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FTC Hyundai No Action Letter

FTC Hyundai No Action Letter

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Published by Bennet Kelley
Hyundai NAL
Hyundai NAL

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Published by: Bennet Kelley on Feb 01, 2013
Copyright:Attribution Non-commercial

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02/01/2013

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Division of Aderising Practice
Christpher Smith, EsquireSNRDentn
1301
K Street, NWWashingtn, DC
20005-7019
UNTED STATES OF AMERICA
FEDEAL TRDE COMMISSON
WASHNGTON, D.C
20580
Nvember
16,2011
Re:Hyundai Mtr erica, FTC File N
1123110
Dear Mr SmithAsyu knw, the staff f the Federal Trade Cmmissin's Divisin f AdverisingPractices has cnducted an investigatin int whether yur client, Hyundai Mtr America("Hyundai) r thers wrking fr r n its behalf, vilated Sectin
5
f the Federal TradeCmmissin Act,
15
USC §
45
in cnnectin with a blgging campaign designed t buildinterest in ads that wuld premiere during the bradcast f Super Bwl XV.Our inquiry fcused n whether blggers wh had been given gi certicates as anincentive t include links t Hyundai vides in their pstings and/r t cmment n thesefrhcming Super Bwl ads were tld t disclse t their readers that they had received thiscmpensatin r indeed were tld nt t disclse this infrmatin Sectin
5
requires thedisclsure f a material cnnectin beween an adveriser and an endrser when such arelatinshp is nt therwise apparent frm the cntext f the cmmuncatin that cntains theendrsement
A
adveriser's prvisin f a gi t a blgger fr psting specic cntent prmting the advertiser's prducts r serices is likely t cnstitute a material cnnectin thatwuld nt be reasnably expected by readers f the blgUpn carel review f this matter, including nn-public infrmatin submited t thestaff, we have determined nt t recmmend enfrcement actin at ts time We cnsideredseveral factrs in reachng this decisin First, it appears that Hyundai did nt knw in advanceabut use f these incentives, that a relatively small number fblggers received the gicericates, and that sme f them did, in fact, disclse this infrmatinSecnd, the actins with which we are mst cnceed here were taken nt by Hyundaiemplyees, but by an individual wh was wrkng fr a media rm hired t cnduct theblgging campaign Althugh advertisers are legally respnsible fr the actins f thsewrking directly r indirectly fr them, the actins at issue here were cntrary bth t Hyundai'sestablished scial media plicy, whch calls fr blggers t disclse their receipt f cmpensatin, and t the plicies f the media rm in questin Mrever, upn leng f themiscnduct, the media rm prmptly tk actin t address it

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