Google was hit by a $22.5 million penalty as a result of an investigation by the Federal Trade Commission covering Google’s practices with users of the Safari browser. A very interesting aspect of this new case against Google (Google 2), is that it raises the issue of Google’s violation of the Self-Regulatory Code of Conduct of the Network Advertising Initiative (NAI Code). This is an interesting evolution in the history of the FTC rulings. At first, the FTC focused on violation of privacy promises made in Privacy Statements, then it went on to pursue violation of the Safe Harbor Principles. In this new iteration, the FTC attacks misrepresentation of compliance with industry standard.