The Electronic Privacy Information Center (EPIC), the Center for Digital Democracy (CDD) and the U.S. Public Interest Research Group (U.S. PIRG) laid out an additional 15 remedies they maintain are essential to protecting consumer privacy in the face of GoogleClick's unprecedented ability to construct extremely intimate portraits of users' behaviors.

Among their requests: require Google to stipulate it will never engage in behavioral tracking, cease storage of IP addresses, and maintain separate databases of user information for Google and DoubleClick.

In addition, the groups seek a stipulation ordering Google to give a user the right to learn what data has been collected on him or her and then have the ability to delete that information.

An opt-in approach is also recommended before allowing Google to collect any personal data to personalize search experiences.

"The potential for great profit associated with the large amount of data that would be readily accessible as the result of a merger may prove to be too tempting, and there is nothing preventing Google from reversing its stance and beginning to sell or otherwise distribute personally identifiable information," the complaint warns.

Since the trio filed its initial complaint on April 20, the FTC has made a "second request" of Google for additional information and supplementary materials. European regulators are investigating Google's data collection practices, and the New York State Consumer Protection Board endorsed the EPIC complaint.

EPIC's latest filing was motivated by the FTC director's own statement that it only makes a second request in cases where there are strong probabilities of an issue, said Marc Rotenberg, executive director of EPIC.

"We think the scale of this transaction in terms of its new threat to consumer privacy is so significant that the FTC cannot in any way approve it unless it ensures the consumer's privacy is protected," said Jeff Chester, CDD executive director.

Added PIRG's consumer program director Ed Mierzwinski: "We think the growth of sophisticated tracking has snuck up on consumers and regulators."

The combined online/offline window Google has into consumers through applications that draw on credit-card data, personal calendars and other tools demonstrates that there is no longer a clear line between online and offline, Mierzwinski added, calling it a "richer environment for developing a dossier on consumers."

Without the FTC forcing the case, the complaint maintains, Google's privacy policy is both subject to change and cannot be legally enforced.

The FTC is "aware this is a unique transaction that goes to the heart of the Internet economy," said Chester. "I think we're confident that our amended complaint is getting the attention it deserves."

The dominance of the Google/DoubleClick combination might also inspire a "race to the bottom" of best practices by smaller companies faced with no other way to compete, they warned.

Google last week announced its expansion into the RSS field with the acquisition of FeedBurner, the leader in distributed content.

The search giant also retained lobbyist Makan Delrahim, a former deputy assistant general in the Justice Department's antitrust division, to help win approval of the deal.

The Association of National Advertisers and American Association of Advertising Agencies have gone on record with the FTC expressing concern about the impact the marriage of the world's largest search company with the world's largest online advertising company would have on the industry.

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