to say we should.

Jim Kuchinsky

For what its worth, I like position 2. I dont think BPA needs to be concerned whether its spam or not. As Stephanie Hanaway said, if you are following CANSPAM rules, there will be no problem. If you are not, someone other than BPA will regulate it.

If a subscriber is qualified by meeting the requirements of the Field Served, Definition of Recipient Qualification, and is from a valid source, then he qualifies regardless of how or what format the magazine reaches him. Any judgement as to the quality of that subscriber should be left to the advertiser.

Rich Cress

I guess that if names from a business directory are considered "qualified," then what's the difference if they're sent a print or digital version?

However, in my opinion, the only circulation that is ACTUALLY qualified are the people in the top three lines of paragraph 3b. everything else is highly suspect and mostly not worth printing & mailing. So now if you make it cheaper to send issues, will it really help advertisers? Unlikely.

How about if BPA asks publishers to include conversion rates on their BPA statements if they use digital names? In other words, if I include 5,000 digital circulation from other sources for one year, I have to then tell you that 2.6% actually qualified themselves within that year and moved-up to become part of my top three lines.

Rich Cress

mark lefens

I'm dead against the idea. It's a path down the road to the same circ-based smoke and mirrors selling our industry has engaged in for decades in print. Advertisers are demanding more hard, useful metrics and these proposed changes go in the opposite direction. The worst thing about the changes is that they will promote slick selling at the expense of good content, which is what really generates meaningful metrics.

Heidi Spangler

In my opinion, digital recipients should be considered qualified regardless of source as long as they meet the Publisher's definition of recipient qualification. The source should not matter. There are 3b source options in the print world that are all considered qualified and those same source options should be available in the digital world. Buyers make decisions based on what is reported on the BPA statement and can determine whether or not they value non-requested digital delivery on their own. BPA should not be making this determination for them.

What concerns me a great deal is the inability to convert a requested print subscriber to "communication other than request" digital. If someone requests the magazine and qualifies to receive it, provides an email address, but checks print for delivery, I have to send him a print subscription or not count him as qualified. With paper and postage expenses going up, I would like to be able to take some of these names and send them the digital edition instead of the print edition and report them as "communication other than request" digital. I have all of the information I need to qualify them and they did communicate an interest in my brand. However, under the current rules, if I switch them to digital, I cannot report them as qualified at all. This option should be available.

Eric Rutter

First of all, in the interest of full-disclosure, I proposed this change to Glenn yesterday. His original post in this string is a revised (and much improved) version of my proposal to him.

Lots of good points expressed on both sides of the issue. Clearly, there are many pros and cons.

However, my tendency is that BPA statements should be agnostic when it comes to print vs digital (aka electronic) editions.

Simply put, I believe that wherever possible, BPA should treat both print and digital in exactly the same manner.

Neither a subscriber's edition preference nor that of a publisher should not alter BPA's classification of that edition.

I agree with several of the contributors to this string. Why can a publisher report copies distributed at trade shows (albeit as non-qualified) on a BPA statement but cannot report a non-request digital copy?

I see Glenn's point regarding digital's low cost and, in turn, low barrier to entry. But I don't think that should be the driver.

Bottom line: If it's fully disclosed, the reader can make his/her own decision as to quality.

Eric Rutter
VP, Audience Marketing
Reed Business Information

Keith Biondo


My take is that it would somewhat dilute what BPA stands for. I understand the concept of caveat emptor if there is full disclosure, but with this allowable non-request electronic circulation, what is specifically is being audited? The fact that an email was sent?

I am a little old school I guess, and the reasons a publisher might give for considering this idea ought to be viewed from a publisher perspective. Nothing is stopping us from sending out emails to expand the brand and build readership. That can be done without the BPA imprimatur.

We do it at Inbound Logistics magazine. We have many more digital readers reading our Logistics Planner (66,000) than our audited circulation. And those are not emails sent, but measurable downloads. I don't report them because I don't ask the qualifier and demographic questions.

I see the reason for considering the change given your point about the economy. But consider that cut-backs are happening all over, even in agencies. I have seen media buying skills diminish over time and more so recently. If that is true, and it is not specifically BPA's or the publications' problem, then the bottom line is the finer points of media vetting are more regularly overlooked and the distinctions you draw between request and non-request, even given the safeguards you cite, are likely to be lost on the majority of media buyers.

The result is many buy top line numbers. I could be wrong but that result would lightly dilute the BPA brand in my view. Sorry. Get the publishers to answer the 'do you want this question' at the very least. Email differs from mail in that there are 2 controls: cost (a lot more than inexpensive email transmission costs) and audited postal receipts are more reliable than email logs.

If there is a business reason that accrues benefit to the BPA organization perhaps that it would broaden membership or BPA fees received then that is certainly something to factor in.

For what it is worth...

Best Regards,
Keith G. Biondo
Inbound Logistics™ Magazine

Glenn Hansen

More thoughts on the matter....While we can address electronic editions with separate reporting and added disclosures, too often we hear the users of the BPA statements (buyers and sellers) have become less knowledgeable in reading a circ statement and more time challenged. Will they take the time to read the important details, or will they simply say, “its on the BPA statement it must be good?” Is that acceptable, or should a body created to self regulate the industry do more?

Use of DART by advertisers was mentioned to track when their ad is viewed in an electronic edition. Is the business model for digital magazines changing to views? We have offered publishers to report downloaded digital copies since day one, but seven years later still none report this way.

Thinking along those lines, maybe we should report the verified clicks/views as qualified circulation, and the balance of copies sent to passive sources as non-qualified.

Glenn Hansen

Sylvia, Good points, but perhaps, there are very good reasons to be cautious regarding electronic (digital) circulation.

There are fiscal tests of reasonableness which prevent a publisher from taking a 25,000 circulation trade magazine to 125,000 circ by simply printing and posting 100,000 more copies to names found in business directories. This is not an economically feasible (or sustainable) venture. Yet for electronic copies, the pain point in cost to the publisher is far lower. Should advertisers pay for spam?

You mentioned that your advertisers use DART and are aware of when their ad is viewed as a part of your electronic copies. Is your business model to charge only for the views? What if other publishers are not using DART?

Maybe it is reasonable to allow what you suggest, but place a cap on publishers' total non-request electronic circulation…5%, 10%, 15% etc.? This would keep the spam concern in check.

You also note that “providing advertisers with measurement of their advertising is more significant than any paragraph 3b sourcing.” If that is as you believe, then I presume you would support sending the electronic copies unsolicited as a promotional campaign (count copies as non-qualified), but only count those who click to view as bona fide recipients. The delivery mechanism is not a magazine in the post, but rather an e-mail with a hyperlink (not even a PDF attachment). The recipient, by clicking on the link takes a proactive step to view the magazine…one might say to “request” the magazine (3b sourcing). These clicks are easily tracked. Why not count these recipients as having requested copies?

At present, BPA does not include copies of a electronic copy solicitation promotional campaign as non-qualified. We do not allow the reporting of these copies at all. Perhaps we should, particularly if there are substantive demographics to support each person sent the e-mail hyperlink. Why not report this demo information?

You referenced ABC and asked for parity. Let’s have a representative from ABC comment on this blog and explain their rationale for accepting unsolicited e-mailed hyperlinks that qualify as magazine delivery. There must be some logic to it. If it makes sense for the industry, you will find us in complete support!

Douglas Hebbard

Another factor to be considered is the source of the e-mail address. Any "qualified" reader who has provided a valid address, even if they have never requested an electronic copy, is a more "qualified" reader than someone whose address was plucked from thin air -- or whose e-mail address is being "repurposed".

I would second Sylvia's comment about use of directory names under the qualified subscriber category. BPA should not fear qualified digital subscribers as much as the continued degrading of the term "qualified" as regards to print copies.

Kieran Anderson

I tend to believe that allowing publishers the ability to include non-request recipients of the "digital" versions of their print properties in their qualified circulation numbers on the BPA statement; is an excellent idea. I'm not sure what the exact difference is, but if you have opt-in recipients of your digital properties, shouldn't these be seen as a 'qualified' requests, since they've asked to receive it?

I would also suggest that this information is displayed prominently in Paragraph 3a rather than Paragraph 9, which I feel is overlooked unless you are dealing with a savvy media agency/person.

As publishers, we must justify our circulation to advertisers who are all facing their own challenges as budgets and resources tighten.

The reality is that many publishers are seeing an increase in online visitation and activity and this is just the beginning of what is to come. We are figuring out how to best monetize this transition to digital, while protecting our print properties and to do so, it has to be qualified in order to justify the enhanced / increased circulation of our content to our advertisers, which can then be converted into additional revenue in these tough times.

Stephanie Hanaway

I support position #2, and wholeheartely agree with Sylvia that it makes no sense that directory names are considered qualified for print but not for digital when digital is the medium that can be measured! I do agree that BPA should only count those emails that can be proven to have been delivered, but should not impose a bunch of other safeguards that are already imposed by CANSPAM anyway. Just require that all CANSPAM rules be followed.

Rob Chambers

Although it is appealing at first glance to bolt on non-requested digital circulation, this is simply multiplying the 'spam' problem. Making it required that delivery could be proved is one partial solution, but even this does not alleviate the concern of many advertisers / agencies that digital copies are not read and worse that advertising is not noted. I believe that it should remain a requirement that digital copies are requested.

p malm

Explicit opt-in should be required. Lower numbers but separates wheat from chaff. If an e-newsletetr can't exist based upon how many people actually want to receive it, it shouldn't be in the market. Spam is spam is spam and BPA should put its stake in the ground to stop it.

James Zammit, B2B Circ Pro

Non-request digital circulation should absolutely be accepted as qualified circ.

BPA obviously accepts printed non-request distribution as qualified circulation - and publishers are able to support this by providing print and postage invoices.

Similar to auditing requested digital circulation, the publisher should provide electronic log files to verify successful delivery of the digital copies. If a publisher isn't able to internally generate and furnish acceptable logs/reports, there are many service providers who are very good at doing this, at nominal rates.

Opt-out options within the e-mail notification should be in place, and opt-out requests should most definately be honored and fulfilled at the publisher level.

BPA does not limit non-request print circulation, so why limit non-request digital circ? Other than the method in which the publication is delivered, what's the difference between non-request print circ vs. non-request digital circ?

Aside from the challenging economic climate, publishing is simply moving faster and more aggressivlely into the digital world, employing the web to extend reach and build brand awareness. BPA needs to respond to this and allow the reporting of qualified non-request digitial circulation.

sylvia sierra

I encourage BPA to have parity of rules with ABC, as they allow reporting of digital of all sources.
On our digital only product advertisers are tagging their ads with DART code and they will be able to measure the results of their ads on a meanignful way, including number of impressions to be delivered. Providing advertisers with measurement of their advertising is more significant than any paragraph 3b sourcing.
I fail to understand why BPA allows media companies to send a print product to a name pulled from a directory and consider those recepients qualified subscribers, and yet, on a medium that has response metrics and transparency we are not allowed to consider them qualified.

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