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  a newsletter by |_| j. b. crawford               home archive subscribe rss

>>> 2024-06-08 dmv.org (PDF)

The majority of US states have something called a "Department of Motor Vehicles," or DMV. Actually, the universality of the term "DMV" seems to be overstated. A more general term is "motor vehicle administrator," used for example by the American Association of Motor Vehicle Administrators to address the inconsistent terminology.

Not happy with merely noting that I live in a state with an "MVD" rather than a "DMV," I did the kind of serious investigative journalism that you have come to expect from me. Of These Fifty United States plus six territories, I count 28 DMVs, 5 MVDs, 5 BMVs, 2 OMVs, 2 "Driver Services," and the remainder are hard to describe succinctly. In fact, there's a surprising amount of ambiguity across the board. A number of states don't seem to formally have an agency or division called the DMV, but nonetheless use the term "DMV" to describe something like the Office of Driver Licensing of the Department of Transportation.

Indeed, the very topic of where the motor vehicle administrator is found is interesting. Many exist within the Department of Transportation or Department of Revenue (which goes by different names depending on the state, such as DTR or DFA). Some states place driver's licensing within the Department of State. One of the more unusual cases is Oklahoma, which recently formed a new state agency for motor vehicle administration but with the goal of expanding to other state customer service functions... leaving it with the generic name of Service Oklahoma.

The most exceptional case, as you'll find with other state government functions as well, is Hawaii. Hawaii has deferred motor vehicle administration to counties, with the Honolulu CSD or DCS (they are inconsistent!) the largest, alongside others like the Hawaii County VRL.

So, the point is that DMV is sort of a colloquialism, one that is widely understood since the most populous states (CA and TX for example) have proper DMVs. Florida, third most populous state, actually has a DHSMV or FLHSMV depending on where you look... but their online services portal is branded MyDMV, even though there is no state agency or division called the DMV. See how this can be confusing?

Anyway, if you are sitting around on a Saturday morning searching for the name of every state plus "DMV" like I am, you will notice something else: a lot of... suspicious results. guamtax.com is, it turns out, actually the website of the Guam Department of Revenue and Taxation. dmvflorida.org is not to be confused with the memorable flhsmv.gov, and especially not with mydmvportal.flhsmv.gov. You have to put "portal" in the domain name so people know it's a portal, it's like how "apdonline.com" has "online" in it so you know that it's a website on the internet.

dmvflorida.org calls itself the "American Safety Council's Guide to the Florida Department of Motor Vehicles." Now, we have established that the "Florida Department of Motor Vehicles" does not exist, but the State of Florida itself seems a little confused on that point, so I'll let it slide. But that brings us to the American Safety Council, or ASC.

ASC is... It's sort of styled to sound like the National Safety Council (NSC) or National Sanitation Foundation (NSF), independent nonprofits that publish standards and guidance. ASC is a different deal. ASC is a for-profit vendor of training courses. Based on the row of badges on their homepage, ASC wants you to know not only that they are "Shopper Approved," "Certifiably Excellent (The Stats To Prove It)," they have won a "5-Star Excellence Award" (from whom not specified), and that the Orlando Business Journal included their own John Comly on its 2019 list of "CEOs of the Year."

This is the most impressive credential they have on offer besides accreditation by IACET, an industry association behind the "continuing education units" used by many certifications, and which is currently hosting a webinar series on "how AI is reshaping learning landscapes from curriculum design to compliance." This does indeed mean that, in the future, your corporate sexual harassment training will be generated by Vyond Formerly GoAnimate based on a script right out of ChatGPT. The quality of the content will, surprisingly, not be adversely affected. "As you can see, this is very important to Your Company. Click Here [broken link] to read your organization's policy."

In reality, ASC is a popular vendor of driver safety courses that businesses need their employees to take in order to get an insurance discount. Somewhere in a drawer I have a "New Mexico Vehicle Operator's Permit," a flimsy paper credential issued to state employees in recognition of their having completed an ASC course that consisted mostly of memorizing that "LOS POT" stands for "line of sight, path of travel." Years later, I am fuzzy on what that phrase actually means, but expanding the acronym was on the test.

We can all reflect on the fact that the state's vehicle insurance program is not satisfied with merely possessing the driver's license that the state itself issues, but instead requires you to pass a shorter and easier exam on actually driving safely. Or knowing about the line of sight and the path of travel, or something. I once took a Motorcycle Safety Foundation course that included a truly incomprehensible diagram of the priorities for scanning points of conflict at an intersection, a work of such information density that any motorcyclist attempting to apply it by rote would be entirely through the intersection and to the next one before completing the checklist. We were, nonetheless, taught as if we were expected to learn it that way. Driver's education is the ultimate test of "Adult Learning Theory," a loose set of principles influential on the design of Adobe Captivate compliance courses, and the limitations of its ability to actually teach anyone anything.

This is all a tangent, so let's get back to the core. ASC sells safety courses and... operates dmvflorida.org?

Here's the thing: running DMV websites is a profitable business. Very few people look for the DMV website because they just wanted to read up on driver's license endorsements. Almost everyone who searches for "<state name> DMV" is on the way to spending money: they need to renew their license, or their registration, or get a driving test, or ideally, a driver's ed course or traffic school.

The latter are ideal because a huge number of states have privatized them, at least to some degree. Driver's ed and traffic school are both commonly offered by competitive for-profit ventures that will split revenue in exchange for acquiring a customer. I would say that dmvflorida.org is a referral scam, but it's actually not! it's even better: it's owned by ASC, one of the companies that competes to offer traffic school courses! It's just a big, vaguely government-looking funnel into ASC's core consumer product.

In some states, the situation is even better. DMV services are partially privatized or "agents" can submit paperwork on the behalf of the consumer. Either of these models allow a website that tops Google results to submit your driver's license renewal on your behalf... and tack on a "convenience fee" for doing so. Indeed, Florida allows private third-parties to administer the written exam for a driver's license, and you know dmvflorida.org offers such an online exam for just $24.95.

You can, of course, renew your driver's license online directly with the state, at least in the vast majority of cases. so how does a website that does the same thing, with the same rates, plus their own fee, compete? SEO. Their best bet is to outrank the actual state website, grabbing consumers and funneling them towards profitable offerings before they find the actual DMV website.

There's a whole world of DMV websites that operate in a fascinating nexus of SEO spam, referral farm, and nearly-fraudulent imitation of official state websites. This has been going on since, well, I have a reliable source that claims since 1999: dmv.org.

dmv.org is an incredible artifact of the internet. It contains an enormous amount of written content, much of it of surprisingly high quality, in an effort to maintain strong search engine rankings. It used to work: for many years, dmv.org routinely outranked state agency websites for queries that were anywhere close to "dmv" or "renew driver's license" or "traffic school." And it was all in the pursuit of referral and advertising revenue. Take it from them:

Advertise with DMV.ORG

Partner with one of the most valuable resource for DMV & driving - driven by 85% organic reach that captures 80% of U.S drivers, DMV.ORG helps organize the driver experience across the spectrum of DMV and automotive- related information. Want to reach this highly valued audience?

dmv.org claims to date back to 1999, and I have no reason to doubt them, but the earliest archived copies I can find are from 2000 and badly broken. By late 2001 the website has been redesigned, and reads "Welcome to the Department of Motor Vehicles Website Listings." If you follow the call to action and look up your state, it changes to "The Department of Motor Vehicles Portal on the Web!"

They should have gone for dmvportal.org for added credibility.

In 2002, dmv.org takes a new form: before doing pretty much anything, it asks you for your contact information, including an AOL, MSN, or Yahoo screen name. They promise not to sell your address to third parties but this appears to be a way to build their own marketing lists. They now prominently advertise vehicle history reports, giving you a referral link to CarFax.

Over the following months, more banner ads and referral links appear: vehicle history reports, now by edriver.com, $14.99 or $19.99. Driving record status, by drivingrecord.org, $19.99. Traffic School Online, available in 8 states, dmv-traffic-school.com and no price specified. The footer: "DMV.ORG IS PRIVATELY OPERATED AND MAINTAINED FOR THE BENEFIT OF ITS USERS."

In mid-2003, there's a rebranding. The header now reads "DMV Online Services." There are even more referral links. Just a month later, another redesign, a brief transitional stage, before in September 2003, dmv.org achieves the form familiar to most of us today: A large license-plate themed "DMV.ORG" logotype, referral links everywhere, map of the US where you can click on your state. "Rated #1 Site, CBS Early Show."

This year coincides, of course, with rapid adoption of the internet. Suddenly consumers really are online, and they really are searching for "DMV." And dmv.org is building a good reputation for itself. A widely syndicated 2002 newspaper article about post-marriage bureaucracy (often appearing in a Bridal Guide supplement) sends readers to dmv.org for information on updating their name. The Guardian, of London, points travelers at dmv.org for information on obtaining a handicap placard while visiting the US.

You also start to see the first signs of trouble. Over the following years, an increasing number of articles both in print and online refer to dmv.org as if it is the website of the Department of Motor Vehicles. We cannot totally blame them for the confusion. First, the internet was relatively new, and reporters had perhaps not learned to be suspicious of it. Second, states themselves sometimes fanned the flames. In a 2005 article, the director of driver services for the Mississippi Department of Transportation tells the reporter that you can now renew your driver's license online... at dmv.org.

dmv.org was operated by a company called eDriver. It's hard to find much about them, because they have faded into obscurity and search results are now dominated by the lawsuit that you probably suspected is coming. The "About Us" page of the dmv.org of this period is a great bit of copywriting, complete with dramatic stories, but almost goes out of its way not to name the people involved. "One of our principals likes to say..."

eDriver must not have been very large, their San Diego office address was a rented mail box. Whether or not it started out that way is hard to say, but by 2008 eDriver was a subsidiary of Biz Groups Inc., along with Online Guru Inc and Find My Specialist Inc. These corporate names all have intense "SEO spam" energy, and they seem to have almost jointly operated dmv.org through a constellation of closely interlinked websites. In 2008, eDriver owned dmv.org but didn't even run it: they contracted Online Guru to manage the website.

Biz Groups Inc was owned by brothers Raj and Ravi Lahoti. Along with third brother David, the Lahotis were '00s domain name magnates. They often landed on the receiving end of UDRP complaints, ICANN's process for resolving disputes over the rightful ownership of domain names. Well, they were in the business: David Lahoti owns UDRP-tracking website udrpsearch.com to this day.

Their whole deal was, essentially, speculating on domain names. Some of them weren't big hits. An article on a dispute between the MIT Scratch project and the Lahotis (as owners of scratch.org) reads "Ravi updated the site at Scratch.org recently to includes news articles and videos with the word scratch in them. It also has a notice that the domain was registered in 1998 and includes the dictionary definition of scratch."

Others were more successful. In 2011, Raj Lahoti was interviewed by a Korean startup accelerator called beSuccess:

My older brother Ravi was the main inspiration behind starting OnlineGURU. Ravi owned many amazing domain names and although he didn't build a website on every one of his domains, he DID build a small website at www.DMV.org and this website started doing well. Well enough that he saw an opportunity to do something bigger with it and turn it into a bigger business.

And he is clear on how the strategy evolved to focus on SEO farming:

Search Engine Marketing and Search Engine Optimization has definitely been most effective in my overall marketing strategy. The beautiful thing about search engines is that you can target users who are looking for EXACTLY what you offer at the EXACT moment they are looking for it. Google Adwords has so many tools, such as the Google Keyword Tool where you can learn what people are searching for and how many people are searching the same thing. This has allowed me to learn about WHAT the world wants and gives me ideas on how I can provide solutions to help people with what they are looking for.

Also, San Diego Business Journal named Raj Lahoti "among the finalists of the publication's Most Admired CEO award" in 2011. So if he ever meets John Comly, they'll have something to talk about.

The thing is, the relationship between dmv.org and actual state motor vehicle administrators became blurrier over time... perhaps not coincidentally, just as dmv.org ascended to a top-ranking result across a huge range of Google queries. It really was a business built entirely on search engine ranking, and they seemed to achieve that ranking in part through a huge amount of content (that is distinctly a cut above the nearly incoherent SEO farms you see today), but also in part through feeding consumer confusion between them and state agencies. I personally remember ending up on dmv.org when looking for the actual DMV's website, and that was probably when I was trying to get a driver's license to begin with. It was getting a bit of a scammy reputation, actual DMVs were sometimes trying to steer people away from it, and in 2007 they were sued.

A group of website operators in basically the same industry, TrafficSchool.com Inc and Driver's Ed Direct, LLC, filed a false advertising suit against the Online Guru family of companies. They claimed not that dmv.org was fraudulent, but that it unfairly benefited from pretending to be an official website.

Their claim must have seemed credible. At the beginning of 2008, before the lawsuit made it very far, dmv.org's tagline changed from "No need to stand IN LINE. Your DMV guide is now ON LINE!" to "Your unofficial guide to the DMV." This became the largest indication that dmv.org was not an official website, supplementing the small, grey text that had been present in the footer for years.

The judge was not satisfied.

See, the outcome of the lawsuit was sort of funny. The court agreed that dmv.org was engaging in false advertising under the Lanham Act, but then found that the plaintiffs were doing basically the same thing, leaving them with "unclean hands." Incidentally, they would appeal and the appeals court would disagree on some details of the "unclean hands" finding, but the gist of the lower court's ruling held: the plaintiffs would not receive damages, since they had been pursuing the same strategy, but the court did issue an injunction requiring dmv.org to add a splash screen clearly stating that it was not an official website.

The lawsuit documents are actually a great read. The plaintiffs provided the court with a huge list of examples of confusion, including highlights like a Washington State Trooper emailing dmv.org requesting a DUI suspect's Oregon driving records. dmv.org admitted to the court that they received emails like this on "a daily basis," many of them being people attempting to comply with mandatory DUI reporting laws by reporting their recent DUI arrest... to Online Guru.

The court noted the changes made to dmv.org in early 2008, including the "Unofficial" heading and changing headings from, for example, "California DMV" to "California DMV Info." But those weren't sufficient: going forward, users would have to click "acknowledge" on a page warning them.

It is amusing, of course, that the SEO industry of the time interpreted the injunction mainly in the SEO context. This was, after all, a website that lived and died by Google rankings, part of a huge industry of similar websites. Eric Goldman's Technology and Marketing Law Blog wrote that "My hypothesis is that such an acknowledgment page wrecks DMV.org’s search engine indexing by preventing the robots from seeing the page content."

The takeaway:

This suggests a possible lesson to learn from this case. The defendants had a great domain name (DMV.org) that they managed to build nicely, but they may have too aggressive about stoking consumer expectations about their affiliation with the government.

It's wild that "get a good domain name and pack it with referral links" used to be a substantial portion of the internet economy. Good thing nothing that vapid survives today! Speaking of today, what happened to dmv.org?

Well, the court order softened over time, and the acknowledgment page ultimately went away. It was replaced by a large, top-of-page banner, almost comically reminiscent of those appearing on cigarettes. "DMV.ORG IS A PRIVATELY OWNED WEBSITE THAT IS NOT OWNED OR OPERATED BY ANY STATE GOVERNMENT AGENCY." Below that, the license plate dmv.org logotype, same as ever.

Besides, they reformed. At sustainablebrands.com we read:

Over our 10-year history, DMV.org’s mission has shifted entirely from profit to purpose. We not only want to bring value to our users by making their DMV experience easier, we ultimately want to reduce transportation-related deaths, encourage eco-friendly driving habits, and influence other businesses to reduce their carbon footprints and become stewards of change themselves.

This press-release-turned-article says that they painted "the company’s human values on our wall, to remind ourselves every day what we’re here for and why" and that, curiously, dmv.org "potentially aim[s] to" "eliminate Styrofoam from local eateries." The whole thing is such gross greenwashing, bordering on incoherent, that I might accuse it of being AI-generated were it not a decade old.

dmv.org lived by Google and, it seems, it will die by Google. Several SEO blogs report that, sometime in 2019, Google seems to have applied aggressive manual adjustments to a list of government-agency-like domain names that include irs.com (its whole own story) and dmv.org. Their search traffic almost instantaneously dropped by 80%.

dmv.org is still going today, but I'm not sure that it's relevant any more. I tried a scattering of Google queries like "new mexico driver's license" and "traffic school," the kind of thing where dmv.org used to win the top five results, and they weren't even on the first page. Online Guru still operates dmv.org, and "dmv.org is NOT your state agency" might as well be the new tagline. Phrases like that one constantly appear in headings and sidebars.

They advertise auto insurance, and will sell you online practice tests for $10. Curiously, when I look up how to renew my driver's license in New Mexico, dmv.org sends me to the actual NM MVD website. That's sort of a funny twist, because New Mexico does indeed allow renewal through private service providers that are permitted to charge a service fee. I don't think dmv.org makes enough money to manage compliance with all these state programs, though, so it's actually returned to its roots, in a way: just a directory of links to state websites.

Also, there's a form you can fill out to become a contributor! Computers Are Bad has been fun, but I'm joining the big leagues. Now I write for dmv.org.