I’m just posting up in a main article, answers to some of the questions I asked of Phorm as they were published in the comments section of another post and just in case anyone missed them.

I’m still waiting on answers to the other ones but at least they’ve been good enough to address these so far.

Here you go:

1. Phorm changed their name from 121 Media Inc as of their AGM on 26 April
2007. What was the rational behind this decision?

As we began to grow and hire more people and looked to international
markets, we realised that our name 121Media was a play on words that only
really worked in English and it wasn’t a very good play on words at that.
It’s true that England and America are divided by a common language — often
when we spoke to Americans they called us one-twenty-one media, so we
thought we needed a better name — one that reflected a company that can
help the internet change, or morph, around your interests.

2. Can you tell me what the financial position of Phorm was at the end of
the financial year for 2007 ie, end of December 2007 as we¹re talking US
financial years. In particular, what was the annual turnover of the company,
it¹s gross and net profits/losses and it¹s capital value?

Please see all of our accounts that are published on the website:
www.phorm.com/investors
Also, every market announcement we’ve made to the market is available on our
site. Www.phorm.com/announcements

3. I understand that you are paying British ISP¹s large quantities of money
to be able to be able to put your system into their networks. The much
quoted figure for your payment to BT is £85million. Can you confirm or rebut
this figure and what are the relevant figures for Talk Talk and Virgin
Media?

That’s wrong. We are not paying ISPs anything. More relevant advertising is
more valuable and so the OIX creates value throughout the advertising chain:
websites make more money (including blogs and the ‘long tail’ as what
matters is that an interested person is looking at the site, not what’s on
the site), advertisers get better ROI, consumers see ads that are more
interesting or relevant (eg sales). In addition, the OIX will not serve pop
ups or pop unders. There is a revenue share between the ISP and phorm.
Please see the phorm.com site for a diagram of revenue flows. The figure
from Investec took into account trends in online advertising spend and other
factors.

4. If Phorm possess the kind of money you are rumoured to be offering
various ISP¹s and based on the registered losses of the company for 2005 and
2006, where is this money coming from? Or in the case that the money doesn¹t
exist but your company has been underwritten in some kind of agreement on
assumption of future profitability based on your business model, who¹s doing
the underwriting?

As above. We are not paying the ISPs anything.

5. Your site claims that you have already confirmed deals with BT, Virgin
Media and Talk Talk, have you confirmed deals with any other UK ISP¹s to
date and which ISP¹s are you currently in discussions with to provide this
service?

These are commercially confidential.

6. How many employees does Phorm have working for it, encompassing all
geographical areas of operation? By this the assumption is that you have
employees in the UK and the US or indeed anywhere else in the world.

We have approximately 145 employees worldwide, located in the UK, US and
Russia.

7. In which countries do Phorm have any kind of fixed operational base or
employees?

As above.

8. Do Phorm have any operational bases or data communications services in
either China or Russia?

Yes we have a development team in Russia (we also have dev teams in London
and New York)

9. I¹m sure you can understand people¹s concerns that a company which on
paper only appears to have a virtual and or shared office space in London
and an address in Delaware in the US that has previously been identified as
a base of operations or indeed simply a forwarding mail service for e-mail
spam/scams so I¹d like to ask a few questions regarding these two registered
addresses.

Concerning your London offices:

10. The company that runs your London address is advertised as offering
virtual offices. shared desks for those who rent space there for when
they¹re needed and also a ¹serviced office¹ arrangement comprising of staff
to answer calls for companies who rent space and to forward on mail. Can you
confirm a few things regarding your London set up?

11. Is anyone permanently stationed within these premises or are they
operated as a virtual office and temporary for employees taking advantage of
the Œhot desking¹ facility?

Yes people are permanently stationed here. We have approximately 60 full
time people in London. If you saw the clutter on our desks you would realise
the impossibility of any hot desking

If you’re in any doubt about whether the offices are real, then do contact
Jack Marshall at ClickZ or Chris Williams at The Register who came to visit
us here.

See the following articles:

Clickz
The Register

12. (Determinate on the last question) How many employees does Phorm have
permanently based in your London registered address?

About 60 noted as above

13. I don¹t expect you to get the tape measure out but what is the rough
office space area that Phorm take up in these premises?

It’s big — enough for 60 people and their clutter. Political Penguin, I
think we’ve invited you to come and see us? If not, then consider the
invitation extended. Email me.

Concerning your US office:

14. I know it sounds pedantic, but does this address actually exist or is it
simply a mail forwarding service?

It exists. It is not a mail forwarding service

15. (Determinate on the last question) How many employees are permanently
based in your US registered office?

I guess about 40 people

16. Again, what is the approximate size of this base of operations in terms
of office space taken up?

Smaller than UK — smaller desks. With those American dividers.

Getting a little bit techie now.

17. It is a common trait of scam operators is to register domain names via
proxy domain registrars. Although it is not necessarily appropriate to make
assumptions of a company based on the practices of others why have you
registered www.phorm.com, www.webwise.com and www.oix.com via the use of a
proxy registrar instead of an open registration that is linked to the
address of one of your offices be it the one in the US or the one in the UK?

Not sure — will get back to you. But I know that ahead of the announcement
we did not want a leak so we were careful not to give our brand names away.

18. You claim that you have been assessed by Privacy International. Can you
explain why there is no reference to ŒPhorm¹ on their website and if this
assessment is available can you tell us both who from Privacy International
undertook it and publish a copy?

I’ve tried to clarify this here and on other blogs, and it’s true that Kent
does refer to PI when in fact the Privacy Impact Assessment was conducted by
Simon Davies of 80/20 Thinking, a privacy consulting firm. Simon is the
director of Privacy International and he and a colleague at Privacy
International, Gus Hosein, conducted the assessment. As I have mentioned
before Simon is known for his unforgiving scrutiny so we felt he was the
best man for the job.

19. Who has Phorm asked to evaluate the legal position of their technology
in respect of both the Data Protection Act 1999 and the Regulation of
Investigative Powers Act 2000 and if such a report has been compiled, can
you publish it?

Consumer privacy protection is of paramount importance for us (remember,
we’ve built a system that stores no data — and it’s been designed that way.
We haven’t bolted on privacy protection as an afterthought. We built the
technology so as we can never know who you are, where you’ve browsed).

Our technology complies with the Data Protection Act, RIPA and other
applicable UK law.