On social media and other digital advertising platforms, proper disclosure of material interests between an endorser and the product manufacturer is critical to inform consumers and avoid alleged deceptive advertising practices. The comment deadline for Federal Trade Commission’s (FTC) recent request for public comment to inform planned revisions to its Guides Concerning the Use of Endorsements and Testimonials in Advertising (the Guides) has been extended to June 22, 2020. Comments provide stakeholders an important opportunity to inform and shape the Guides and FTC enforcement policy which are revisited from time to time. With the social distancing measures now in place, established and emerging social medial platforms are more important than ever before. Not surprisingly, we expect to see ever-growing monitoring and possible enforcement by the FTC, as illustrated by a recent action against detox tea manufacturer Teami suggests.
