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California Carbon Disclosure Requirements Delayed

In October, we posted that California had enacted the Voluntary Carbon Market Disclosure Act (or​ ​“VCMDA”), a law that aims to force companies to more clearly disclose the basis for their carbon reduction claims. The VCMDA...more

NAD Considers Whether ​“Better” and ​“Best” Claims are Puffery

Royal Oak sells Super Size charcoal briquets that are 50% bigger than the briquets sold by certain competitors. Royal Oak advertises that ​“a bigger briquet is a better briquet” and that the briquets provide ​“the best...more

Massachusetts Hops on the Junk Fee Bandwagon – and Online Cancellation, Too

This week, Massachusetts Attorney General Andrea Joy Campbell’s office touted the release of draft regulations to prohibit hidden ​“junk fees,” enhance transparency in various transactions, and make it easy for consumers to...more

NARB Reads Less Into Emojis Than NAD

Earlier this year, Coca-Cola reformulated its Powerade beverage to include more electrolytes. In some ads, it boasted that the beverage now contained ​“50% more electrolytes vs. Gatorade Thirst Quencher.” One social media...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

NAD Decision Provides Guidance on Disclosures for Endorsements

NAD recently issued a decision in a challenge that Bath & Body Works (or ​“B&BW”) brought against Goose Creek that touches upon a number of common issues advertisers face. The decision covers a lot of ground, and yesterday we...more

NAD Decision Provides Guidance on Claims Against Unnamed Competitors

NAD recently issued a decision in a challenge that Bath & Body Works (or ​“B&BW”) brought against Goose Creek that touches upon a number of common issues advertisers face. Although the decision covers a lot of ground – B&BW...more

New Gmail Marketing Requirements Will Impact Most Advertisers

This month, Google announced that it would soon implement new requirements for ​“bulk senders” – defined as senders who send more than 5,000 messages to Gmail addresses in one day – that will likely impact most companies that...more

SharkNinja Faces Heat Over Temperature and Non-Stick Claims

In 1985, Bon Jovi released their second studio album, 7800° Fahrenheit. As a good New Jersey resident with good taste in music, I bought the album. I remember learning that the title supposedly referred to the melting point...more

10/20/2023  /  Advertising , Manufacturers , Marketing , NAD

New California Law Regulates Carbon Claims

Green is the new black, or so it seems, based on the growing number of companies that are making ​“green” claims. Claims about carbon reductions are particularly in fashion, both with advertisers and with a growing number of...more

California Bans Hidden Fees

As we posted yesterday, the FTC announced a proposed rule that could fundamentally alter how businesses across industries advertise prices and disclose fees to consumers. At around the same time the FTC was preparing to...more

NARB Gives FTC an Opportunity to Apply New Endorsement Guides

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

Retailer to Pay $10 Million to Settle Pricing Claims

Lawsuits challenging how companies advertise sales are on the rise. In this year alone, we’ve posted about a lawsuit over a grocer’s BOGO offers, a lawsuit over a major retailer’s frequent sales, and a large settlement over...more

10/20/2023  /  Advertising , Marketing , Retailers , Settlement

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

NAD Addresses Apples and Oranges in Price Claims

Google recently ran two commercials for its YouTube TV service, each of which ended with the following tagline: “More than cable. For $600 less than cable.” A disclosure at the bottom of the screen explained: “Annual average...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

NAD Reads into Emojis 

Earlier this year, Coca-Cola reformulated its Powerade beverage to include more electrolytes. In some ads, it boasted that the beverage now contained “50% more electrolytes vs. Gatorade Thirst Quencher.” One social media post...more

8/11/2023  /  Advertising , Emoji , NAD , Social Media

NARB Decision Holds Lessons for Claim Substantiation

NARB recently announced a decision in a case involving various claims that Shark Ninja made in an infomercial for its Shark Stratos Powered Lift-Away vacuum cleaner, including claims about how well the vacuum picks up hair...more

8/10/2023  /  Advertising , Marketing , NARB

NAD Reads Into WSJ’s “Cancel Anytime” Claims

Most NAD cases are brought by competitors, but NAD can also initiate a proceeding pursuant to its “responsibility for monitoring and reviewing national advertising for truthfulness and accuracy.” Looking at the cases NAD...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

NARB Agrees Advertiser Can’t Support Aspirational Net Zero Claims

JBS – the second-largest food company in the world – made several aspirational claims about its commitment “to be net zero by 2040.” Those claims were challenged by a trade association, who argued that the claims were...more

6/22/2023  /  Advertising , Marketing , NARB

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

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