NeoMarketing: Profit Engineering for Rule of 40 and CMO Comeback (Part 5)

Impossible to Inevitable

Each of NeoMarketing’s four breakthrough technologies solves problems that were previously considered impossible within traditional marketing frameworks. These represent fundamental capabilities that transform how businesses approach customer relationships and profit generation and unlock the pathway to Rule of 40 outperformance.

AI Agents: Beyond Human-Scale Personalisation

Traditional marketing operates under a constraint that has never been openly acknowledged: true personalisation doesn’t scale. Creating individual experiences for thousands of customers requires human insight and creativity that no team can provide economically. Even sophisticated martech platforms operate through broad segmentation because the alternative—individual customer journeys—demands more human input than businesses can afford.

AI Agents Collective eliminates this constraint by enabling “segments of few” that can scale down to individual customers. Through specialised agents handling audience segmentation, content creation, journey orchestration, and performance analysis, brands can create truly personalised experiences without proportional increases in human overhead.

For Best customers, AI Twins provide conversational interfaces that understand context, preferences, and timing in ways that traditional automation cannot match. These aren’t chatbots—they’re sophisticated customer advocates that can engage in meaningful dialogue, understand complex requests, and coordinate responses across multiple business systems. This level of individual attention was previously exclusive to luxury retail or high-touch B2B sales environments.

Progency: Bridging the Execution Gap

Most businesses understand retention theory but struggle with retention execution. The gap between knowing what should be done and having the capability to do it systematically represents one of marketing’s greatest challenges. In-house teams face bandwidth constraints, technology integration complexities, and the need to balance retention with acquisition responsibilities.

Progency provides capabilities that internal teams cannot replicate: dedicated specialists focused exclusively on customer lifecycle optimisation, AI-powered automation that operates continuously rather than in campaign bursts, and performance-based accountability that aligns vendor success with client outcomes. This infrastructure enables sophisticated strategies like predictive intervention, behavioural trigger automation, and systematic Rest-to-Best migration that require dedicated focus and specialised expertise.

NeoMails: Solving Attention Recession

Email marketing faces a fundamental economic problem: traditional ESPs charge based on volume, creating misaligned incentives for engagement quality. Brands pay more to send more emails, regardless of whether those emails create value for recipients or businesses. This volume-based model encourages frequency over relevance, contributing to the attention recession that plagues digital marketing.

NeoMails operates on fundamentally different economics—zero CPM engagement through interactive email experiences that create value for recipients. By building habit-forming daily touchpoints that feel more like app experiences than traditional email campaigns, NeoMails reclaim attention without paying platform taxes. This shift from interruption-based to invitation-based engagement represents a fundamental evolution in how brands maintain ongoing customer relationships.

NeoN: Cooperative Ad-vantage

Platform dependency creates a structural disadvantage where brands compete for customer attention through intermediaries who capture 20-30% of transaction value. Traditional retargeting compounds this problem by charging premium prices to reach customers brands already know, creating the AdWaste crisis that erodes profitability as businesses scale.

NeoN’s brand-to-brand cooperative network eliminates these intermediaries through authenticated identity targeting based on deterministic PII matching rather than probabilistic cookies. Participating brands simultaneously function as publishers (monetising their engaged audiences) and advertisers (reaching dormant customers cost-effectively). This cooperative structure creates mutual advantage whilst delivering precision targeting impossible through conventional adtech platforms.

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Together, these breakthroughs enable the systematic profit engineering that makes Rule of 40 performance inevitable rather than aspirational.

Thinks 1670

NYTimes: “As venture firms double down on their deal making, there is less appetite for investing in general A.I. systems designed to do everything, because that work is dominated by established companies like OpenAI and Google. Instead, they are starting to focus on A.I. that does specific tasks, like Ribbon, a company that does A.I. for job interviews, and Eleos Health, which creates A.I. to record and summarize doctor visits. Tech companies acknowledge that they may be overestimating A.I.’s potential. But even if the technology falls short, many executives and investors believe, the investments they’re making now will be worth it. “Christopher Columbus thought he was headed to the Orient, and he ended up in the Caribbean,” said Mr. Nicholson of Page One Ventures. “He did not get to where he thought he was going, but he still got to a place that was highly valuable.””

ICONIQ: “Top-quartile ARR growth among $25M-$100M ARR companies increased to 93% YTD in 2025, up from 78% in 2023. AI-Native companies achieve significantly higher funnel conversion rates, especially from free trial/proof-of-concept phases ($100M+ ARR companies: 56% vs. 32% for others). Overall AE quota attainment remains flat (58% YTD in 2025 vs. 59% in 2024).”

Economist: “Jamin Ball of Altimeter Capital, a VC firm, notes that companies experiment with many AI applications, which suggests they are enthusiastic but not committed to any one product. He quips that this “easy-come, easy-go” approach from customers produces ERR, or “experimental run rate”, rather than ARR. Others note that churn is often upwards of 20%. It doesn’t help that, in some cases, AI startups are charging based on usage rather than users, which is less predictable. Add to this the fact that competition is ferocious, and getting more so. However fast an AI startup is growing, it has no guarantee of longevity. Many create applications on top of models built by big AI labs such as OpenAI or Anthropic. Yet these labs are increasingly offering applications of their own. Generative AI has also made it easier than ever to start a firm with just a few employees, meaning there are many more new entrants, says Max Alderman of FE International, an advisory firm.”

Mint: “If India’s middle class stays on the margins of its growth story, the economic consequences could be significant. Domestic demand may stay fragile, increasing reliance on public investment and exports. Inequality risks would deepen if growth benefits just the wealthy, while consumer-facing sectors would grapple with weak demand and stunted expansion potential. A persistently cautious middle class may have social and political ramifications. Rising aspirations without economic security often leads to public frustration and mistrust in institutions. This could make it harder to turn growth into broad-based prosperity.”

NeoMarketing: Profit Engineering for Rule of 40 and CMO Comeback (Part 4)

The Path

The images demonstrate NeoMarketing’s systematic approach to achieving Rule of 40 performance through three strategic imperatives that transform marketing economics. Rather than choosing between growth and profitability, this framework delivers both by engineering profits from existing customer relationships whilst eliminating wasteful spending.

Maximise the Best: From 60% to 65% Revenue Share

Best customers represent the most underutilised asset in most businesses. Despite generating 60% of revenue from just 20% of the customer base, traditional marketing treats them like any other segment. NeoMarketing’s approach recognises that these customers can generate significantly more value through systematic cultivation.

The AI Agents Collective makes this possible by solving marketing’s most persistent limitation: the inability to personalise at true individual scale. Where traditional segmentation creates 8-10 broad groups, AI agents enable “segments of few”—micro-cohorts that can scale down to individual customers whilst maintaining operational efficiency. For Best customers, AI Twins create conversational interfaces that understand preferences, predict needs, and orchestrate experiences that feel genuinely personal rather than algorithmically generated.

This level of personalisation was previously impossible through human effort or existing martech platforms. A single marketing team cannot create individual content for thousands of high-value customers, and traditional automation lacks the contextual understanding necessary for authentic personalisation. AI Agents bridge this gap, enabling Best customers to receive the VIP treatment that their economic contribution warrants.

Double the Rest: From 30% to 45% Revenue Contribution

Rest customers represent the greatest growth opportunity in most businesses—engaged prospects who need systematic intervention to reach their value potential. Yet most in-house teams lack the bandwidth, expertise, or technology stack integration necessary to execute sophisticated Rest-to-Best migration strategies.

Progency solves this execution gap by providing capabilities that internal teams simply cannot replicate. Through the PEAK framework (Platform + Experts + AI Agents + Kaizen), Progency delivers done-for-you marketing with performance-based accountability. This isn’t outsourcing—it’s accessing specialised infrastructure designed specifically for customer lifecycle optimisation.

The systematic approach focuses on relationship building over transaction pressure, using NeoMails to create daily engagement touchpoints that transform sporadic interactions into habitual connections. These interactive email experiences solve the attention recession problem by delivering value-driven content at zero CPM—something traditional ESPs cannot offer due to their transactional, volume-based business models.

Slash the Waste: From 15% to 10% Marketing Spend

The most immediate profit impact comes from eliminating the 70% of marketing budgets wasted on reacquisition. Traditional platforms charge premium prices to reach customers brands already know, creating a structural inefficiency that erodes margins as businesses scale.

NeoN revolutionises reacquisition through the world’s first brand-to-brand cooperative advertising network. Using authenticated identity matching based on PII rather than probabilistic cookies, brands can reach their dormant customers through partner brand audiences at 30-50% lower costs than traditional platforms. This cooperative structure eliminates platform intermediaries whilst delivering precision targeting impossible through conventional adtech.

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These three strategies compound to deliver growth rate and profit margin improvement. Growing revenue from existing customers whilst reducing acquisition costs creates a virtuous cycle where profits fund further customer experience improvements, enabling even stronger retention and higher lifetime values.

Thinks 1669

WSJ: “The Federal Reserve will face the problem of an AI purchasing agent talking to an AI credit agent with the only constraint on them being the underlying code dictating their behavior and the instructions users give them. Further, these two agents may conduct transactions using a form of currency that is lightly regulated and doesn’t move through the traditional banking system. Since these interactions would take place in the shadow banking sector, the Fed won’t see first movements in where the money supply is expanding or contracting, one of the main things central bankers need to observe to do their job correctly and guide the economy. And as AIs make financial decisions, how can anyone be certain that they will respond to Fed policy in the same way as our historical data tells us humans respond to Fed policy?”

BVP: “We believe that the coming decade is poised for an even bigger growth spurt, leading to a trillion-dollar digital opportunity. This era of entrepreneurship is almost five times the value creation that happened in the last decade. And given that more than 60% of India’s economy is consumer-led, we expect a large share of this value to accrue to consumer startups. India is about to witness its digital economy take off like a rocket, with a triple engine of commerce, content, and consumer discernment fueled by AI. There has never been a better time to be a consumer entrepreneur in India; in this report, we dive into this new era’s growth engines, AI’s impact so far, and the key metrics entrepreneurs should prioritize.”

FT: “The first wave of AI co-pilots and assistants did little to change working life. The hope has now shifted to agents — tools capable of automating individual tasks, or even entire work processes. According to McKinsey, agents promise to create serious business value by automating complex and important operations. But the consultants also warn this will require a rethink of entire business processes. Persuading its customers to move beyond the many GenAI pilot projects that litter the corporate world will be a heavy lift for the tech industry. That does not mean that, in the longer run, generative AI has no chance of bringing about the kind of transformation in working life that its boosters claim. But, for now, the chasm between capital spending and revenue has shown little sign of narrowing.”

SaaStr: “Be AI-first, grow >25% at scale, get into the top tier, or become irrelevant.”

NeoMarketing: Profit Engineering for Rule of 40 and CMO Comeback (Part 3)

Foundations

Before deploying NeoMarketing’s advanced technologies, businesses must establish three critical foundational requirements that transform fragmented marketing operations into systematic profit opportunities. These aren’t merely technical prerequisites—they’re strategic imperatives that determine whether the marketing operates as a cost centre or profit engine.

Requirement 1: Unified Intelligence (Single Customer View)

Traditional marketing’s greatest operational weakness lies in fragmented data systems that create multiple versions of the same customer across different platforms. When the eCommerce platform, email system, advertising accounts, and customer service tools operate in isolation, it is not possible to engineer profits systematically.

Unified Intelligence consolidates every customer touchpoint into a single, comprehensive view. This integrated foundation connects transactional data, marketing engagement, behavioural analytics, and service interactions into one authoritative customer profile. Unlike traditional CDPs that simply aggregate data, Unified Intelligence creates actionable insights that power autonomous decision-making across all customer interactions.

This foundation enables AI agents to orchestrate personalised experiences, allows accurate lifetime value calculations, and provides the data integrity necessary for performance-based accountability. Without this unified foundation, NeoMarketing’s profit engineering capabilities cannot function effectively.

Requirement 2: Identify Every Customer (Mobile AND Email)

With unified intelligence established, the next requirement addresses traditional marketing’s addiction to anonymous targeting. When 70% of marketing budgets disappear into reacquisition waste, the root cause is simple: repeatedly paying premium prices to reach customers who are already known but are unidentified.

Collecting both mobile numbers and email addresses from every customer interaction creates unprecedented targeting precision whilst building owned communication channels that bypass platform dependency. Mobile numbers enable WhatsApp and RCS engagement, while email powers NeoMails campaigns, lifecycle automation, and authenticated identity matching across the NeoN network. Together, they transform anonymous traffic into identified relationships that generate compound value.

Requirement 3: Segment by Lifetime Value (Best-Rest-Test-Next Framework)

Traditional demographic segmentation tells companies nothing about profitability. The BRTN framework revolutionises customer classification by organising the database around actual economic value and engagement trajectory.

Best customers (top 20%) generate 60% of revenue and deserve AI Agents Collective treatment. Rest customers (middle 40%) represent the greatest growth opportunity for systematic migration to Best status through Progency and NeoMails. Test customers (bottom 40%) enable cost-effective reactivation via NeoN’s authenticated targeting. Next customers require efficient acquisition strategies.

This value-based segmentation creates dynamic customer categories with specific strategies, clear ownership, and measurable migration outcomes—transforming marketing from demographic guesswork into economic precision.

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Together, these three foundations create the integrated platform necessary for systematic profit engineering.

Thinks 1668

Indian Express: “At the core of [Pulak] Prasad’s philosophy is a simple idea: avoid harm, choose carefully, and let time do the work. His investing lens is shaped by Charles Darwin, not stock market cycles. And this mindset holds lessons for every retail investor, especially those who want to grow wealth steadily, with clarity and patience.”

Economist: “If you could invent something to fulfill an economist’s dream, it would look an awful lot like a prediction market. A world where every uncertain future can be priced, hedged and insured against? Kenneth Arrow and Gérard Debreu would approve. A market mechanism to co-ordinate the decentralised wisdom of crowds, ensuring the accuracy of such prices? Adam Smith and Friedrich Hayek sought just that. In recent years, the fantasy has crept closer to reality. Platforms that allow users to speculate on current affairs and more have seen remarkable surges in volume and visibility…Yet despite having proved their worth as a way to discover information, prediction markets have further to go when it comes to fulfilling their full economic promise. That is true both in their ability to help financial institutions hedge and share risk, and as a meaningful addition to capital markets.”

FT: “Think of a discount rate as the interest you must pay for the fact that most of a company’s cash flows don’t come to you immediately. So it makes sense it would be higher the risker a business is. This is an oversimplification, of course. Just look up an average for the sector and use that. PEs, modified PEs, and a basic discounted cash flow model. Pretty much all most retail investors will ever need.”

Simon Willison: “The term context engineering has recently started to gain traction as a better alternative to prompt engineering.”

NeoMarketing: Profit Engineering for Rule of 40 and CMO Comeback (Part 2)

North Star Metric

The North Star Metric for measuring the NeoMarketing transformation should be the Rule of 40—originally developed for SaaS but equally powerful for any business. The Rule of 40 states that a company’s combined revenue growth rate and profit margin should exceed 40%, creating a balanced framework that prevents the false choice between growth and profitability. I wrote in EAGLES: The Six Essential Metrics to Revolutionise eCommerce Profitability:

The Rule of 40 provides an elegant solution to the growth-versus-profitability dilemma that plagues many eCommerce businesses. By stipulating that a healthy business’s combined revenue growth rate and profit margin should exceed 40%, it creates a flexible framework that accommodates different strategic phases while maintaining fiscal discipline.

This metric acknowledges that companies may legitimately prioritise growth over immediate profitability, but not without limits. A business growing at 50% annually can run at a 10% loss and still meet the Rule of 40 standard, while a mature business growing at 15% should generate at least 25% profit margins.

What makes the Rule of 40 particularly valuable for eCommerce is its ability to counterbalance the industry’s frequent over-emphasis on growth at all costs. By incorporating this metric into regular reporting, businesses create a natural brake against unsustainable practices like excessive discounting, over-reliance on paid acquisition, or margin-eroding free shipping policies.

I asked Claude for an explainer on why the Rule of 40 is such a good metric for every company.

The Rule of 40, originally popularised in SaaS circles, offers a brilliantly elegant solution to one of business’s most persistent dilemmas: the false choice between growth and profitability. This metric—which requires that a company’s combined revenue growth rate and profit margin exceed 40%—provides a flexible framework that can transform how any company approaches systematic, sustainable growth.

Why Every Company Needs the Rule of 40

Prevents Growth-at-All-Costs Madness: The Rule of 40 creates a natural brake against unsustainable practices. A company growing at 50% annually can justify running at a 10% loss and still meet the standard, whilst a mature business growing at 15% should generate at least 25% profit margins. This balance prevents the common trap of celebrating growth that destroys long-term value.

Accommodates Different Strategic Phases: Unlike rigid profitability targets, the Rule of 40 recognises that businesses legitimately prioritise differently at various stages. High-growth startups can operate at lower margins whilst still demonstrating fiscal discipline, whilst mature companies must prove their efficiency through higher profitability when growth naturally slows.

Forces Strategic Discipline: Most businesses operate with separate growth and profitability initiatives that often work at cross-purposes. The Rule of 40 forces integration—every strategic decision must consider both growth and margin impact simultaneously, creating more coherent business strategies.

Real-World Application Beyond SaaS

For eCommerce companies, the Rule of 40 counterbalances the industry’s frequent over-emphasis on growth metrics like conversion rates and customer acquisition. It prevents margin-eroding practices such as excessive discounting, over-reliance on paid acquisition, or unsustainable free shipping policies.

For traditional retailers, it provides a framework for evaluating expansion decisions—new locations, product lines, or market entry strategies must contribute to the combined 40% threshold rather than just top-line growth.

For B2B service companies, it helps balance investment in new capabilities against operational efficiency, ensuring that expansion strengthens rather than dilutes the business model.

The Profit Engineering Connection

The Rule of 40 becomes particularly powerful when combined with systematic approaches to eliminate waste and maximise customer value. Companies achieving Rule of 40 performance typically focus on maximising revenue from existing customers whilst ruthlessly eliminating inefficient spending—precisely the approach that transforms marketing from a cost centre into a profit engine.

By adopting the Rule of 40 as a primary metric, companies create a balanced scorecard that ensures growth investments deliver sustainable returns whilst maintaining the operational discipline necessary for long-term success.

Thinks 1667

Arnold Kling: “No other species on earth combines strength in cooperation with strength in competition. If another species is high in cooperation, then it is low in competition. If it is high in competition, then it is low in cooperation. I believe that this combination of high cooperation and high competition is the key to understanding social psychology, and the human condition more generally. We cooperate in order to compete, and we compete in order to cooperate. We cooperate in order to compete by forming teams, creating roles, and building loyalty. We do this in sports, business, war, politics, and other realms.”

Cindy Anderson: Based on the survey responses, there are five ways that executives find value in thought leadership consumption: (1) It drives revenue growth and profitability: 46 percent of global C-suite executives said that thought leadership helped drive greater revenue growth in their organization (2) It gives executives a competitive advantage. Almost all (96 percent) of respondents said that having that kind of data and analysis helps them make better business decisions. (3) It improves innovation and business agility (4) Their employees are more satisfied (5) They have fewer knowledge gaps. Thought leadership helps them compensate for inadequate data and analysis within their own organizations.”

WaPo: “Over the past five years, Saylor has transformed his Tysons Corner datamining company, MicroStrategy, into what he calls a “bitcoin treasury.” The company issued stock and bonds to raise money, and with that, it bought billions of dollars worth of the cryptocurrency. When bitcoin prices rose with the presidential election last year of Donald Trump, a crypto fan, company shares tripled in value. The company’s profits, however, didn’t end there. In a feat of what seems like financial levitation, the company’s stock rose even faster than the price of bitcoin, and today the “bitcoin treasury” company is valued by investors at almost twice the value of its main asset, the bitcoin.”

SaaStr: “Unlike previous technology waves where knowledge could be protected through patents or trade secrets, AI advancement seems to follow a different pattern. The core insights about training large language models have become valuable precisely because they can’t be easily replicated or reverse-engineered…The war for AI talent isn’t just about building better products—it’s about access to a finite pool of people who understand how to make AI actually work in enterprise contexts.”

NeoMarketing: Profit Engineering for Rule of 40 and CMO Comeback (Part 1)

Overview

In my previous essay, I explored how NeoMarketing provides the systematic approach to achieving sustainable, profitable growth. Here is a summary of the key ideas.

NeoMarketing: Engineering Marketing’s Third Great Era

Marketing has reached its own “mission impossible” moment. Like breaking the sound barrier or landing on the Moon, achieving simultaneous growth and profitability has long seemed insurmountable. Traditional marketing forces an impossible choice: CMOs deliver growth, CFOs demand profits, and CEOs want both. Yet rising marketing spend continues to outpace revenue growth by 30-50%, whilst 70% of budgets disappear into reacquisition AdWaste—repeatedly paying premium prices to reach customers already in the database.

This structural failure isn’t merely a budgeting problem. It’s the inevitable result of marketing’s evolution through two distinct eras. Brand Marketing (1950s-1990s) built awareness through mass media but struggled with measurement. Performance Marketing (2000s-2020s) solved measurement through digital targeting but created platform dependency and the £500 billion AdWaste crisis.

NeoMarketing represents marketing’s third great era—a systematic approach to engineering profits, not just growth. Rather than optimising existing approaches, it inverts the fundamental assumptions that have governed marketing for two decades.

The Five Great Shifts

NeoMarketing transforms marketing through five critical transitions:

  • From Rented Reach to Owned Attention: End the 20-30% platform “revenue tax” by building direct customer relationships through websites, emails, apps, and WhatsApp rather than renting access through Google, Meta, and Amazon.
  • From Revenue Engineering to Profit Engineering: Replace growth-at-any-cost mentality with systematic margin improvement focused on lifetime value, repeat purchase rates, and Rule of 40 performance.
  • From Reacquisition Addiction to Retention Mastery: Shift from first-sale obsession to repeat-sale focus, halving AdWaste through loyalty programmes that systematically grow customer value over time.
  • From Anonymous Segments to Identified Individuals: Move beyond third-party cookies and demographic approximations to first-party data and N=1 personalisation that recognises each customer’s unique value potential.
  • From Fragmented Tools to AI-First Integration: Replace manual operations across disconnected martech stacks with AI agents powering autonomous systems that learn, adapt, and optimise continuously.

The 4 A’s: Breakthrough Technologies

Four innovations make NeoMarketing’s profit engineering possible today:

  • Agents: AI-powered multi-agent systems enable true 1:1 relationships at scale through the AI Agents Collective, making every customer feel unique without human overhead.
  • Agency: Progency reinvents the agency model with outcome-based pricing—earning only when measurable growth is delivered, aligning incentives for true profit partnership.
  • Attention: NeoMails solve the “No Hotline” problem by creating habit-forming engagement channels that transform the inbox into daily owned media.
  • Acquisition: NeoN creates the world’s first brand-to-brand cooperative ad network using authenticated identity targeting, allowing brands to simultaneously monetise their audiences and reach dormant customers at 30-50% lower costs.

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NeoMarketing is the only path for systematic, sustainable, profitable growth, transforming marketing from cost centre to profit engine, delivering systematic profit margin improvements and Rule of 40 performance.

Thinks 1666

SaaStr: “In June 2025, Replit CEO Amjad Masad dropped a bombshell on X: his company had crossed $100M ARR, up from just $10M at the end of 2024. That’s 10x growth in less than 6 months—making Replit one of the fastest B2B scale stories in recent history. But here’s what makes this story truly remarkable: Replit didn’t just grow fast. It and other leaders in the space fundamentally changed what it means to build software, pioneering the “vibe coding” movement where anyone can create production apps using natural language. No (or relatively little) coding expertise required.  And allowing more experienced developer to ship far faster. This isn’t just another software success story. It’s the emergence of a new category that’s attracting billions in investment and fundamentally disrupting the $500B+ software development market.”

Amjad Masad: “In Silicon Valley, you hear a lot of talk about the 10x engineer Think of some of these A.I. researchers as 1,000x engineers. If you can add one person who can change the trajectory of your entire company, it’s worth it.”

Bloomberg: “For as long as most of us can remember, business has been able to call on a ready supply of foreign workers. The giants of Silicon Valley, farmers and food processors, hotels and restaurants, housebuilders and megastores: All have dealt with labor shortages by recruiting immigrants. One result has been an astonishing demographic transformation: 16% of the British population, 20% of the Swedish population, 19% of the German population and 14.3% of the US population were born abroad. This golden age for employers is coming to an end. Popular discontent with mass immigration is rising, anti-immigrant parties are flourishing and mainstream parties are finally taking note.”

Arnold Kling: “Sports gambling is an example of a predatory business model. The entire business is designed to find psychologically weak people and exploit them. Maybe 95 percent of sports gamblers do it for fun and don’t hurt themselves, but the point of the business is to capture the other 5 percent. Or so I believe. To really know whether sports gambling is predatory, I propose that either a government agency or a consumer organization conduct a business model audit for each firm in the industry. This would look at all of the business processes involved—product design, marketing, customer relations, etc. The goal would be to identify practices that either intentionally or unintentionally select for and take advantage of the customers who are least able to fend off exploitation.”