Point of Sale Newsletter - April 2019

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Media Transparency: An Update on the Status of the FBI/DOJ Investigation, Recovery Efforts and Best Practices Going Forward -

The number of issues and areas of inquiry resulting from the revelations set forth in the ANA/K2 Report continue to mount. As originally detailed in the Fall of last year, the FBI is actively investigating certain media buying agencies for alleged non-transparent practices and looking to the advertisers potentially defrauded to assist with its investigation. Just last week, AdAge published an article noting that the FBI has an “unredacted version” of the K2 report including names of all 41 previously unidentified sources. Moreover, certain agencies are affirmatively trying to cover their tracks and/or to revise their existing contracts to either permit the questionable conduct going forward or to limit the audit rights of their advertiser clients.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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