Scams Prey on Victims of the Recession With Bogus Job, Money-Making Schemes
The Federal Trade Commission today announced a new crackdown on con artists who are preying on unemployed Americans with job-placement and work-at-home scams, promoting empty promises that they can help people get jobs in the federal government, as movie extras, or as mystery shoppers; or make money working from their homes stuffing envelopes or assembling ornaments.

FTC Warning About Job Scams:

With the U.S. unemployment rate just under 10 percent, the FTC is redoubling its efforts to put a stop to these schemes, which make life even more difficult for hundreds of thousands of Americans already wrestling with the economic downturn.

Video 1 of the FTC Press Conference – Operation Bottom Dollar

As part of the law enforcement sweep announced today, dubbed “Operation Bottom Dollar,” the FTC has filed seven cases against the operators of deceptive and illegal job and money-making scams and announced developments in four previously filed job scam cases. In addition, the sweep includes 43 criminal actions by the Department of Justice, many involving the substantial assistance of the U.S. Postal Inspection Service, as well as one additional civil action by the Postal Inspection Service and 18 actions by state attorneys general.

Video 2 of the FTC Press Conference – Operation Bottom Dollar

During a joint press conference today at the FTC, David C. Vladeck, Director of the FTC’s Bureau of Consumer Protection, was joined by Tony West, Assistant Attorney General for the Civil Division of the Department of Justice; Ohio Attorney General Richard Cordray; and a Grandview, Texas, job seeker who lost money to a company that made false promises of full-time work with benefits. The FTC also announced partnerships with the online job placement service Monster.com, the search engine Bing, by Microsoft, and the centralized network of online communities Craigslist, to help job seekers recognize job scams so they can avoid being victimized. Monster, Careerbuilder, Bing and Craigslist will display FTC consumer education material to people who are using the companies’ Web sites to look for jobs.

Video 3 of the FTC Press Conference – Operation Bottom Dollar

“Federal and state law enforcement officials will not tolerate those who take advantage of
consumers in times of economic misfortune,” Vladeck said. “If you falsely advertise that you will connect people with jobs or with opportunities for them to make money working from home, we will shut you down. We will give your assets to the people you scammed, and, when
it’s appropriate, we’ll refer you to criminal authorities for prosecution.”

“Employment and business opportunity fraud causes terrible hardship to those who are suffering the most in these difficult economic times,” said Assistant U.S. Attorney General Tony West. “The Justice Department is committed to prosecuting those who defraud through false promises of employment or financial success.”

To help consumers avoid being conned by employment scams, the FTC has produced a new consumer education video in English and Spanish. Still shots from the Web sites of some of the operators charged in this law enforcement sweep, as well as video footage of FTC Consumer Protection Director Vladeck, and Monica Vaca, an Assistant Director in the FTC’s Division of Marketing Practices, will also be available. To view them, go ftc.gov/jobscams and youtube.com/ftcvideos. For access to higher resolution versions, visit aperturefilms.com/ftc or contact the FTC’s Office of Public Affairs.

Operation Bottom Dollar: FTC Law Enforcement Actions

The FTC announced seven new cases against promoters of the job and money-making scams, including one that victimized more than 100,000 people. This brings to 11 the number of cases the agency has brought since last spring challenging these types of operations. In each case, the FTC got a court order temporarily barring these operators from continuing their deceptive, illegal tactics and freezing their assets. The FTC also is asking the courts for permanent orders that would allow the agency to try to get money back to reimburse victims. In two of the matters announced today, criminal authorities executed search warrants, and arrested the two operators of one of the businesses.

In the law enforcement actions announced today, the FTC charged that:

Government Careers Inc. and three principals preyed on job seekers since at least March 2009 by running deceptive ads on job Web sites. Government Careers claimed it could help people get postal, border patrol, and wildlife jobs as well as administrative support and clerical positions with the federal government. It told people they could get these jobs if they paid $119 for study materials, which would allow them to pass any required test with a score of 95 percent or better. But according to the FTC complaint, those who paid the fee found that there are no exams for the positions they sought, or that the supposed job vacancies did not exist. The company also hawked career counseling services, charging $965 for services like resume editing and employment exam preparation. Although the defendants said that consumers would not have to pay the fee until they got a government job, the defendants demanded payment before consumers obtained the promised jobs. The Arizona Attorney General’s Office is the FTC’s co-plaintiff in this case, which was filed in the U.S. District Court for the District of Arizona. After the court issued a temporary restraining order, the defendants agreed to an interim order that prohibits any alleged misconduct pending resolution of the case.

Real Wealth, Inc. and its principal allegedly conned more than 100,000 people by selling them booklets that supposedly explained how they could earn money by applying for government grants and working from home mailing postcards and envelopes. Using direct mail campaigns that sometimes targeted the elderly and disabled, Real Wealth lured consumers, according to the FTC complaint, with deceptive solicitations such as “Collect up to $9,250 with my simple 3 minute form” or “All I do is mail 30 postcards everyday and I make an extra $350 a week!” Real Wealth also claimed that consumers could “rake in up to $1,500+ per week or more in solid cash” by learning “secrets” about the “$700 billion banking industry bailout.” This case was filed in the U.S. District Court for the Western District of Missouri. After the court issued a temporary restraining order, the defendants agreed to an interim order that prohibits any alleged misconduct pending resolution of the case.

Darling Angel Pin Creations and two principals allegedly claimed on the Internet and in newspaper advertisements that by purchasing a starter kit, consumers could earn up to $500 per week assembling angel pins, and that no experience, special tools, or sewing skills were required. Consumers paid between $22 and $45 to get started, and sometimes paid hundreds more for the supplies they would need to make the pins. However, according to the FTC’s complaint, there was a catch: Consumers were required to have one of their assembled angel pins approved by the company before they could make any money – but the company rejected nearly all the angel pins consumers submitted, no matter how well-made. The FTC charged that the defendants made false and baseless claims that consumers could earn substantial income from angel pin assembly, when in fact they could not. This case was filed in the U.S. District Court for the Middle District of Florida, Tampa Division. After the court issued a temporary restraining order, the court issued interim orders with regard to all the defendants in the case prohibiting further misconduct.

Abili-Staff, Ltd., two principals, and a related entity sold supposed work-at-home opportunities online. Billing itself as a “scam free” and “legitimate” job search service, Abili-Staff sold supposedly pre-screened lists of jobs, telling consumers they could access the lists after paying a fee ranging from $29.98 to $89.99, according to the FTC’s complaint. The FTC alleged that defendants falsely told consumers they would have unlimited access to more than 1,000 work-at-home job listings, and that they would get their money back if they did not get a job. This case was filed in the U.S. District Court for the Western District of Texas, San Antonio Division. The court issued a temporary restraining order pending a preliminary injunction hearing held February 16-17, 2010.

Entertainment Work, Inc. and two principals marketed memberships in a Web site that was supposed to list jobs as movie extras, jobs on television, or jobs in print media. By telemarketing and placing advertisements on Web sites and in newspapers across the country, the defendants sold trial memberships for $19.95 to $24.95, and automatically converted those into annual memberships for an additional fee of $80 after two weeks, according to the FTC complaint. The FTC charged that Entertainment Work deceptively claimed consumers would find entertainment and media jobs near where they lived, without regard to their experience, skills, or appearance. The complaint also charged that the company failed to disclose that to cancel their membership, people would have to pay an additional fee or undertake a burdensome process. This case was filed in the U.S. District Court for the Southern District of Florida. The defendants have agreed to an interim court order that immediately halts the alleged misconduct.

Independent Marketing Exchange, Inc. and its principal allegedly made false earnings claims, and additional misrepresentations in the course of selling a smorgasbord of work-at-home opportunities, including an envelope mailing opportunity, a postcard mailing opportunity, and a mystery shopper opportunity. Their deceptive practices have injured numerous consumers, including stay-at-home and single mothers. The FTC’s complaint alleged that the defendants falsely represented to consumers that they could make substantial amounts of money. The case was filed in the U.S. District Court in the District of New Jersey. After the court issued a temporary restraining order, the defendants agreed to an interim order pending a further hearing.

Preferred Platinum Services Network and the husband-and-wife team who owned and operated it allegedly marketed a work-from-home scheme in which consumers were told they could earn significant sums by labeling postcards describing a non-existent product promoted by Preferred Platinum called “mortgage accelerator.” Advertised in local pennysavers and newspaper classified sections, and at the defendants’ Web site, the scheme touted earnings of up to $1 per postcard, as well as a 60-day money-back guarantee. Consumers paid an enrollment fee of $80 to $90, and they typically did not learn until later that they would have to pay $40 more for each additional batch of 100 postcards, according to the FTC complaint. At the same time this matter was filed, criminal authorities executed search warrants on the business and arrested the husband-and-wife team, charging each of them with one count of mail fraud. This case was filed in the U.S. District Court for the District of New Jersey. The court issued a temporary restraining order, followed by a preliminary injunction on February 16, 2010. Both individual defendants also have been indicted by a grand jury.

In addition to the seven cases announced today, since last summer, the FTC has settled or litigated four law enforcement actions stemming from employment and work-at-home scams:

Job Safety USA. Principal Wagner Ramos Borges allegedly systematically offered phony jobs to people seeking maintenance and cleaning work. The U.S. District Court for the District of Maryland Greenbelt Division, issued a default judgment ordering Borges to pay $414,900 – which is the estimated amount of his profits during the period covered by the FTC complaint. http://www.ftc.gov/opa/2009/07/shortchange.shtm

Career Hotline, Inc. Career Hotline took money from job seekers by guaranteeing them jobs that paid at least $25,000 per year, according to the FTC complaint. The federal court in the Middle District of Florida issued a default judgment against Career Hotline ordering the company to pay $75,000, which is the estimated amount of money job seekers lost to this scam. In addition, the company’s principal, Susan Bright, reached a settlement with the FTC that prohibits her from deceiving consumers about job availability, salaries, access to interviews, job listings and refunds. The settlement order also includes a suspended judgment against her because she is financially unable to pay, but the full judgment will become due immediately if Bright misrepresented her financial condition. http://www.ftc.gov/opa/2009/08/hotline.shtm

Penbrook Productions. The FTC complaint alleged that in this online scam, principal Michael Allen Brooks used fictional spokesperson “Angela Penbrook” to entice consumers to become “certified” rebate processors, supposedly earning as much as $225 per hour. A settlement approved February 10, 2010 by the U.S. District Court for the Central District of California requires the defendants to pay $125,000 within 10 days, plus a significant additional amount from assets they own that are to be liquidated. The settlement bars the defendants from making or assisting others to make deceptive claims in connection with work-at-home, franchise, or business opportunities. http://www.ftc.gov/opa/2009/07/shortchange

International Marketing and principal Zolio Cruz Carrion falsely promised Spanish- speaking consumers substantial income for stuffing envelopes, and was charged in an FTC complaint filed in the U.S. District Court for the District of Puerto Rico in 2008. The court granted the FTC’s motion to hold Cruz in contempt for failing to comply with an earlier order and briefly jailed him for contempt. It also prohibited him from marketing any business, employment, investment or work-at-home opportunity. http://www.ftc.gov/opa/2009/12/intermarketing.shtm

The FTC would like to acknowledge the assistance of: AARP’s Legal Counsel for the Elderly; United States Postal Inspection Service, Tampa Field Office; Better Business Bureaus of Southern Arizona, West Florida, New Jersey, the Southland (Southern California), and Coastal, Central, & Southwest Texas; U.S. Attorneys for the Southern District of New York, New Jersey and Western District of Missouri; Attorney General’s Offices of Florida, New Jersey and Pennsylvania; Florida Department of Agriculture and Consumer Service; Washington State Department of Financial Institutions, Securities Division Los Angeles County Department of Consumer Affairs; Ocean County New Jersey Department of Consumer Affairs; and the Tucson Police Department.

The enforcement actions announced today named the following defendants: Government Careers Inc. – Jon Coover; Richard Friedberg; and Rimona Friedberg. Abili-Staff, Ltd. – Pamela Barthuly; Jorg Becker; and Equitron, LLC. Darling Angel Pin Creations, Inc. – Shelly R. Olson and Judith C. Mendez; d/b/a/Angel Pin Creations. Entertainment Work, Inc. – Jason Barnes and Racquelle Barnes; d/b/a Resource Publishing Co. Independent Marketing Exchange, Inc. – Wayne Verderber, II, d/b/a as National Data Management, N.D.M., Global Mailing Services, G.M.S., Independent Mailing Services, Independent Mailing Services, Inc., I.M.S., Independent Shoppers Network, Independent Shoppers, Success At Home, Success-At-Home Mailing, IMEX, IMEX, Inc., and Continental Publishing Company. Preferred Platinum Services Network – Rosalie Florie; d/b/a Home Based Associate Program and PPSN, LLC. and Philip D. Pestrichello, individually. Real Wealth, Inc. – Lance Murkin; doing business as American Financial Publications, Emerald Press, Financial Research, National Mail Order Press, Pacific Press, United Financial Publications, Wealth Research Group, and Wealth Research Publications.

NOTE: The Commission authorizes the filing of complaints when it has “reason to believe” that the law has been or is being violated, and it appears to the Commission that a proceeding is in the public interest. A complaint is not a finding or ruling that the defendants have actually violated the law. Stipulated final orders are for settlement purposes only and do not constitute an admission by the defendants of a law violation. A stipulated final order requires approval by the court and has the force of law when signed by the judge.

Copies of the documents related to these cases are available from the FTC’s Web site at http://www.ftc.gov and also from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580. The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,700 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

FTC Testifies About Stepped-Up Efforts to Protect Consumers Affected by the Economic Downturn
The Federal Trade Commission today told the U.S. Senate Committee on Commerce, Science and Transportation that the agency has stepped up efforts to protect consumers affected by the economic downtown, and that additional authority would make the agency even more effective.

The testimony presented by FTC Chairman Jon Leibowitz described the agency’s efforts to prosecute financial fraud and deception, including working with states to bring hundreds of cases against mortgage relief scams in 2009. The testimony also discussed the FTC’s rulemaking and consumer education initiatives, how additional authority will enhance the agency’s effectiveness, and the FTC’s perspective on recent proposals to create a consumer financial protection agency as part of a broader reform of the financial services regulatory system.

As stated in the testimony, during the past five years the FTC has targeted financial services providers in more than 100 actions and, over the past decade, obtained nearly half a billion dollars in redress for consumers. As the economic downturn has taken hold, the FTC’s highest priority has become targeting frauds that prey on consumers made vulnerable by the financial crisis. The agency has shifted more of its consumer protection staff to the area of financial services, while continuing to carry out its broader consumer protection mission. In addition to prosecuting mortgage foreclosure and loan modification scams – with our state attorney general partners bringing more than 200 lawsuits last year – the FTC has targeted a variety of other deceptive and fraudulent schemes, including those in mortgage servicing, debt relief services, credit repair, economic stimulus scams, debt collection, advance-fee loans, payday lending, and credit card marketing, as well as fake get-rich-quick schemes, work-at-home offers, and job-hunting ads.

Describing other FTC efforts in the financial area, the testimony noted that it is in the process of formulating new rules to address unfair or deceptive practices in:

1. Mortgage relief services
2. Mortgage advertising and servicing
3. Debt relief services

Also, in conjunction with the federal banking agencies, the FTC is considering additional rules to protect the privacy of consumers’ sensitive financial information. The testimony also recounted the FTC’s many
education campaigns to help consumers manage their resources and avoid scams, including a major effort on mortgage relief services scams.

According to the testimony, new enforcement and regulatory tools would strengthen the FTC’s ability to anticipate and respond to financial fraud. The agency encourages Congress to give it explicit authority to act against those who assist others they know, or consciously avoid knowing, are engaged in unfair or deceptive practices under the FTC Act. The FTC has asked Congress for authority to use more efficient rulemaking procedures to address consumer protection issues and enhance the agency’s ability to stop financial fraud. In addition, the FTC would like the authority to seek civil penalties for violations of the FTC Act, and to prosecute civil penalty cases in federal court in its own name so that it can bring cases more quickly and more effectively.

Regarding President Obama’s proposed Consumer Financial Protection Agency, the testimony expressed FTC support for the goal of making consumer financial protection more effective while ensuring that the FTC’s authority and ability to protect consumers remains uneroded and clear. The FTC should remain active and effective in policing financial and nonfinancial products and services.

The Commission vote authorizing the testimony was 4-0. Commissioner Kovacic dissents from that portion of the testimony that seeks across-the-board authority for the Commission to use, for promulgating all rules respecting unfair or deceptive acts or practices under the Federal Trade Commission Act, the notice and comment procedures of the Administrative Procedure Act, although he would be willing to consider whether all the procedures currently required to issue, repeal, or amend these rules are necessary. Commissioner Kovacic also dissents from the Commission's endorsement of across-the-board civil penalty authority.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,700 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

Ohio Attorney General Richard Cordray

A job seeker who lost money to a scam

Also attending will be representatives of the U.S. Postal Inspection Service, Monster.com, and Microsoft
 
WHEN: Tuesday, February 9, 2010, 11 a.m.
 
WHERE: Federal Trade Commission
600 Pennsylvania Ave., N.W., Room 432
Washington, DC
Call-in Information: The toll-free phone number (in the U.S. and Canada) is (866) 363-9013, the confirmation number is 55572813, and the chairperson is Gail Kingsland. The lines, which are for media only, will open at 10:45 a.m. EST. Please reference the confirmation number when joining the call.
 
VIDEO: A new FTC consumer education video, available in English and
Spanish, tells anyone looking for work how to steer clear of a job scam. Still shots from the Web sites of some of the operators charged in this law enforcement sweep, as well as video footage of Consumer Protection Director Vladeck, and Monica Vaca, an Assistant Director in the Division of Marketing Practices, will also be available. They can be downloaded at aperturefilms.com/ftc when the press conference begins.
PRESS CONTACT: FTC Office of Public Affairs
202-326-2180

The Federal Trade Commission has joined an effort to alert consumers to online deceptive marketing connected to free trial offers that require individuals to cancel or opt-out of a recurring charge for future products or services.

The Director of the FTC’s Bureau of Consumer Protection, David C. Vladeck, appeared at a press conference with officials from Visa and the Better Business Bureau (BBB) today to caution consumers about the free trial feature, known as a “negative option.” In a negative option feature, a company takes a consumer’s failure to cancel a free trial offer as permission to begin charging for the service. While many merchants use this billing process appropriately, others pre-check consent boxes, bury the details of the offers in the fine print, terms and conditions, and make cancellations or returns difficult, catching consumers in a cycle of recurring charges for products and services they do not want.

“Free trial marketing can be convenient for consumers–if the terms are clearly spelled out beforehand,” Vladeck said. “Legitimate marketers don’t hide critical information about costs or cancellation policies to get their customers to agree to future charges.”

The FTC, Visa and the BBB offer tips to online shoppers on how to spot deceptive free trial offers, and how to deal with unauthorized charges:

Take time to read and understand all terms and conditions, so a free trial doesn’t turn into a costly purchase you didn’t intend to make.

Pay particular attention to any pre-checked boxes before you submit your payment card information for an order. Failing to un-check the boxes may bind you to terms and conditions you don’t want.

Review credit card statements when you get them for any unauthorized charges, and notify the card issuer promptly of any unusual activity or unauthorized charges.

Try to resolve the situation with the merchant. If you’re unsuccessful, contact the card issuer immediately to dispute the charge.
Consumers who think they’ve been victims of deceptive marketing and who haven’t been able to resolve the issue directly with the merchant should call their card issuer to dispute the charge. They also may report their experiences to the FTC at www.ftc.gov/complaint or their local BBB at www.bbb.org. More information is available at www.visa.com/negativeoption.

Related:

FTC Consumer Alert on Free Trial Offers

Richard Cleland has finally clarified once and for that affiliate disclosure should be done at the point of the affiliate link, which makes sense when it comes to being clear and conspicuous. I suppose it should have been obvious to me, but when I first started researching the issue nearly two years ago there was a lot of confusion among even the A-List bloggers about what they needed to do.

At WorkAtHomeTruth, we are finishing up moving ALL products (affiliate products and any we create) to a separate store area and within a review by the "WorkAtHomeTruth Staff" the first thing a person will see is "Available at the WorkAtHomeTruth store" so there is no possible confusion that we are selling the product we are reviewing.

But I'll save information about the new store set up for a later post. I want to talk about the strange case of the strange history of affiliate marketing.

When I first started studying affiliate marketing many years ago almost all of the major courses recommended "hiding" affiliate links – and not just to prevent affiliate theft, but because they said an affiliate link would look strange to a consumer and would potentially make them hesitant to click on the link.

Now, the marketers weren't necessarily saying to hide the material connection, but on the other hand none of them were saying to make the material connection explicit – and as anyone knows who's been in affiliate marketing since 1999 as I have – affiliates didn't even think in terms of disclosing material connections (initially because most affiliates were more concerned with providing tremendous value to their visitors, although obviously that changed over the years).

It's strange to think about the early years of affiliate marketing now after learning more about how the FTC views "clear and conspicuous disclosure" this year. The first time I read their actual information on clear and conspicuous disclosure over a year ago I was more confused after reading the guidelines than before. So either the new guidelines are clearer or I'm just smarter.

How the FTC viewed the future of interactive marketing in 1996

Since when I first started studying affiliate marketing I wasn't keyed in at all to the tremendous amount of information the FTC has available, I was curious to see what was potentially available at the time.

I'll post more, but the first thing that caught my eye were the remarks of Mary L. Azcuenga (FTC Commissioner at the time) PMAA Promotion Law/Marketing Conference on November 20, 1996…specifically this section:

"THE FUTURE

Speaking of the future, let me look forward for a moment to future challenges. It is difficult to overstate the rapid evolution that is occurring in the communications marketplace. These changes, principally the growing ascendency of computers and the Internet, can provide enormous benefits to consumers in terms of choice, convenience and the ability to obtain information about products or services. They also present some significant challenges for law enforcement.

Interactive marketing on the Internet will rely heavily on attracting consumers to particular websites. This can be accomplished in many ways, including contests, games and sweepstakes. One company even announced last week a proposal to begin paying consumers to watch advertising. Other Internet advertisers may seek new audiences by trying to enhance the content on their websites. One of the potential challenges of Internet marketing that may loom ahead and is reason for some concern is the very real possibility of a further blurring of the lines between editorial content and advertising.

This blurring already has occurred in traditional media. Newsweek referred to the problem as the "New Hucksterism." The Commission has just announced final issuance of a consent order in a case that presented a novel form of marketing(8). The company sent mailings to several million consumers across the country. Inside the envelope was what appeared to be an article torn from a magazine, printed on glossy, magazine stock and complete with a ragged margin, a byline, and a page number and month and year at the bottom of the page. The article, entitled "Applause, Applause," appeared to be a favorable review of a $300 book on how to be a successful speaker. To complete the picture, a self-adhesive, yellow note was attached to the article with the following handwritten notation directed to the name of the individual recipient: "Try this. It works! J."

In fact, the Commission alleged, this mailing was a promotion designed to sell the book. The supposed book review was written by the marketer and never had appeared in a magazine. The attached note was not from a friend or acquaintance, the mysterious "J," but again, was part of the promotion. In short, the entire solicitation was designed to fool consumers into believing that it was not just another promotion, but rather an independent review of the book mailed to the consumers by some acquaintance vouching for its quality.

This case is a good illustration of an important principle of law. It is deceptive for an advertiser to disguise a promotion as an independent review, editorial content, or something other than an advertisement. We have applied this principle in several contexts in recent years, including our guides for the use of endorsements and testimonials, "infomercials," those feature-length advertisements appearing in news report format that imply an independent review of the virtues of a product, and, more recently, the "advertorial," the term often used to describe an advertisement made up to look like an editorial. Consumers should be able to tell when a message comes to them as a paid advertisement. Only then can they evaluate the message critically."

Click here for the entire text of the remarks.

Clearly the FTC already had in its mind that it would have a hard time keeping up with technology. But what's amazing to me – considering that it was never addressed in my early affiliate marketing training is that the FTC predicts with dead-on accuracy:

"One of the potential challenges of Internet marketing that may loom ahead and is reason for some concern is the very real possibility of a further blurring of the lines between editorial content and advertising".

I think that the fact that most of us as affiliates didn't think about this issue much early on really reflects something Steven Wagenheim stated over at the Warrior Forum:

"Know what the problem is?

Too many of you folks have been marketers for too long and have
forgotten how to just be regular folk."

Defendants Could Pay More Than $1 Million for Failing to Disclose Terms of Recurring-Fee Plan

An online marketer of purportedly “free” Internet auction kits, which automatically charged unwitting consumers $59.95 a month for enrollment in an “online supplier” program for Internet auctions, has agreed to settle Federal Trade Commission charges that its actions violated federal law. The separate proposed court settlements with the company and two of its former executives bar them from similar deceptive conduct in the future, and require them to make specific disclosures to ensure consumers are aware of any recurring-fee plans (also known as “continuity plans” or “negative option plans”) for which they are signing up or being charged. The proposed court settlements also require the settling defendants to pay a total of what could be more than $1 million.

According to the FTC’s complaint, Commerce Planet operated a Web site offering consumers a free “online auction kit” that included information about how to start a business selling products on online auction sites such as eBay. Commerce Planet claimed the kit would provide consumers with “an easily managed online business that has the potential to supplement, or even replace” their current source of income. Although Commerce Planet allegedly told consumers they would be charged as little as $1.95 shipping and handling for this “free” trial offer, consumers had to provide their credit card information, and many were unwittingly signed up for the company’s $59.95 per month “Online Supplier” program. The FTC contends that over an 18-month period Commerce Planet did not clearly and conspicuously disclose that, by registering for the “free offer,” consumers also were agreeing to be enrolled in the “Online Supplier” program and would be charged a “membership fee” of up to $59.95 per month unless they canceled within a few days of ordering.

The terms and conditions of the program, including information about the recurring $59.99 fee, were difficult to find on Commerce Planet’s Web site. They appeared on a separate page from the trial offer that could only be accessed by a link, or on the payment page, but below the bottom of the visible screen. Most consumers did not even realize they had been enrolled in “Online Suppler” until their credit cards were repeatedly charged, after which many requested refunds. Most consumers had difficulty getting a refund, frequently calling the company multiple times, and sometimes had to contact an attorney or ask their credit card companies to reverse the charges.

The FTC’s complaint charged Commerce Planet with violating federal law by: 1) failing to disclose that consumers who ordered their online auction kit would be signed up for a continuity
program; and 2) unfairly charging consumers for the “Online Supplier” program without getting their express informed consent to do so.

The proposed court orders settle charges against Commerce Planet, former Commerce Planet CEO Michael Hill, and Aaron Gravitz, the former president of Legacy Media LLC, a wholly owned subsidiary of Commerce Planet. The orders prohibit the settling defendants from misrepresenting any material facts associated with the sale of a product or service, including specific representations that are common in negative-option offers. The FTC’s case against the fourth defendant, former Commerce Planet president Charles Gugliuzza, will proceed in federal court.

The settling defendants must make specific disclosures before requesting payment for any product or service and before making any offer with a continuity plan feature. They must first get consumers’ express informed consent before charging them for any goods or services, and must document the consumers’ consent in all transactions involving a continuity plan feature. Finally, the proposed orders require the defendants to provide information about their refund policies, honor their refund policies, monitor their sales agents, and track their agents’ billing information.

The orders include judgments of $19.7 million against each settling defendant, which have been suspended due to their inability to pay. Under the orders, however, Commerce Planet will pay $100,000, Gravitz will pay $192,000, and Hill will pay $230,000, plus future proceeds from loans that may bring his total payments to over $900,000.

The Commission vote authorizing the staff to file the complaint and proposed stipulated final orders against Commerce Planet, Hill, and Gravitz, as well as the complaint against Gugliuzza, was 4-0. The complaint was filed in the U.S. District Court for the Central District of California on November 10, 2009, and the stipulated orders were lodged with the court on November 16, 2009. The orders have not yet been signed by the court.

NOTE: The Commission authorizes the filing of a complaint when it has “reason to believe” that the law has or is being violated, and it appears to the Commission that a proceeding is in the public interest. A complaint is not a finding or ruling that the defendants have actually violated the law. Stipulated final orders are for settlement purposes only and do not constitute an admission by the defendants of a law violation. Consent orders have the force of law when signed by the judge.

Copies of documents related to this case are available from the FTC's Web site at http://www.ftc.gov and also from the FTC's Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, DC 20580. The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC's online Complaint Assistant at www.ftccomplaintassistant.gov or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,500 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC's Web site provides free information on a variety of consumer topics.

The Federal Trade Commission has asked a federal court to issue a contempt order against BlueHippo, a company that collected more than $15 million from consumers based on claims that it would finance their purchases of new computers, but delivered neither the financing nor the financed computers, in violation of a 2008 court order. The FTC alleged that less than one percent of consumers who signed up with BlueHippo received the financed computers they applied for, and undisclosed conditions to redeem “store credits” were rigged to discourage consumers from using them.

In a contempt motion lodged with the court today, the FTC charged that BlueHippo has flouted a settlement reached with the agency last year, continuing to deceive thousands of financially strapped consumers with phony promises that it would help them purchase a computer even if they have credit problems. The FTC also is asking the court to order BlueHippo to compensate injured consumers and bar BlueHippo from similar conduct in the future.

“Years of broken promises by BlueHippo have left consumers seeing red,” said FTC Chairman Jon Leibowitz. “We’re putting companies like this on notice: If you mistreat consumers and thumb your nose at the courts, we will hold you accountable.”

The FTC reached a settlement with Baltimore-based BlueHippo in April 2008 that required the company to pay $3.5 million for consumer redress and barred the defendants from further deceiving customers. According to the FTC’s 2008 complaint, BlueHippo Funding, LLC and affiliate BlueHippo Capital, LLC offered to extend credit to consumers to finance purchases of personal computers and other consumer electronics with down payments of $99 to $124, and a year of weekly or bi-weekly payments ranging from $36 to $88. BlueHippo promised to deliver the product once the consumer made 13 weekly payments. But most consumers did not receive the computers they ordered in the time promised, even after they had made 13 weeks of payments, the Commission alleged. The Commission charged that BlueHippo’s marketing tactics were deceptive, and violated the FTC Act and other federal credit statutes.

Even after this settlement order was entered by the court, BlueHippo continued to deceive consumers, according to the FTC. The company aggressively marketed itself as a computer finance company and spent the rest of 2008 signing up customers and taking their money, but failing to provide them with financed computers. The FTC’s contempt motion alleges that between April and December of 2008, more than 35,000 customers contracted for BlueHippo’s computer financing deal. But the company provided, at most, a single financed computer, failing to provide financed computers even for 2,477 customers who managed to meet the companies’ conditions. Complaints about the company poured into the Better Business Bureau. On top of all that, BlueHippo failed to submit a report to the FTC showing how it was complying with the settlement, as required by the order.

Finally, in April, 2009, after the FTC notified the court that BlueHippo was violating the settlement, the company began ordering thousands of computers. Even so, the FTC alleges that BlueHippo failed to order computers for 1,015 of the 2,477 consumers who had qualified for financing by making 13 consecutive payments and completing the required paperwork. For the 1,462 consumers who finally received a computer, BlueHippo did not even order – let alone ship – the computers within the three- to four-week time frame the company had advertised. On average, it took about six months between the time these consumers qualified for their computers and the time BlueHippo ordered the machines, according to the FTC’s contempt motion.

The FTC’s contempt motion also charged that BlueHippo failed to disclose key aspects of its refund policy. In particular, the company promised that while consumers who canceled their order after seven days could not obtain cash refunds, they could get “store credit,” which could be used to buy desktop computers, laptops, monitors, software, and televisions. But it failed to tell consumers that they would have to send a money order to cover undisclosed shipping and handling fees, as well as taxes, even if they had more than enough store credit to cover these costs – and that they could only order one item at a time.

The contempt motion against defendants BlueHippo Funding, LLC; BlueHippo Capital, LLC; and Joseph Rensin was filed in the U.S. District Court for the Southern District of New York.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,500 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

Read the original FTC press release here along with related documents

Attorney Failed to Turn Over Proceeds from Defendants’ Business Opportunity Involving Sale of Internet Kiosks to Consumers.

The Federal Trade Commission has filed civil contempt charges against an attorney who represented the marketers of an “Internet kiosk” business opportunity that turned out to be nothing more than a Ponzi scheme.

In its contempt action, the Commission charged that the attorney representing defendants in the case flouted a March 2009 federal court order that required him to turn over $238,300 to the FTC. The court had previously had determined that money given to the attorney as a retainer for his work on the case derived from the defendants’ proceeds from their illegal scheme. The court found that the FTC was entitled to that money, so that it could be used to reimburse victims of the scam.

In the March 2009 order, the court also imposed an $18.9 million judgment against the operators of the scam – Network Services Depot, Charles Castro, and several other defendants. The judgment upheld FTC charges that the defendants violated the FTC Act and the agency’s Franchise Rule by duping hundreds of consumers into buying Internet kiosk business opportunities with false promises of lucrative earnings. The judgment paved the way for the FTC to distribute more than $2 million to victims.

The civil contempt action against Jeffrey S. Benice and his law firm, Jeffrey S. Benice, a Professional Law Corporation, was filed in the U.S. District Court for the District of Nevada.

Copies of the March 2009 order and other court documents are available from the FTC’s Web site at http://www.ftc.gov/ and also from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, DC 20580.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,500 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

Read the full press release here along with related documents.

Related: FTC Press Release about the 18.9 million dollar judgement 

Company Also Required to Implement Comprehensive Anti-Fraud Program and to Monitor its Agents

MoneyGram International, Inc., the second-largest money transfer service in the United States, will pay $18 million in consumer redress to settle FTC charges that the company allowed its money transfer system to be used by fraudulent telemarketers to bilk U.S. consumers out of tens of millions of dollars. MoneyGram also will be required to implement a comprehensive anti-fraud and agent-monitoring program.

The FTC charged that between 2004 and 2008, MoneyGram agents helped fraudulent telemarketers and other con artists who tricked U.S. consumers into wiring more than $84 million within the United States and to Canada – after these consumers were falsely told they had won a lottery, were hired for a secret shopper program, or were guaranteed loans. The $84 million in losses is based on consumer complaints to MoneyGram – actual consumer losses likely are much higher.

The FTC charged that MoneyGram knew that its system was being used to defraud people but did very little about it, and that in some cases its agents in Canada actually participated in these schemes. According to the FTC’s complaint, MoneyGram knew, or avoided knowing, that about 131 of its more than 1,200 agents accounted for more than 95 percent of the fraud complaints it received in 2008 regarding money transfers to Canada; a similarly small number of agents was responsible for more than 96 percent of all fraud complaints to the company in 2006.

“Money transfer services have a responsibility to make sure their systems don’t become conduits to rip people off,” said David C. Vladeck, Director of the FTC’s Bureau of Consumer Protection. “In this case, MoneyGram not only ducked this responsibility, but also looked the other way while its agents took part in the scams.”

Minneapolis, Minnesota-based MoneyGram operates through a worldwide network of approximately 180,000 agent locations in 190 countries and territories. In its complaint, the FTC charged that in recent years this network has increasingly been used by telemarketing scammers to prey on U.S. consumers. Con artists prefer to use money transfer services because they can pick up transferred money immediately, the payments are often untraceable, and victimized consumers have no chargeback rights or other recourse.

In 2007, 72 percent of all complaints received by the FTC involving Canadian-based fraud reported using money transfer services to make payments. According to a recent FTC survey cited in the complaint, at least 79 percent of all MoneyGram transfers of $1,000 or more from the United States to Canada over a four-month period in 2007 were fraud-induced. The Commission’s complaint further stated that based on the more than 20,600 fraud complaints MoneyGram itself received, U.S. consumers lost more than $44 million to cross-border money-transfer frauds between 2004 and 2008 alone. When combined with losses reported by U.S. consumers on money transfers within the United States, that number grows to $84 million.

In many of the scams that used MoneyGram’s money transfer system, the con artists used counterfeit checks to induce consumers to send money back by wire transfer. The most prevalent of these scams were lottery or prize schemes in which consumers were told they had won thousands of dollars and just had to pay a fee for “taxes,” “customs,” or “insurance” to a third-party to collect their winnings. Consumers paid the fee using MoneyGram, but received nothing. In another scheme, telemarketers told consumers they were guaranteed loans, regardless of their credit score. All they had to do was pay “insurance,” “paperwork,” or “processing” fees to complete the transaction. Consumers who sent funds using a money transfer service got nothing in return.

In mystery shopping scams, the con artists called U.S. consumers or sent them a piece of direct mail in which they claimed to be hiring consumers to visit stores such as Wal-Mart to evaluate MoneyGram money transfer operations. The con artists sent consumers a cashier’s check, telling them to deposit it in their checking account and then send most of the money back using a money transfer at Wal-Mart. When the counterfeit checks bounced, consumers realized they had lost the money they transferred. By this time, however, the money transfer agents had already received and paid out the money, often either without checking IDs or by using fake drivers license information.

The FTC’s complaint alleges that MoneyGram ignored warnings from law enforcement officials and even its own employees that widespread fraud was being conducted over its network, claiming that proposals to deal with the problem were too costly and were not the company’s responsibility. The company even discouraged its employees from enforcing its own fraud prevention policies or taking action against suspicious or corrupt agents. Some employees who raised concerns were disciplined or fired, the FTC charged.

In addition, at least 65 of MoneyGram’s Canadian agents have been charged by Canadian or U.S. law enforcers with, or are currently being investigated for, colluding in fraud schemes that used the MoneyGram system.

The complaint charges MoneyGram with violating both the FTC Act and the FTC’s Telemarketing Sales Rule by helping sellers or telemarketers who it knew – or consciously avoided knowing – were violating federal law, and for not taking adequate steps to prevent fraud.

The agreed-upon court order settling the FTC’s charges bars MoneyGram from knowingly providing substantial help or support to any sellers or telemarketers that are violating the Telemarketing Sales Rule and requires it to implement a comprehensive anti-fraud program. Under the anti-fraud program, MoneyGram must conduct background checks on prospective agents; educate and train its employees about consumer fraud; institute agent monitoring; and discipline agents who don’t comply with the rules. The order also requires MoneyGram to provide a clear and conspicuous fraud warning on the front of all its money transfer forms. The order’s conduct provisions apply to all MoneyGram money transfers sent worldwide from either the United States or Canada.

The order contains monitoring and discipline provisions that will ensure MoneyGram is properly training, monitoring, and taking actions to address problems related to its agents. To do this, the order requires MoneyGram to develop and maintain a system for receiving consumer complaints and data, and to provide that information to the FTC upon request. MoneyGram also must take all reasonable steps to identify agents that are involved in fraud. It must review its transaction data to identify any unusual or suspicious activity by its agents and fire any agent who it believes may be participating in fraudulent activities. It also must fire or suspend any agent who has not taken appropriate steps to stop fraudulent money transfers.

Finally, MoneyGram will pay the Commission $18 million, which will be used to provide redress to consumers.

Consumer Education

The FTC has a new Consumer Alert, available on its Web site athttp://ftc.gov/bcp/edu/pubs/consumer/alerts/alt034.shtm, titled “Money Transfers Can Be Risky Business.” It includes useful information on how consumers can avoid telemarketing and money transfer fraud, including the following tips. Don’t wire money to:

• someone you don’t know, in the U.S. or in a foreign country;
• someone claiming to be a relative in the midst of a crisis and who wants to keep the
  request for money a secret;
• someone who says a money transfer is the only form of payment that’s acceptable; or
• someone who asks you to deposit a check and send some of the money back.

Consumers interested in the process of redress administration should call 202-326-3755.

The FTC’s case was investigated with the assistance of the Toronto Strategic Partnership, Project Colt, Project Emptor, and the U.S. Postal Inspection Service. Additional assistance was provided by the Durham Regional Police Service, Ontario, Canada, and the Canadian Anti-Fraud Call Centre (PhoneBusters).

The Toronto Strategic Partnership includes the FTC, the U.S. Postal Inspection Service, Competition Bureau Canada, the Toronto Police Service Fraud Squad – Mass Marketing Section, the Ontario Provincial Police Anti-Rackets Section, the Ontario Ministry of Consumer Services, the Royal Canadian Mounted Police, and the United Kingdom's Office of Fair Trading. Project Colt includes the FTC, the Royal Canadian Mounted Police, Surete du Quebec, City of Montreal Police Service, Canada Border Services Agency, Competition Bureau Canada, U.S. Homeland Security, U.S. Postal Inspection Service, and the Federal Bureau of Investigation. Project Emptor includes the FTC, the Business Practices and Consumer Protection Authority of British Columbia, the Royal Canadian Mounted Police, Competition Bureau Canada, the Federal Bureau of Investigation, and the U.S. Postal Inspection Service.

The Commission vote approving the complaint and proposed consent order was 3-0, with Commissioner Pamela Jones Harbour recused. The complaint and order were filed on October 19, 2009, in the U.S. District Court for the Northern District of Illinois, Eastern Division.

NOTE: The Commission authorizes the filing of a complaint when it has “reason to believe” that the law has or is being violated, and it appears to the Commission that a proceeding is in the public interest. A complaint is not a finding or ruling that the defendants have actually violated the law. A stipulated court order is for settlement purposes only and does not necessarily constitute an admission by the defendants of a law violation. Stipulated orders have the force of law when signed by the judge.

Copies of the complaint and stipulated order are available from the FTC’s Web site athttp://www.ftc.gov and from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580. The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,700 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

Click here for the original FTC press release, supporting documentation, and consumer tips

10/5/2009 FTC Press Release:

Changes Affect Testimonial Advertisements, Bloggers, Celebrity Endorsements
The Federal Trade Commission today announced that it has approved final revisions to the guidance it gives to advertisers on how to keep their endorsement and testimonial ads in line with the FTC Act.

The notice incorporates several changes to the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising, which address endorsements by consumers, experts, organizations, and celebrities, as well as the disclosure of important connections between advertisers and endorsers. The Guides were last updated in 1980.

Under the revised Guides, advertisements that feature a consumer and convey his or her experience with a product or service as typical when that is not the case will be required to clearly disclose the results that consumers can generally expect. In contrast to the 1980 version of the Guides – which allowed advertisers to describe unusual results in a testimonial as long as they included a disclaimer such as “results not typical” – the revised Guides no longer contain this safe harbor.

The revised Guides also add new examples to illustrate the long standing principle that “material connections” (sometimes payments or free products) between advertisers and endorsers – connections that consumers would not expect – must be disclosed. These examples address what constitutes an endorsement when the message is conveyed by bloggers or other “word-of-mouth” marketers. The revised Guides specify that while decisions will be reached on a case-by-case basis, the post of a blogger who receives cash or in-kind payment to review a product is considered an endorsement. Thus, bloggers who make an endorsement must disclose the material connections they share with the seller of the product or service. Likewise, if a company refers in an advertisement to the findings of a research organization that conducted research sponsored by the company, the advertisement must disclose the connection between the advertiser and the research organization. And a paid endorsement – like any other advertisement – is deceptive if it makes false or misleading claims.

Celebrity endorsers also are addressed in the revised Guides. While the 1980 Guides did not explicitly state that endorsers as well as advertisers could be liable under the FTC Act for statements they make in an endorsement, the revised Guides reflect Commission case law and clearly state that both advertisers and endorsers may be liable for false or unsubstantiated claims made in an endorsement – or for failure to disclose material connections between the advertiser and endorsers. The revised Guides also make it clear that celebrities have a duty to disclose their relationships with advertisers when making endorsements outside the context of traditional ads, such as on talk shows or in social media.

The Guides are administrative interpretations of the law intended to help advertisers comply with the Federal Trade Commission Act; they are not binding law themselves. In any law enforcement action challenging the allegedly deceptive use of testimonials or endorsements, the Commission would have the burden of proving that the challenged conduct violates the FTC Act.

The Commission vote approving issuance of the Federal Register notice detailing the changes was 4-0. The notice will be published in the Federal Register shortly, and is available now on the FTC’s Web site as a link to this press release. Copies also are available from the FTC’s Consumer Response Center, Room 130, 600 Pennsylvania Avenue, N.W., Washington, DC 20580.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 1,700 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s Web site provides free information on a variety of consumer topics.

MEDIA CONTACT:
Betsy Lordan
Office of Public Affairs
202-326-3707
STAFF CONTACT:
Richard Cleland
Bureau of Consumer Protection
202-326-3088
(FTC File No. P034520)
(endorsement testimonial guide.wpd)

The original release with full text in PDF format can be found here.

It's somewhat interesting to me to break down the analysis and reaction to the release by different groups (although obviously even these can be broken down much further):

Legal sites discussing the FTC release:

• Law.com Legal Blog Watch: The FTC Blog Rules: Overbroad or Overblown?
• Eric Goldman's Technology and Marketing Law Blog – Do the FTC's New Endorsement/Testimonial Rules Violate 47 USC 230?
• David Johnson's Digital Media Law Blog: Bloggers and Advertisers Beware: FTC Rules on Sponsored Endorsements Create Major Risks for "Word of Mouth" Advertising
• Mike Young Internet Law and Business Blog: FTC New Rule: Bloggers Must Disclose Compensation

News Sites discussing the release:

• Wall Street Journal – UPDATE: FTC Toughens Endorsement Rules For Celebrities, Bloggers
• Associated Press: FTC: Bloggers, testimonials need better disclosure
• CNET News: Yes, new FTC guidelines extend to Facebook fan pages
• MSNBC – FTC: Bloggers must disclose freebies on reviews

 Consumer Advocacy sites discussing the release:

• Consumer Reports – Bloggers Who Shill Must Also Tell (note: I find it somewhat strange that Consumer Reports sees no irony in the fact that they are mixing judgements with data in this headline).

Sites more critical of the new regulations

• BuzzMachine – FTC Regulates Our Speech
• EdRants.com – Interview with the FTC’s Richard Cleland
• Slate – The FTC's Mad Power Grab

Advertising and Marketing Organizations discussing the new FTC regulations

• Adage Discussion on the New Regulations
• Media Post – FTC Clamps Down On Ad Testimonials

Internet Marketers discussing the FTC release:

• Warrior Forum - Discussion on Final Endorsements and Testimonial Guidelines
• Alex Sysoef at HowToSpoter – FTC Attacks Affiliate Bloggers
• Frank Kern – FTC Declares Shenanigans On All Kinds of Stuff