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FTC Prosecution of Affiliates for Advertising Claims
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FTC Prosecution of Affiliates for Advertising Claims

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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. …

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: Intermediate
Target audience: Affiliates/Publishers
Niche/vertical: FTC

Jeff Ifrah, Partner, Ifrah Law (Twitter @crimeinthesuite)

Published in Business , Self Improvement
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Transcript

  • 1. FTC Prosecution of Affiliates for Advertising Claims January 11, 2011, Affiliate Summit West 2011
  • 2. Don’t forget: You can copy-paste this slide into other presentations, and move or resize the poll.
  • 3. WHO WE ARE
    • JEFF IFRAH: Partner
    • IFRAH LAW: A Focus on Government Investigations
    • And E-Commerce
    © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 4. 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
  • 5. FEDERAL TRADE COMMISSION © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
    • WHO?
    • WHAT?
    • WHY?
    • HOW?
  • 6. 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
  • 7. SO, WHAT DOES IT ALL MEAN…
    • What is UNFAIR?
    • What is DECEPTIVE?
    © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 8. GUIDANCE FROM THE FTC © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 9. © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com AND THAT MEANS… Advertisers, Brokers & Affiliates Advertisers , Brokers & Affiliates ,
  • 10. REVISED ENDORSEMENT GUIDES © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com Disclaimers
  • 11. SOCIAL MEDIA & PAID BLOGGERS © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com They paid me…
  • 12. © 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”
  • 13. TEMPORARY RESTRAINING ORDER AGAINST AFFILIATES © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 14. HOW TO STAY OFF THE FTC’S RADAR © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 15. CRITICAL ADVICE “ IN THE EVENT…” © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 16. FOOD FOR THOUGHT © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 17. 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
  • 18. JEFF IFRAH, IFRAH LAW jeff@ifrahlaw.com / P (202) 912-4823 Blog FTCBeat.com © 2010 Ifrah PLLC. Proprietary and Confidential. / (202) 912-4823 / ifrahlaw.com
  • 19. Don’t forget: You can copy-paste this slide into other presentations, and move or resize the poll.