How In-House Lawyers Responded to the FTC’s ‘Influencer’ Letters
Recently, the FTC sent letters admonishing social media influencers for including certain products in their social media posts and failing to provide adequate disclosures in those posts e.g., that the influencers were being compensated for highlighting the products. This article discusses how some attorneys responded to those FTC letters. It appears that most attorneys recognized the importance of the letters and advised their clients to ensure that future posts contain adequate disclosures. The challenge here is that the FTC, unlike their European counterparts, have not been explicit about what constitutes an adequate disclosure on social media.