In an opinion adopted on December 8, the EU Article 29 Working Party again rebuffed the Online Behavioral Advertising industry’s self-regulatory proposal, continuing to hold firm that European law requires affirmative, opt-in consent prior to the placement of any cookie for tracking purposes. The Working Party broke down the OBA industry proposal, and then–in a rebuttal of the industry’s contention that the opinion will result in the proliferation of dreaded browser pop-up windows–offered up a number of methods of obtaining consent not involving pop-ups.