New FTC Guidelines
WHY Is the FTC Cracking Down on Earnings Claims?
FTC Statement: Consumer Losses Attributable to Deceptive Ad Claims
* FTC v. Wealth Press (1-11-23): Trade Recommendations in Financial Markets – settlement $1.7 Million
* FTC v. Lurn (3-2-23): eCommerce Coaching $65 Million
* FTC v. DK Automation (11-16-22): Amazon Biz Ops - $52 Million
Net Impression
> How consumers perceive Earnings Claims
> Not what marketers imply, what consumers infer
* Reasonable Consumers (not gullible)
* Must be Substantiated
Earnings Claims
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We'll help you build your Autopilot AMZ Business!
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Average monthly revenue $165,015
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Conservative Profit Margin 25%
- Average Monthly Units Sold 796
Apply Net Impression to Earnings Claims
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Promised results $165K/Mo are “Typical”
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I should be able to achieve the same!
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“Reasonable Consumers”
Is the Typical Disclaimer Enforceable?
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Promised results Aspirational
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No promise that you can achieve the same!
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You may not make any money