[{"source":"FTC USA Business Blog Posts","id":3197413,"description":"New FTC warning letters cite unsupported Coronavirus-related health and earnings claims sgressin April 24, 2020 | 12:44PM New FTC warning letters cite unsupported Coronavirus-related health and earnings claims By Seena Gressin The FTC is not the pen pal you want if you operate a multi-level marketing company but aren’t closely monitoring your distributors. In its latest round of warning letters, the FTC warns ten MLM companies that they are responsible for the claims made by their participants. The letters direct the companies to report within 48 hours what actions they’ve taken to stop their distributors from claiming their products can treat or prevent Coronavirus disease, that MLM business opportunity participants are likely to earn substantial income, or both. The FTC says that the health and earnings claims are unsubstantiated and therefore violate truth-in-advertising laws. The products at issue are not scientifically proven to treat or prevent COVID-19, the disease that Coronavirus causes. The FTC previously has sent warning letters to companies about their Coronavirus-related health claims, but the new letters are the first to also target claims about potential business opportunity earnings. The letters come at a time when millions of people are out of work and facing financial challenges as a result of the pandemic. MLM companies rely on a network of independent distributors, sometimes called business opportunity participants, to buy and resell their products, often through direct person-to-person sales or online. MLMs typically offer participants a cut of the sales made by people the participant recruits to invest in the business opportunity. The new recruits then try to sell the products, and try to recruit more people to do the same. Most people who join MLMs make little or no money. According to the FTC, distributors of the MLM companies receiving the letters have posted promotional messages on Facebook, Instagram, and other social media sites. Health claims the FTC letters cite include: “STAY SAFE!! MAKE YOUR IMMUNE SYSTEM STRONG!!!” Standard coronavirus protection kit . #antiseptics and #immunity_support.” “HOW WILL YOU FIGHT OFF CORONA? USE NUTRABURST-CHAGA- .... #coronacure #coronaprevention ... #immunesupport #immunebooster ... #immunesystembooster” “Got the coronavirus heebeegeebees? Boost your immunity with this amazing deal!!!!” “... If interested to learn more or obtain oils or rollers Let me know A little extra protection can help #doterra #NursesCOVID19 #Dialysis #ImmunityBoosters #ImproveRespiratoryFunction” Earnings claims the FTC letters cite include: “...Living in quarantine and where 14 million people applied for unemployment just last week ... I’ll stick with the opportunity to change people’s lives ... turn a small investment into six figures .... #arbonne ... #quarantine #2020” “Need to make extra money? Find it difficult to pay your bills? Were you laid off/ #fired? Be your own Boss w/doTERRA essential oils. Msg me to achieve financial independence #laidoff #unemployed #cantpaymybills #cantpaymyrent #student #sales #sidehustle #makemoney #stayathomemom.” “[E]veryone’s getting stimulus checks right now... There is no better investment you could do... Take that money that you’re about to get back... figure out a way to make this happen tonight.” In the letters alleging unsubstantiated health claims, FTC staff reminds the companies that, under the FTC Act, claims that a product can prevent, treat, or cure a serious disease require the support of well-controlled human clinical studies. Because “no such study is currently known to exist” for the advertised products, the FTC says the companies “must immediately cease making all such claims.” In the letters alleging deceptive earnings claims, FTC staff reminds the companies that under the FTC Act, “claims about the potential to achieve a wealthy lifestyle, career-level income, or significant","pubDate":"Mon, 05 Oct 2026 08:07:08 +0200","url":"https://www.ftc.gov/business-guidance/blog/2020/04/new-ftc-warning-letters-cite-unsupported-coronavirus-related-health-earnings-claims","titre":"New FTC warning letters cite unsupported Coronavirus-related health and earnings claims"},{"source":"FTC USA Business Blog Posts","description":"FTC challenges influencer campaign for Warner Bros.’ Shadow of Mordor game lfair July 11, 2016 | 11:17AM FTC challenges influencer campaign for Warner Bros.’ Shadow of Mordor game By Lesley Fair In the popular video game Shadow of Mordor , players don’t just randomly slash, hack, and pillage. They battle specific opponents through a feature known as the Nemesis System. In the FTC’s lawsuit against Warner Bros. Home Entertainment , truth in advertising had a nemesis: paid pitches for Shadow of Mordor that Warner Bros. deceptively claimed were independent reviews. And read on for a startlingly candid statement by one of those influencers. To help launch Shadow of Mordor , Warner Bros. brought a social media company on board to coordinate a YouTube influencer campaign. One strategy was to hire influential gamers to post videos promoting Shadow of Mordor – videos that ultimately yielded more than 5.5 million YouTube views. In addition to free game access, Warner Bros. paid the influencers cash – ranging from hundreds of dollars to five figures. Influencers’ videos were subject to pre-approval and, according to the terms of the agreement, Warner Bros. “will be deemed the author and exclusive owner.” Warner Bros. was quite exacting in what else it required of influencers: “Video will feature gameplay” of the Shadow of Mordor game. “Video will have a strong verbal call-to-action to click the link in the description box for the viewer to go to the [game’s] website to learn more about the [game], to learn how they can register, and to learn how to play the game.” “Video will promote positive sentiment” about the game. “Video will not show bugs or glitches that may exist.” “Video will not communicate negative sentiment” about Warner Bros. Home Entertainment, its affiliates or the game. Warner Bros. also required “One Facebook post or one Tweet by Influencer in support of Video.” “Positive sentiment” posted for cash? That sounds like the kind of material connection between an advertiser and endorser the FTC says should be clearly and conspicuously disclosed. And for FTC watchers, that’s where the story gets almost as interesting as Shadow of Mordor . According to the complaint , influencers were directed to place sponsorship information in the text of the description box – that’s the collapsed box just below a YouTube video – not in the video itself. Furthermore, they were told to put “information about [the game] above the fold” in the description box and that the “description box will include FTC disclaimer disclosing that the post is sponsored.” But as the first example shows, only the top few lines of the description box are immediately visible. Without clicking the “Show More” button and possibly scrolling down, consumers wouldn’t see the sponsorship disclosure – especially since Warner Bros. mandated that game information had to come first. The second screenshot shows an example of the sponsorship information at the end of the expanded “Show More” box and illustrates – inadvertently perhaps – the FTC’s concern with the placement of the disclosure. In this example, the gamer wrote “This video sponsored by Warner Bros.” and followed with this telling statement: “No one reads this far into the description ... what are you doing snooping around.” Our sentiments exactly, Dude. In other instances, influencers’ videos included a half-hearted sponsorship disclosure – for example, “This has been one of my favorite sponsored games, so thanks that I could play it for free!!” – that failed to mention that in addition to free play, Warner Bros. was paying them thousands of dollars. The complaint charges that Warner Bros. falsely represented that the Shadow of Mordor gameplay videos reflected the independent opinions or experiences of impartial","id":3189423,"url":"https://www.ftc.gov/business-guidance/blog/2016/07/ftc-challenges-influencer-campaign-warner-bros-shadow-mordor-game","titre":"FTC challenges influencer campaign for Warner Bros.’ Shadow of Mordor game","pubDate":"Thu, 01 Oct 2026 08:11:55 +0200"}]