If you use online endorsements or testimonials from others, you should review your internal marketing policies and your FTC website forms to avoid substantial liability for deceptive advertising.<\/span><\/p>\n The Reverb Communications Case<\/b><\/p>\n Reverb Communications is a public relations firm representing major clients in the video game industry, including clients such as MTV Games and Harmonix, as well as smaller firms that sell mobile game apps via the iTunes store. According to the FTC, Reverb\u2019s fee often includes a percentage of the sale of its clients\u2019 gaming apps.<\/span><\/p>\n The iTunes store provides users the ability to post reviews of gaming applications that are available for purchase. These reviews include a rating system (based on a possible rating of one to<\/span> five <\/span>stars) and written text.<\/span><\/p>\n According to the FTC, during a period of approximately one year Reverb employees posted reviews in the iTunes store favorable to games of Reverb\u2019s clients. The reviews were posted in a manner that would convey the impression tha<\/span>t unaffiliated or non associated consumer<\/span>s had posted them.<\/span><\/p>\n In addition to giving five-star ratings to Reverb\u2019s clients\u2019 games, Reverb\u2019s employees posted written endorsements such as:<\/span><\/p>\n The FTC brought suit claiming that Reverb engaged in deceptive advertising by having its employees pose as ordinary consumers posting reviews, while \u00a0failing to disclose that the reviews were from paid employees working on behalf of their clients. Reverb agreed to settle the case.<\/span><\/p>\n Lessons Learned<\/b><\/p>\n The basic lesson is clear \u2013 don\u2019t use employees or contractors to post fake endorsements under <\/span>any circumstances<\/i><\/b>.<\/span><\/p>\n The FTC stated in its press release announcing the Reverb settlement: \u201cCompanies, including public relations firms involved in online marketing need to abide by long-held principles of truth in advertising. \u00a0Advertisers should not pass themselves off as ordinary consumers touting a product\u2026\u201d.<\/span><\/p>\n What to Do?<\/b><\/p>\n What if you post actual endorsements (not fake ones) from satisfied customers on your website \u2013 or if you allow bloggers to post endorsements on your site? <\/span><\/p>\n What is required to avoid a deceptive advertising claim by the FTC? \u00a0<\/span><\/p>\n If some of your endorsers receive a fee or some kind of benefit in connection with their endorsements, you need to place a link in close proximity to the endorsement that links to disclosure text such as:<\/span><\/p>\n Conclusion<\/b><\/p>\n The FTC settlement with Reverb requires Reverb to remove the previously posted deceptive endorsements and to refrain from using employees to post fake reviews for its clients in the future. <\/span><\/p>\n The Reverb case indicates that the FTC is very serious about enforcement of its Guides that were announced late last year and you can e<\/span>xpect more FTC enforcement actions in the near future.<\/span><\/p>\n <\/p>\n By now it should be clear how important it is for you to be FTC compliant. But how can you do that without spending $7,500-$8,000 or more on Internet Attorneys?<\/p>\n Smart business owners around the world are doing it with the help of FTC Guardian.<\/p>\n FTC Guardian is a service that is 100% focused on helping to keep you get and stay FTC compliant and fully protected.\u00a0And right now, we are offering a free training to give you the knowledge, information, and guidance that you need to stay out of trouble with the Federal Trade Commission.<\/a><\/p>\n![\"\"](\"\/images\/button_banner-SDLM.png\")
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Here\u2019s How To Make Sure You,\u00a0Your Business & Website Is FTC Compliant<\/h2>\n