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The FTC’s focus on prosecuting affiliate networks; lessons from the FTC’s recent case against affiliates, FTC v. Cantkier, et al.; and what this means for you.Experience level: IntermediateTarget audience: Affiliates/PublishersNiche/vertical: FTCJeff Ifrah, Partner, Ifrah Law (Twitter @crimeinthesuite)
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© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
FTC Prosecution of Affiliates for Advertising Claims
January 11, 2011, Affiliate Summit West 2011
WHO WE ARE
JEFF IFRAH: Partner
IFRAH LAW: A Focus on Government InvestigationsAnd E-Commerce
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
TODAY’S PRESENTATION OVERVIEW
• Insider’s Understanding of the FTC
• Real-life Examples & What They Mean to You
• Staying Out of the Government’s Cross-hairs
• Critical Advice “in the event…”
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
FEDERAL TRADE COMMISSION
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
• WHO?
• WHAT?
• WHY?
• HOW?
FTC PRIORITIZES AFFILIATE MARKETERS
“Anyone in the chain between a seller and the ultimate
consumer.”- David Vladeck, Director FTC Bureau of Consumer
Protection
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
SO, WHAT DOES IT ALL MEAN…
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
•What is UNFAIR?
•What is DECEPTIVE?
GUIDANCE FROM THE FTC
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
AND THAT MEANS…
Advertisers, Brokers & Affiliates
Advertisers, Brokers & Affiliates,
Advertisers, Brokers & Affiliates,
REVISED ENDORSEMENT GUIDES
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
Disclaimers
SOCIAL MEDIA & PAID BLOGGERS
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
They paid me…
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
FTC V. REVERB COMMUNICATIONS
“GREAT, family-friendly board game app”“One of the best apps just got better”
TEMPORARY RESTRAINING ORDER AGAINST AFFILIATES
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
HOW TO STAY OFF THE FTC’S RADAR
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
CRITICAL ADVICE “IN THE EVENT…”
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
FOOD FOR THOUGHT
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
FTC PROSECUTION OF GIRLS GONE WILD
“ Monthly Preview Program. 30-day money back guarantee if not completely satisfied. Additional title $19.99 + $4.99 shipping and handling. Cancel Anytime.”
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
JEFF IFRAH, IFRAH LAWjeff@ifrahlaw.com / P (202)
912-4823Blog FTCBeat.com
© 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
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