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Cameo Settles with 30 AGs Over Endorsement Issues

Cameo is a platform where people can pay celebrities to record videos with scripted personal messages. Jimmy Kimmel recently used the platform to see if he could get George Santos to say silly things and then Kimmel aired...more

Court Sides with Tea Drinkers in Made in USA Dispute

In 2020, plaintiffs filed a class action complaint in California federal court against Bigelow Tea, alleging that the company falsely represents that its teas are made in the United States, when the teas are actually grown...more

FTC Sends Warning Letters Over Warranty Practices

The FTC is focused on ensuring that consumers have options when it comes to repairing products. Two years ago, we summarized an FTC workshop, report, Policy Statement, and three settlements on this issue. Last week, the FTC...more

FTC Updates Made in the USA Guidance

Last week, the FTC released an updated version of its Complying with the Made in USA Standard business guide. The heart of the guidance remains the same: if you expressly or implicitly state that a product is Made in the USA...more

FTC Challenges Adobe’s Subscription Practices

Adobe needs no introduction. It makes the software that enables many of our readers to view this complaint and it makes the software that enables many of our non-readers to touch up photos to make themselves appear more...more

10th Circuit Decision at Odds with FTC over ​“American Made” Claims

I Dig Texas and Creager Services both sell construction equipment called skid steer attachments. I Dig Texas urged customers to buy its products instead of Creager Services’ products by appealing to their sense of patriotism....more

Company Complies with NARB Decision on Review Disclosures After FTC Intervenes

Smile Prep operates a website that provides reviews of clear aligners (or ​“invisible braces”) based on an ​“extensive five-point analysis.” Because Smile Prep’s sole source of revenue consists of commissions from some of the...more

FTC Announces $2 Million Penalty over Made in USA Claims

I’ve never owned a tractor, but based on Kenny Chesney’s 1999 hit She Thinks My Tractor’s Sexy, I understand that some people find them to be quite alluring. (The same goes for farmer’s tans, but that’s more relevant to this...more

FTC Sends Warning Letters to Companies and Influencers Over Disclosures in Posts

Earlier this year, we examined how changes to the FTC’s Endorsement Guides might affect influencer campaigns and suggested that companies may want to monitor FTC actions in this area to see what types of conduct grab the...more

FTC Recommends Sharpening Blurred Lines When Advertising to Kids

In October, we posted about the FTC’s day-long workshop on “Protecting Kids from Stealth Advertising in Digital Media” and wondered what the FTC might be planning. Last week, we got an answer when the FTC released a “Staff...more

FTC and Six States Announce Settlement Over Fake Reviews and Claims

A year ago, the FTC and six states filed a lawsuit against Roomster and its owners, alleging that they had posted “tens of thousands of fake positive reviews to bolster their false claims that properties listed on their...more

FTC Assesses Primary Purpose of Emails in CAN SPAM Enforcement

As most people know – either from professional or personal experience – the CAN SPAM Act requires companies who send “commercial” email messages to give consumers an opportunity to opt-out of receiving those messages in the...more

New Endorsement Guides Include Big Changes, But Few Surprises

In May 2022, the FTC proposed changes to its Endorsement Guides. Among other things, those changes created more prescriptive disclosure requirements for endorsements, imposed various requirements for consumer reviews, and...more

Latest Made in USA Settlement Offers Lessons for Fashion Companies

This week, just a few days before the Fourth of July holiday, the FTC announced a settlement with three fashion companies (that operated together as a common enterprise) over patriotic claims that the companies made about...more

FTC Targets Publishing Clearing House “Dark Patterns” in Sweeping Order

Yesterday, the FTC announced an $18.5 million settlement with Publishers Clearing House (PCH), a marketing company known for using sweepstakes to sell magazine subscriptions. In its 52-page complaint, the FTC alleges PCH used...more

States Follow FTC Auto Renewal Settlement with a New $2.3 Million Settlement

In 2017, the FTC announced that Adore Me, an online lingerie company, had agreed to return more than $1.3 million to customers who enrolled in a negative-option membership program offering discounts and other benefits. Almost...more

NAD Addresses Hyperlinked Disclosures

When a disclosure is necessary to prevent an ad from being misleading, the disclosure must be presented in a “clear and conspicuous” manner. Exactly what that means depends a lot on the context, but one question we get...more

Talking Trash at the FTC: Event Recap

This week, the FTC held its Talking Trash at the FTC workshop, a four-hour event intended to examine “recyclable” claims in ads. We’ve sifted through some of the trash and pulled out a few things worth noting....more

Google to Pay $8 M to Settle with Texas Over DJ Endorsements

In January 2022, the Texas Attorney General filed a lawsuit against Google alleging that the company engaged iHeartMedia DJs to provide endorsements for its Pixel 4 phone, even though they had never used it. In November 2022,...more

NAD Finds Dark Patterns in a Rewards Program

For $9.99 per month, Pier 1 offers Pier 1 Rewards, a loyalty program that includes benefits such as a 10% discount on all purchases and free shipping and returns on eligible items. Until recently, when a consumer added an...more

FTC Reminds Advertisers to Keep AI Claims in Check

A recent post on the FTC’s Business Blog notes that although there may be disagreement about what “artificial intelligence” or “AI” is, those terms are being used in marketing campaigns, and the FTC worries that some...more

FTC and State AGs Can Continue Joint Case Over Fake Reviews

Fake reviews continue to be a hot topic in consumer protection. In 2022, we reported that six states and the Federal Trade Commission filed a lawsuit against Roomster – a platform through which people can find rooms and...more

FTC Challenges Half-Baked “Made in USA” Claims

Instant Brands advertises that its Pyrex glass products are “Proudly Made in USA” and as “American as Apple Pie.” For many years, it appears that Instant Brands’ claims complied with the requirements set forth in FTC’s Made...more

FTC Starts Process of Updating Green Guides

Green marketing is very much in vogue, and so is suing companies over their green marketing. If you want to avoid those suits, you should generally start by looking at the FTC’s Green Guides. But a lot has changed since the...more

FTC and States Settle with Google and iHeartMedia Over Misleading Endorsements

In January, we reported that the Texas Attorney General had filed a lawsuit against Google alleging that the company engaged iHeartMedia DJs to provide endorsements for its Pixel 4 phone, even though they had never used it....more

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