Common FTC Disclosure / Testimonial Mistake
I have seen this done a couple times recently by marketers trying to sidestep FTC rules regarding testimonials and typical results.
The marketer will say:
If 1000 people buy a $1997 guru product. 600 do nothing and never install it. 400 try the product and each make on average $300.
The typical user experience is $300 in earnings. Not zero.
The "most do nothing" claim also presumes that the marketer knows that most buyers do nothing with their product. How do they know that?
The marketer is simply looking for an easy out - fabricating that most do nothing as an excuse to avoid FTC disclosure requirements.
The end result is a potential fraud action by the FTC:
- False claims about the average user not doing anything.
- False claim that anyone who uses the product will make millions.
- Improper and inflated earnings claims without an accurate disclosure of common results.
.
The marketer will say:
Most buyers sit on their butt and do nothing with the program, so the typical results are no earnings. But for those who do take action ... then the pitch continues about easy millions.The FTC disclosure rules about earnings results, testimonials, whether they are typical, and an average user experience pertain to users. Not buyers.
If 1000 people buy a $1997 guru product. 600 do nothing and never install it. 400 try the product and each make on average $300.
The typical user experience is $300 in earnings. Not zero.
The "most do nothing" claim also presumes that the marketer knows that most buyers do nothing with their product. How do they know that?
The marketer is simply looking for an easy out - fabricating that most do nothing as an excuse to avoid FTC disclosure requirements.
The end result is a potential fraud action by the FTC:
- False claims about the average user not doing anything.
- False claim that anyone who uses the product will make millions.
- Improper and inflated earnings claims without an accurate disclosure of common results.
.
David
Call Center Fuel - High Volume Data
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