10. It is difficult for potential users to find information about CJB.NET's advertising

practices.  The FAQ page does not disclose anything about a user agreement or the use of

adware.

7

  Visitors to the signup page at www.cjb.net must click on a hyperlink located in

the lower right corner of the Web site to learn about CJB.NET's policies that is,

contractual terms that bind the user to distribute invasive advertising software through

their CJB.NET hosted Web site.  When a visitor to the site clicks on the  Policies  link,

they learn that  CJB Management, Inc. reserves the right to send you advertisements and

promotional offers and to place advertisements on the services we provide to you. You

authorize CJB Management, Inc. to provide your contact information to third parties for

the purpose of sending you advertisements and promotional offers. 

8

  Additionally,  By

using CJB.NET, you agree to be bound by these terms and conditions. If you do not wish

to be bound by these terms and conditions, you may not use CJB.NET. 

11. While CJB.NET does provide customers with some notice that they will receive

advertisements, those customers are not informed that anyone who visits a free Web site

hosted by CJB.NET will be prompted to download advertising programs onto their

computers.  The 180solutions Zango product is among the advertising programs that are

distributed through CJB.NET.

12. CDT was first made aware of CJB.NET's deceptive practices on November 14, 2005,

when a blog that tracks spyware and adware called attention to several Web sites hosted

by CJB.NET.

9

  The blog highlighted several of the problems with CJB.NET's security

warnings and End User License Agreements (EULAs), which were later confirmed

through further research by CDT and the Technology Law & Public Policy Clinic.

10

13. Visitors to CJB.NET hosted Web sites are also inadequately notified about the

company's advertising policies.  When visitors navigate to CJB.NET hosted sites, they

are prompted with security warning (ActiveX) notices that appear to require them to

download a program to properly view the Web site.  The name of the program to be

downloaded is given as  Web site Access By Zango Search Tools  in the ActiveX

prompt.  Visitors that click  Yes,  likely make the logical assumption based on the

prompt that in order to view the Web site hosted by CJB.NET, they need to download the

 Web site Access  program created by 180solutions.  This is not the case.  Neither the

Zango product nor any other additional software is in fact required to view CJB.NET 

hosted Web pages.

14.  Eventually, users/webmasters are given a prompt from 180solutuons.  The license

agreement appears in a wide, short window that is difficult for many users to read and

does not reliably work on all browsers.

7

 See http://www.cjb.net/help.html.

8

 See http://www.cjb.net/policies.html (emphasis added).

9

 See http://netrn.net/spywareblog/archives/2005/11/13/180solutions sponsors class of second graders in 

ohio.

10

 See Appendices 1A and 1B, infra.

4