When preparing to run advertising that includes endorsements, our clients frequently ask whether any “magic words” are necessary and how disclosures should be made on space-constrained forums such as Twitter. On May 29, 2015, the Federal Trade Commission (“FTC”) staff announced it had addressed some of these questions by updating the FAQs to its Guides Concerning Use of Endorsements and Testimonials in Advertising (“Endorsement Guide”), providing some much needed clarity on a variety of endorsement-related issues, including special wording, Twitter disclosures, social media “like” buttons, affiliate marketing, employee endorsements, uploading videos, and more.
FAQ Series 1: FTC Issues New Guidance on Endorsements and Related Online Disclosures
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