 As a Commissioner, Leibowitz was also involved in various Internet issues, from fighting spam and spyware to creating effective guidelines for online behavioral targeting (the practice of collecting Internet users' unique browsing history to target advertising), to ensuring that website privacy policies are clear and accessible to consumers.Leibowitz urged the Commission to "name names" of advertisers who paid to advertise through so-called nuisance adware, software that displays or downloads advertisements on consumers' computers without their consent.Leibowitz has also advocated for balanced "Net Neutrality" rules and for the right of municipalities to offer broadband to consumers free from restrictive state laws.