Mpa 3999 Capstone Thesis

Kushnir, Small, Riggio 1
High Stakes: A Guide to Legal and Ethical Cannabis Marketing
Clark University Capstone Practicum
MPA/MSPC 3999
Shea Kushnir, Mo Small, Anabel Riggio

Introduction:
Research Question
Since its legalization of adult-use cannabis in 2016, Massachusetts has been tasked with a
difficult policy question: How can we create one centralized guide to legal and ethical cannabis
marketing in Massachusetts? While many adult-use dispensaries and medical treatment centers
(MTCs) have opened in the past 7 years, entrepreneurs and industry professionals must remain
competitive to keep their businesses afloat. However, Massachusetts legislation surrounding
cannabis marketing and advertising are highly regulative and restrictive. As the cannabis
industry continues to grow, business owners are challenged to create marketing plans that are
legal, ethical, and effective simultaneously. Through the evaluation of a multi-media marketing
plan, our paper will aim to create a standard guide to the legal and ethical evaluation of cannabis
advertisements.
Cannabis Equity
Our research aims to create a more fair and equitable cannabis industry by streamlining
the regulatory process. Oftentimes, the numerous regulations on cannabis are a barrier to
someone who is entering the industry. The Cannabis Control Commission’s legislation is dense
and difficult to understand, especially for those without the educational privilege to read and
understand the nuances of the law. Due to school segregation, the war on drugs, and other racial
inequities, there is an education gap between white communities and Black and Brown
communities. While Massachusetts has created a social equity program for cannabis
entrepreneurs most directly impacted by the drug war, there is not much easily accessible,
educational information for those branching out into the industry.

Adult use vs. MTCs:
While our research will focus on adult-use recreational cannabis dispensaries, it is
essential to note the differences between adult-use dispensaries and medical treatment centers
(MTCs). Although post-legalization dispensaries greatly outnumber MTCs, MTCs are subject to
different and arguably less restrictive regulations. According to the Massachusetts Cannabis
Control Commission (CCC), MTCs are defined as, “...the site(s) of dispensing, cultivation, and
preparation of Marijuana for medical use” (CCC, 2022). MTC consumers must be qualifying
patients with what is deemed as a Debilitating Medical Condition, determined at the CCC’s
discretion. These consumers must receive a medical cannabis identification card through a
healthcare provider. Conversely, adult-use dispensaries, known by the CCC as marijuana
establishments, are legal retailers, cultivators, and researchers of legal cannabis for adult
recreational use (CCC, 2022). Both MTCs and marijuana establishments require vastly different
licensing to open and operate. Throughout our research, we will refer only to marijuana
establishments, which are able to serve every adult over 21 years of age, and in turn, are subject
to strict regulations and policies.
Marketing Plan Evaluation
Through our project, we will demonstrate, critique, and revise a marketing plan for a
fictional adult-use marijuana establishment. This plan will be comprised of logos, graphics, and
mock-ups of social media posts, created by Shea Kushnir and evaluated by Mo Small and Anabel
Riggio. The plan will be presented in drafts and its revisions will be displayed in the appendices
of this paper. Our goal is to walk our readers through the same regulatory process that real-world
cannabis entrepreneurs experience while navigating the cannabis marketing sector. This
evaluation will be accompanied by assessing existing research that has been completed on the
ethics surrounding cannabis marketing and is presented in case studies and podcasts. The project
will then be published online so that anyone can view our guide without paywalls or barriers of
complicated legalese.
Literature Review
Existing Legal Research
Since Massachusetts legalized adult-use cannabis in 2016 via a ballot initiative, the
Cannabis Control Commission has imposed statutes, regulations, and programs for adult-use
cannabis in the Commonwealth. The following State legal regulations will be reviewed
alongside the federal prohibition of adult-use cannabis, which still imposes criminal legal
liability on all participants within the cannabis supply chain, including cultivators, laboratory
operators, and retailers. The literature consults various sources, including the Cannabis Control
Commission, the Massachusetts State Legislature, and attorneys practicing within the newfound
legal specialty of cannabis law.
The seminal regulation that monitors adult-use cannabis in Massachusetts – and is
enforced by the Cannabis Control Commission – is 935 CMR (Code of Massachusetts
Regulations) 500.000 entitled, “Adult Use of Marijuana.” Before the creation of this
comprehensive regulatory package, the CCC’s draft regulations initially addressed the following
four categories: false or misleading claims, the restriction of advertising to anyone under 21
years old, conspicuous or coded advertising, and product label warnings disclosing the potential
risks of consumption (Austin, 2018). Since our research focuses on the legality of cannabis
marketing and advertising, the section we primarily dealt with in 935 CMR was 500.015,
“General Operational Requirements for Marijuana Establishments.” Within Section 500.015, the
subsection we primarily consulted was Section 4, “Advertising Requirements.” Section 4

discusses permitted and prohibited advertising practices for cannabis retailers, covering issues
such as brand name development and sponsorship, audience composition, pricing, mandated
inclusion of stipulated warnings, broadcast advertising, print advertising, and use of promotional
materials (CCC, 2023). The permitted and prohibited practices from Section 4 comprise the bulk
of our regulatory framework, which is supplemented by the Regulation and Taxation of
Marijuana Act. This Act legalized the production, distribution, and sale of adult-use cannabis
and instituted the Cannabis Control Commission as the State’s cannabis regulatory authority.
The Act also introduces the State’s audience composition threshold for cannabis marketing and
advertising, which stipulates that cannabis advertisements must be directed toward an audience
of which at least 85 percent are verified adults 21 years of age and older. The Act expects
cannabis retailers to verify the ages of consumers prior to sale to avoid legal liability. This
means the maximum percentage of minor exposure permitted is 15 percent (Commonwealth of
Massachusetts, 2016).
Other entities within the cannabis industry likewise maintain voluntary regulations for
organizational members, such as the National Association of Cannabis Businesses, or the NACB.
While these regulations are not mandated by the State, many cannabis businesses in
Massachusetts adhere to them. The need for additional regulations arose from the increased
popularity of consumer-targeted cannabis advertisements populating in legalized adult-use states
around the country (PR Newswire, 2018). Like 935 CMR 500.000, NACB regulations include
permitted and prohibited practices, including issue areas like advertised consumption, advertised
transport of cannabis goods across state lines, digital advertising prescriptions, packaging of
cannabis products, false and misleading statements, allergen warnings, and audience composition
(National Association of Cannabis Businesses, 2018). Since regulations vary across legalized
adult-use states, members of the National Association of Cannabis Businesses often aspire to
elevated standards that include more stringent regulations than those enforced by their respective
state cannabis regulatory body. Heightened regulations better safeguard cannabis businesses
from federal criminal legal liability. Our legal framework will account for the voluntary
regulations set forth by the NACB, which will be interwoven into CCC-enforced regulations.
Even though the State has passed regulations and statutes that legalize and monitor adult-
use cannabis, the persistence of federal statutes, such as the Controlled Substances Act (1970),
presents a continued liability to cannabis businesses in the Bay State. Under the Controlled
Substances Act, or CSA, cannabis is categorized as a Schedule I substance – the most restrictive
ranking for controlled substances – which makes the federal advertising of marijuana production,
distribution, sale, and/or consumption a felony, whether that advertising is communicated in
print, digitally, or via telecommunications. This means that, technically, cannabis businesses in
legalized adult-use states are still subject to federal criminal legal liability. The threat of liability
was somewhat weakened, however, by the Cole Memo (2013) – established by Deputy Attorney
General James Cole – that ushered in the contemporary period of enforcement whereby the
Department of Justice takes a hands-off approach to the prosecution of cannabis under the CSA,
instead transferring enforcement to U.S. Attorneys’ offices and state and local law enforcement.
The Drug Enforcement Agency, the Department of Justice’s jurisdictional enforcement
mechanism, has become increasingly inactive in enforcing cannabis prohibition (Austin, 2018;
CCC, 2019; Mandell, 2019; Larkin, 2021).
Social equity cannabis businesses, which are designated as such during the licensing
process, introduce important legal implications into the cannabis industry. As the State’s
cannabis regulatory body, the CCC oversees the Social Equity Program (SEP), which is designed
to bolster the prospects of cannabis retailers from historically disadvantaged backgrounds
through State-subsidized training programs and expedited license application review. SEP is
meant to incentivize more cannabis retailers from marginalized backgrounds to enter the state
cannabis industry. The program, while enforced by the CCC, is conducted with the cooperation
of state municipalities (CCC, 2023). Since municipalities control the number of licensees within
a specified locale, social equity programs have allowed for more equitable competition among
cannabis entrepreneurs for entry into local and state markets. These programs also attempt to
rectify the disproportionate impact wrought by cannabis prohibition on communities of color by
elevating the business prospects of social equity entrepreneurs (Unger, 2022; Fertig, 2020). To
fund the CCC’s social equity efforts, the State legislated and passed the cannabis reform bill,
“An Act Relative to Equity in the Cannabis Industry,” which created the Cannabis Social Equity
Trust Fund to subsidize future social equity entrepreneurs entering the Massachusetts cannabis
industry. The Fund takes 15 percent of the current balance from the State’s Marijuana
Regulation Fund; these funds will be aggregated and distributed to social equity entrepreneurs
and economic empowerment applicants entering the industry (Commonwealth of Massachusetts,
2022).
Existing Ethical Research
While ethical considerations are certainly present in cannabis advertisement legislation,
there is a community expectation that cannabis entrepreneurs will go beyond the written policies
to ensure that their products do not end up in the hands of any inappropriate group or individual.
Therefore, we consulted multiple case studies that focus on the ethics of cannabis marketing to
ensure that our client’s marketing plan is not only legally sound but also, morally acceptable.
The following case studies and analyses helped us to craft our ethical expectations for our
client’s marketing plan.
While cannabis marketing is still largely uncharted territory, due to its stigmatization and
federal illegality, numerous researchers have evaluated the impact of marijuana advertisements
on youth. The case study, “Highs and Lows of Cannabis Decriminalization: Twitter Analysis and
Ethical and Regulatory Implications for Retailing and Marketing”, begs the question, “...how do
marketing and public policy intersect to ensure that ethical target marketing is used in the
cannabis industry…?” (Mann, et. al, 2022). In this study, it was determined that Twitter is a
helpful guide in social media policy making because of the nature of the app. On Twitter, “When
persuasive messages are tweeted and shared by a number of people, a social norm can emerge
regarding a certain issue and can serve as cues on how to think, feel, or act” (Mann, et. al, 2022).
This information is especially pertinent, as Twitter has recently loosened the guidelines
surrounding cannabis advertising. This study will help us make informed determinations about
our client’s use of Twitter in her marketing plan.
A Canadian case study examines where and when children are most likely to see cannabis
advertisements, and whether they are likely to try cannabis as a result of what they have seen. An
interesting finding in this study is that most advertisements were in the form of celebrity
promotion (Noel, et. al, 2021). While cannabis policies and attitudes certainly differ between
Canada and Massachusetts, this information is pertinent as it provides insight into what minors
are most likely to be exposed to. The authors find this, “...concerning, as an increase in social
media use and novel potential for social engagement and peer network integration could increase
youth vulnerability to cannabis marketing through social medical channels” (Noel, et al., 2021).
Celebrity endorsements are a difficult form of advertisement to navigate in Massachusetts, as it

is illegal to utilize any public figure who may appeal to children (CCC, 2023). However, which
public figures appeal to children is up for interpretation. This study was inconclusive on whether
or not increased exposure to cannabis advertisements leads to a greater likelihood to use cannabis
as a minor. However, it offers impactful insight into how social media is potentially targeting
minors with inappropriate content.
A 2022 study assesses cannabis marketing exposure to minors by using a Latent Class
Analysis (LCA), which is used to determine whether and how likely cannabis advertisements
impact certain groups of adolescents in comparison to others. The purpose was to determine
whether exposure to cannabis marketing on social media and print correlates with the
development of Cannabis Use Disorder, a psychological dependence on cannabis. A major goal
of our ethical evaluation is to ensure that cannabis does not end up in the hands of minors. The
authors find, “From a prevention perspective, this study suggests there may be discrete groups of
adolescents at elevated risk from exposure to algorithmic cannabis marketing” (Trangenstein, et.
al, 2022). This study helps to confirm our assumption that adolescents are highly susceptible to
cannabis marketing due to their active online presence. Therefore, we are responsible for
avoiding algorithmically or subliminally targeting minors with our client’s advertisements.
Along with keeping cannabis out of the hands of minors, we are responsible for ensuring
that no specific racial or ethnic group is targeted by our marketing, whether intentionally or
accidentally. Both the stigmatization and criminalization of cannabis use are based on systemic
racism. In fact, early cannabis prohibition was used as a means to target and incarcerate people
of Color, most specifically Black and Mexican men. Harry Anslinger, who served a long tenure
as the director of the Federal Bureau of Narcotics in the mid-1900s, even coined the term
“marihuana” in an attempt to exoticize cannabis so that xenophobic white Americans would

associate the plant with Latin American immigrants and in turn, stay away from it. Anslinger
was quoted as saying, “There are 100,000 total marijuana smokers in the US, and most are
Negroes, Hispanics, Filipinos, and entertainers. Their Satanic music, jazz, and swing, result from
marijuana usage. This marijuana causes white women to seek sexual relations with Negroes,
entertainers, and any others” (Lucien, 2023). These rampant prejudices are what allowed racism
to be the motivating factor of the war on drugs and the over-policing of Black, Brown, and low-
income communities.
Today, in a post-legalization Massachusetts, social equity programs have been created to
economically empower those most directly impacted by the war on drugs. However, one policy
recommendation by Jennifer B. Unger, Ph.D. asks, how can we prevent an over-concentration of
adult-use dispensaries in low-income areas, as we have seen occur with both alcohol and
tobacco? While cannabis is widely considered to be minimally problematic to one’s health,
certain harms come along with cannabis use, such as cannabis-impaired driving and an increased
risk of cannabis use disorder. These are especially concerning risks when it comes to children
and adolescents. Unger writes, “Exposure to advertisements for cannabis retailers (e.g.,
billboards, outdoor signs)... could signal to adolescents that cannabis use is normative, resulting
in increased adolescent use” (Unger, 2022). While we want to effectively market our product, we
must avoid contributing to health disparities in non-white communities that have already been
disproportionately harmed by Nixon and Anslinger’s war on drugs. Therefore, we are
considering the intersections between race, class, and cannabis use in the evaluation of our
client’s marketing plan.
Another policy recommendation explores how we may limit marketing to higher-risk
groups such as pregnant people. While there is a lack of research on the effects of using cannabis
during pregnancy, most healthcare professionals advise against its use. However, 14% of
pregnant adolescents are reported to have used cannabis on a regular basis (Kees et. al, 2019).
This questions the ethicality of, “...whether the marketing of cannabis as a product with medical
benefits has created the illusion of “healthfulness” among pregnant women” (Kees et. al, 2019).
Current Massachusetts legislation requires two of five warning labels to be conspicuously placed
on any cannabis advertisements. One states, “Marijuana should not be used by women who are
pregnant or breastfeeding” (CCC, 2023). While there is no conclusive evidence on whether or
not these labels are effective on cannabis users, studies on warnings on alcohol and liquor bottles
have shown that they are “largely ineffective” on pregnant alcohol consumers (Kees, et. al,
2019). This evidence goes to show that simply warning pregnant people is not enough. Cannabis
entrepreneurs have a moral obligation to ensure that cannabis is not directly marketed to
pregnant people. While research on how cannabis advertising affects consumers is sparse, these
studies can help us to make informed decisions on the ethical evaluation of our client’s work.
Methodology
We employ a secondary data analysis using qualitative data sourced from select podcast
episodes published by marketing and advertising specialists in the cannabis industry to create an
evaluation framework to assess the two marketing proposals crafted by our client, Ms. Kushnir,
for our mock cannabis retailer. The evaluation framework will be used twice for both the first
and second marketing proposals. The first assessment will review Ms. Kushnir’s draft marketing
proposal before revisions, which is provided under the forthcoming evaluation subsection, “First
Draft Marketing Plan.” The second assessment will review Ms. Kushnir’s revised marketing
proposal and is provided under the other evaluation subsection, “Second Draft Marketing Plan.”
The secondary data analysis examines three podcasts that were chosen based on their salience to
cannabis marketing in interstate and intrastate marketplaces, specifically the Massachusetts
marketplace. The podcasts, alongside consulted literature, helped create the legal and ethical
evaluation criteria used to assess our client’s first and second marketing proposals for our mock
cannabis retailer.
Secondary Data Analysis
Heaton (2008) defines secondary data analysis as the “re-use of pre-existing qualitative
[or quantitative] data derived from previous research studies, … such as semi-structured
interviews, responses to open-ended questions in questionnaires, field notes, and research
diaries.” She describes secondary data analysis as serving two main purposes: “... investigate
new or additional research questions” and/or “... verify the findings of previous research”
(Heaton, 2008). Instead of repurposing qualitative data from a formal dataset, our secondary
data analysis repurposes select qualitative data – open-ended and unstructured podcast
“interviews” – for a new research purpose: constructing evaluative criteria for the assessment of
two marketing proposals for our mock cannabis retailer. Because the original purposes of the
three selected podcasts – spotlight industry professionals that provide marketing and advertising
recommendations to various stakeholders in the cannabis industry – are not starkly different from
the purpose of our secondary analysis, our analysis can be specifically understood as a
supplementary analysis, which denotes a “more in-depth analysis of an emergent issue or aspect
of the data that was not addressed or only partially addressed in the primary study…” (Heaton,
2008). While the three selected podcast episodes provided marketing suggestions to
stakeholders, they did not categorize these recommendations into a discernible framework or
schema. Our secondary analysis exploits this gap and repurposes the unstructured “interviews”
between podcast hosts and their guests into specified and interactive criteria.
The use of podcasts in various methodologies, including qualitative ones such as
secondary data analysis, is not a newfound concept or practice. Kinkaid et al. (2019) defended
the methodological benefits of podcasts in their article, “The Podcast-As-Method?: Critical
Reflections on Using Podcasts to Produce Geographical Knowledge.” While their defense
focused on the methodology’s application to the discipline of geography, the benefits extend
beyond geography into other research programs. The benefits they identified include the
following: the auditory format of podcasts allows audiences to discern visceral and connoted
meanings of dialogue beyond the capabilities of textual formats; polyvocality between hosts and
guests fosters diversity in perspectives without privileging one over another; and the ability of
podcasts to decrease the distance between academia and the public through the presentation of
niche topics in layman’s terms. Kinkaid et al. (2019) also acknowledge the accessibility of
podcasts found on multiple streaming services, such as Apple Music, Spotify, and other
platforms, that allow audiences to revisit certain episodes for deeper engagement with content.
The methodological benefits identified by Kinkaid et al. (2019) have been affirmed by
scholars from other disciplinary backgrounds. DeMarco (2022) affirms these benefits through
her research published in the article, “Hear Here! The Case for Podcasting in Research.” Like
Kinkaid et al. (2019), DeMarco (2022) acknowledges that benefits such as polyvocality and
accessibility are somewhat unique to podcasts. She also recognizes the multifaceted functions of
podcasts, which can be used as educational and/or communicative tools for various audiences.
Since the inception of the COVID-19 pandemic, DeMarco (2022) claims that podcasts have
become increasingly commonplace in higher education as tools for knowledge production,
dissemination, and interactive discussion. This role, combined with the methodological benefits
of podcast research, helps substantiate our secondary data analysis using selected podcast
episodes from reputable sources in the field of cannabis marketing.
Our selected podcasts constitute several convergent purposes, namely, digesting
information about niche topics within the broad field of cannabis marketing, such as social media
advertising, brick-and-mortar dispensary marketing, digital advertising, print advertising, and
audience composition rules. Our secondary data analysis consists of taking the qualitative
knowledge and recommendations put forth in the selected podcasts for conversion into
evaluation criteria. The criteria are separated into two subdivisions: legality and ethics. This
conversion of secondary data into a framework allows us to manipulate podcast data for the
evaluation of our client, Ms. Kushnir’s, initial and revised marketing proposals.
We selected three podcast episodes from three separate podcasts within the burgeoning
cannabis marketing and advertising field, which are the following: “088 New England Cannabis
Brand That Sells Good Buds to Great Neighbors with Alex Mazin of Bud’s Goods” from To Be
Blunt (Torabi, 2022) ; “055: Solving the Licensing and Regulatory Challenges for Canna-
Businesses with Dr. Sherry Boodram” from The Green Repeal – A Guide to Cannabis Marketing
& Advertising (Kiley and Boedges, 2022) ; and “Lisa Buffo, Founder, CEO, Cannabis Marketing
Association” from Thinking Outside the Bud (Eckfeldt, 2020). We reasoned that selecting three
separate podcasts diversifies our sources of knowledge, effectively broadening the knowledge we
can repurpose for our secondary data analysis; regardless, all sources of knowledge come from
experts and professionals with years and decades of practice with cannabis marketing. These
sources of knowledge differ in their roles within the field of cannabis marketing. For instance,
the three interviewees from each podcast maintain the following roles: founder and CEO of
CannDelta, a cannabis consulting firm operating within Canada and the U.S.; founder and CEO
of the Cannabis Marketing Association, the first and largest national cannabis membership
organization in the U.S.; and founder and CEO of Bud’s Goods, an adult-use brick-and-mortar
dispensary operating within central and eastern Massachusetts. The three podcast episodes span
from July 2020 to July 2022, making them salient and relevant to our research.
Like the interviewees, the podcast hosts from all three podcasts represent reputable
sources of knowledge, maintaining the following titles and qualifications: Shayda Torabi, host of
To Be Blunt, is the CEO of RESTART CBD, a cannabis dispensary located in Austin, Texas;
Rick Kiley and Jeff Boedges, co-hosts of The Green Repeal, co-manage the national market
consulting firm, SoHo Experiential, and are active in the burgeoning cannabis markets of New
Jersey and New York; and Bruce Eckfeldt, host of Thinking Outside the Bud, is the CEO of Inc
500 and a strategic business coach providing advice to new businesses in various interstate and
intrastate cannabis markets. Kinkaid et al. (2019) and DeMarco (2022) concur that the strength
of podcasts as methodologies is their auditory format, which allows podcasters and their
interviewees to foster polyvocal dialogue without privileging the perspective of one over
another. The coexistence and sharing of knowledge produced and learned from podcasters such
as Torabi, Kiley, Boedges, and Eckfeldt and their interviewees, specifically Mazin, Boodram,
and Buffo, serve as the qualitative data for our secondary data analysis.
After reviewing the three podcast episodes, we identified the following themes –
essentially recommendations proposed by the podcast hosts and their guests – found within the
three podcast episodes: (1) cannabis businesses, such as dispensaries, should tailor their product
marketing to specific products’ intended methods of consumption; (2) marketing strategies,
whether interstate or intrastate, should differ based on designated market segments; (3)
regulatory compliance should be baked into the development of marketing strategies; and (4)
cannabis businesses incorporating ethics into their “true north” mission/vision, such as social
equity cannabis, can distinguish themselves in the marketplace and, subsequently, benefit
because of the potential competitive advantage. Secondary data analyses require that researchers
manipulate, alter, or convert data into a new form to serve an original purpose different from the
research purpose guiding the data’s initial collection (Heaton, 2008). Following this
prescription, we repurposed our identified themes into legal and ethical evaluation criteria.
Evaluation Criteria
We subdivided our identified themes into two umbrellas: legal and ethical. While they
represent two separate categorizations, they do interact and often overlap. For instance, legality
is often understood by ethicists as the minimum threshold of ethics. In this way, legality does
not necessarily imply ethics since the law often contains loopholes and caveats that challenge
ethical prescriptions. Notwithstanding, legality can and does adhere to ethical prescriptions,
especially when crafted alongside ethical considerations.
We included the following subcriteria under the legal umbrella: federal regulatory law,
state regulatory law, and local/municipal regulatory law. Examples of regulations pertinent to
our evaluation under the legal umbrella include the Controlled Substances Act of 1971, 935
CMR – which is enforced by the Cannabis Control Commission – and municipal ordinances and
host community agreements (HCAs) that stipulate the licensing process for cannabis retailers in
specific locales. These legal subcriteria were primarily generated from the first and third themes
identified within the three podcast episodes.
For the ethical umbrella, we devised the following subcriteria: corporate social
responsibility, social equity cannabis, and transparent advertising. Corporate social
responsibility denotes the ethical responsibility of cannabis retailers to reliably serve the interests
of their stakeholders, including customers, local communities, investors, and others. In a for-
profit and freshly regulated industry, adherence to this ethical subcriteria is especially
paramount. Transparent advertising moves beyond regulatory compliance, challenging cannabis
retailers to impose additional safeguards on the packaging, labeling, and other forms of
advertising that hopefully reduce the misuse of products by consumers and decrease minors’
exposure to cannabis advertisements. We specifically adopt two voluntary regulations published
by the National Association of Cannabis Businesses (NACB), including the “Advertising
Standards for Cannabis & Hemp Businesses” and “Packaging & Labeling Standards,” to
implement this sub-criterion (NACB, 2018). These subcriteria were primarily generated from the
first, second, and fourth themes identified within the podcast episodes.
Limitations
Heaton (2008) describes three primary methodological limitations of secondary data
analyses using qualitative data: “problem of data fit,” “problem of not having ‘been there,’” and
“problem of verification.” The latter two “problems,” while limitations, do not necessarily
problematize the methodological integrity of our secondary data analysis. Because podcasts
allow listeners to revisit previously recorded and uploaded episodes, the “problem of not having
‘been there’” during the data collection process is significantly reduced. The “problem of
verification” is likewise minimized because the lived experiences shared by third parties – for
example, experiences shared by podcast guests within the cannabis industry that support the
marketing and advertising recommendations proposed in the selected podcast episodes – are not
necessarily data verifiable through quantitative methods.
The primary limitation of our secondary data analysis is the “problem of data fit,” which
assesses “whether data collected for one (primary) purpose can be reused for another (secondary)
purpose” (Heaton, 2008). Applied to our methodology, the “problem of data fit” implies a
misalignment between the purpose of the primary research – three podcasts aggregating and
sharing marketing and advertising expertise with stakeholders in the cannabis industry – and the
purpose of our secondary research – the creation and implementation of an evaluation framework
for our mock cannabis retailer. Since we specifically employed a supplementary analysis, we
believe we reduced the significance of this limitation on the validity of our research.
Given the post hoc nature of secondary data analyses, the “problem of data fit” is never
entirely escapable. We considered a methodology employing primary research, specifically
semi-structured interviews with two industry professionals, before transitioning to a qualitative
secondary data analysis. This decision was made to adhere to the capstone deadline. Despite the
existence of the “problem of data fit,” we feel that our secondary data analysis somewhat reduces
this methodological limitation through the support of its use, specifically the qualitative (re)use
of podcasts, by other researchers such as Kinkaid et al. (2019) and DeMarco (2022).
Evaluation
First Draft Marketing Plan (Appendix A)
Our client, Ms. Shea Kushnir has presented us with an in-depth marketing plan for her
mock business, The Kushnirs’ House, a diner-themed dispensary and cafe. A copy of the draft
can be found under subsection “Appendix A”. We began by examining her name and logo. We
found the logo to be completely acceptable, pursuant to the CCC’s policies. The name is
intended to be a play on words between “kush,” a colloquial term for cannabis, and the client’s
surname, Kushnir. The Code of Massachusetts Regulations (CMR) states that “...colloquial
references to Marijuana and Cannabis are prohibited from use in the Brand Name” (CCC, n.d.).
However, we believe that if this name was denied or questioned by the CCC, we would be able
to argue its legality, as there is no provision stating that a business may not be named after a
person.
Apart from the CCC’s regulations on advertisement, most social media sites have their
own set of policies for posting about cannabis and other substances. Through our research, we
determined that some are more suitable for cannabis advertisement than others. Our client has
opted to use the following platforms in her marketing plan: Instagram, Facebook, TikTok,
Pinterest, Twitter, and YouTube. Pinterest allows advertisements for CBD (non-psychoactive
cannabinoid found in the cannabis plant) products, as long as they do not make any claims about
therapeutic or medicinal benefits. THC (psychoactive cannabinoid) advertisement is prohibited
Additionally, they do not allow targeting any protected groups in advertisement, such as people
of Color, disabled people, or children (Pinterest, 2023). Ms. Kushnir’s cafe will sell CBD
products, so she may advertise those, but not any products containing THC.
YouTube’s user policies do not mention the words “cannabis” or “marijuana.” However,
there is a section on the “Sale of illegal or regulated goods or services,” which includes
“controlled narcotics and other drugs,” which we assume THC products would fall under. It is
prohibited to advertise these products by including a direct link, phone number, or any other
means of sale. Our client’s plan is to have employees of The Kushnirs’ House share weekly
videos showcasing their favorite products. We believe this is acceptable, so long as there is no
way a viewer can purchase cannabis from the video.
New policy changes on Twitter allow for cannabis advertisement, with a few guidelines.
Advertisers must comply with local policies when creating their ads. They may not depict
pregnant women, cannabis consumption, anything appealing to minors, content that encourages
transportation across state lines, or make any claims about the drug’s health benefits. As long as
our client adheres to these guidelines, she may move forward with Twitter advertisements.
Instagram and Facebook, both owned by Meta, have some of the strictest policies when it
comes to posting about cannabis. These sites pose the biggest challenge for our client, as they are
also some of the most popularly used social media platforms. Their policy states:
Instagram doesn’t allow people or organizations to use the platform to advertise or sell
marijuana, regardless of the seller’s state or country. Our policy prohibits any marijuana
seller, including dispensaries, from promoting their business by providing contact
information like phone numbers, email addresses, street addresses, or by using the
“contact us” tab in Instagram Business Accounts (Facebook, 2023).
Additionally, Meta prohibits photographs of cannabis, including photos depicting its
consumption. However, plenty of adult-use dispensaries use these apps successfully, legally, and
ethically. Many even post photos of the plant without being reported for misuse or having the
post taken down. By a quick glance over existing dispensaries’ pages, one can tell that this rule
does not seem to be strictly enforced. Still, we recommend our client refrains from posting
photographs of cannabis or referring to the drug in any colloquial or non-scientific terms.
Additionally, Ms. Kushnir should be sure to include, “Must be 21+ to follow” in the account’s
bio. Her initial plan was to post “story posts announcing a new sale”, which we strongly advise
against. Not only are sales and discounts for THC products illegal, but this would also entail a
direct promotion on a site that prohibits doing so. The Kushnirs’ House Instagram and Facebook
accounts should remain purely educational, rather than directly promotional.
Finally, TikTok has a complete ban on posting about drugs of any kind– legal or illegal
(TikTok, 2023). The marketing plan states that TikTok will be used to, “post TikToks weekly of
the hottest, newest, or cheapest/on sale product”. This concept is not feasible under the
platform’s policies. As a result, we recommend Ms. Kushnir steers clear of TikTok as a whole
when it comes to marketing The Kushnirs’ House.
Outside of social media, we had some concerns regarding our client’s plan to use
discounts and loyalty programs. Ms. Kushnir’s initial marketing plan includes giveaways of free
products, discounts, and sales, and a “Brownie Points” system that rewards repeat customers for
their loyalty with free items and exclusive sales. However, the CMR states the following as a
prohibited practice:
Advertising through the marketing of free promotional items including, but not limited to,
gifts, giveaways, discounts, points-based reward systems, customer loyalty programs,
coupons, and "free" or "donated" Marijuana, except as otherwise permitted by 935 CMR
500.105(4)(a)9. and except for the provision of Brand Name take-away bags by a
Marijuana Establishment for the benefit of customers after a retail purchase is completed
(CCC, 2023).
Unfortunately, our client must eliminate the “Brownie Points” program from her plan to remain
within the CCC’s guidelines. Additionally, she plans to open the business with a large party
where free cannabis products are offered. We advise against free cannabis giveaways in any
capacity.
Ms. Kushnir’s marketing plan includes the creation of a dispensary website, which will
display information about the brand and the menu of what is available for purchase. While
websites are allowed, the CCC prohibits the “Operation of any website of a Marijuana
Establishment that fails to verify that the entrant is 21 years of age or older” (CCC, 2023). We
suggest that our client goes beyond asking, “Are you 21+?”, and asks the user to input their
entire date of birth to add an extra layer of security to keeping cannabis out of the hands of
minors.
Finally, our client hopes to conduct “Summer Pop-Up Events” to promote her business.
Ms. Kushnir will also distribute fliers and utilize print advertising to spread the word about The
Kushnirs’ House. Print advertisement is allowed to be displayed in public. However, any
promotional materials must follow the following guidelines:
Any such Advertising created for viewing by the public shall include the statement
"Please Consume Responsibly", in a conspicuous manner on the face of the
advertisement and shall include a minimum of two of the following warnings in their
entirety in a conspicuous manner on the face of the advertisement:
a. "This product may cause impairment and may be habit forming.";
b. "Marijuana can impair concentration, coordination and judgment. Do not operate a

vehicle or machinery under the influence of this drug.";
c. "There may be health risks associated with consumption of this product.";
d. "For use only by adults 21 years of age or older. Keep out of the reach of children."; or
e. "Marijuana should not be used by women who are pregnant or breastfeeding." (CCC,
n.d.)
The following warning must also be present:
This product has not been analyzed or approved by the Food and Drug Administration
(FDA). There is limited information on the side effects of using this product, and there
may be associated health risks. Marijuana use during pregnancy and breast-feeding may
pose potential harms. It is against the law to drive or operate machinery when under the
influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There
may be health risks associated with consumption of this product. Marijuana can impair
concentration, coordination, and judgment. The impairment effects of Edibles may be
delayed by two hours or more. In case of accidental ingestion, contact poison control
hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA. (CCC,
2023).
Additionally, these fliers may not be distributed or posted in, “...private vehicles and at bus stops,
taxi stands, transportation waiting areas, train stations, airports, or other similar transportation
venues…” (CCC, 2023). So long as Ms. Kushnir follows these guidelines, she will be able to
advertise The Kushnirs’ House in print.

Second Draft Marking Plan (Appendix B)
Following our revisions to the first draft, Ms. Kushnir submitted a second draft of her
marketing plan alongside mock-up advertisements and fliers for our review. We noticed that
nearly all legal flaws had been corrected. During our first evaluation, we were concerned about
our client’s plan to create a Brownie Points rewards system to offer discounts and deals to repeat
customers, as this is not permitted per the CMR. However, our client amended this marketing
tactic so that the Brownie Points system can only be used for CBD (non-psychoactive) products
and cannabis accessories such as rolling papers, smoking pipes, and herb grinders. This type of
amended rewards system is not outwardly prohibited by CMR guidelines. We consulted
Sunnyside Dispensary, a regional adult-use cannabis dispensary, and MTC, rewards system as a
comparison to our client’s. Under the subsection “Who can join Sunnyside Rewards,” it reads,
“All patients and customers shopping in AZ, FL and IL as well as MA medical patients can join
Sunnyside Rewards… MA Adult Use shoppers can join, however they are only eligible to
redeem their accumulated rewards on non-medicated products” (Sunnyside.shop, n.d.). While
this marketing practice is not explicitly permitted or prohibited by the Massachusetts CCC, we
believe it is a permissible workaround for the CCC’s strict regulations regarding discounts and
sales. We are confident that this rewards plan will adhere to both our legal and ethical framework
for Massachusetts cannabis marketing.

Cannabis Print Flyers First Draft (Figures 1-3)
Figure 1 (Left)
Figure 2
(Right)
Figure 3
During our second round of edits, our client presented us with three mock-up print
advertisements as an example of what she will distribute around the city of Boston. We identified
some legal errors within these fliers. Figures 1 and 3, depict adult-use products containing THC.
According to the CMR, “ Advertising of the price of Marijuana or Marijuana Products, except as
permitted above pursuant to 935 CMR 500.105(4)(a)6” (CCC, 2023). 935 CMR 500.105(4)(a)6
states that the prices of cannabis may be displayed in stores and that store attendants may
respond to questions about pricing. Our client intends to, “Share the opening of our dispensary
through fliers distributed across the Boston area”. If Ms. Kushnir wants to do so, she must
remove the prices from Figures 1 and 3. She may keep the price in Figure 2, as it advertises a
CBD product. One amendment she must make is to include the following statement in Figures 1
and 3:
This product has not been analyzed or approved by the Food and Drug Administration
(FDA). There is limited information on the side effects of using this product, and there
may be associated health risks. Marijuana use during pregnancy and breast-feeding may
pose potential harms. It is against the law to drive or operate machinery when under the
influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There
may be health risks associated with consumption of this product. Marijuana can impair
concentration, coordination, and judgment. The impairment effects of Edibles may be
delayed by two hours or more. In case of accidental ingestion, contact poison control
hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA. (CCC,
2023).
Once our client completes these steps, these print fliers will be safe for publication.
Some improvement our client made to her marketing plan is to ensure that there is a
secure age verification pop-up tab on the website. Additionally, Ms. Kushnir changed her social
media plan to better fit the policies of each given site. For example, on TikTok, she no longer
plans to show depictions of cannabis, but instead, to use it as a platform for employees to
introduce themselves. YouTube posts will be focused only on CBD products instead of both
THC and CBD. Finally, Instagram and Facebook will be used to share “memes” about cannabis,
which we assume will not depict cannabis or its use. While this use of Instagram and Facebook
falls under a “grey area” of permissibility, we believe that there is minimal risk involved, as there
are no legal ramifications for breaking a site’s cannabis policies. The worst-case scenario is a
suspension or banning of The Kushnirs’ House accounts, which may be a marketing calamity but
will not affect the legal operations of our client’s business.
Third Draft Marketing Plan

Ms. Kushnir removed the phone number from the fliers and added the necessary
warnings. The rest of the marketing plan remains amenable to our legal and ethical evaluation
criteria.
Ethical Evaluation of Marketing Plan
Our ethical evaluation of Ms. Kushnir’s marketing plan has been formulated by the
podcasts, case studies, and statistics we reviewed as a means to prepare for this project. We
believe that what is legal and what is ethical often intersect, and as a result, we want to ensure
both are true for our client’s plan. An important section for us to evaluate is the “Target
Audience” portion. She lists her target ethnographic as “White/caucasian, middle-upper class,
preppy, hippy, granola”. From our research on cannabis social equity programs in Massachusetts,
we have determined that this is not an inappropriate group to target. As previously mentioned, a
key goal of ours was to ensure that our client’s marketing plan does not negatively impact those
most harmed by the war on drugs. While we believe that the few harms associated with cannabis
are of minimal concern, other controlled substances such as tobacco and alcohol have
notoriously used advertisement as a means to target Black and Brown populations, and in turn,
promote the stigmatization of communities of Color in regards to substance abuse. While current
social equity policies in Massachusetts benefit people of disproportionate impact who wish to
join the cannabis industry, it is the ethical responsibility of businesses to ensure that those who
do not wish to engage in cannabis use are protected from targeted advertisements. Advertising
ethically is especially important in the cannabis industry, in which 81% of business owners are
white, as of 2017 (Hannah, et. al, 2021). By advertising in a manner that is transparent and
equivocal, we can ensure that Ms. Kushnir’s marketing plan is not only legally sound but also,
ethically appropriate.
Another key criterion for our ethical evaluation was to ensure that no advertisements
targeted children under the age of 21, the legal age of cannabis consumption in Massachusetts.
As Trangenstein, et. al’s study depicts, some adolescents may be at a heightened risk for
choosing to use cannabis at an inappropriate age due to the ads they are exposed to. Ms. Kushnir
has named her target age demographic as millennials, as they are, “...the generation with the
largest cannabis buying habits”. As millennials are above the age of 21, we find no ethical issues
with the target age demographic. Additionally, our client has created a “simple, user friendly
website with age confirmation pop-up tab” according to Massachusetts law. This verification
tool will ensure that no one below the age of 21 will be able to purchase cannabis. Based on the
precautions our client has taken, we are confident that no inappropriate age demographic will be
intentionally targeted by her marketing plan.
Conclusion
At the outset, the primary objective of our group capstone project was to create
complementary legal and ethical frameworks that provide systematic guidelines for current and
upcoming cannabis businesses in Massachusetts’ recreational adult-use marketplace. By
publishing our group capstone project on our respective professional portfolios, we hope to reach
a broader audience beyond academia, such as current and prospective cannabis retailers. We
may also consider uploading our group capstone thesis to our professional networks, including
social media platforms like LinkedIn. In this way, we intend for our systematic criteria to be
used for practical purposes, including the development of marketing and advertising materials –
both print and digital, the promotion of events and discounts, and the development of product
labeling and packaging.
We believe there are currently too many regulatory barriers preventing entry into
Massachusetts’ recreational adult-use marketplace, especially for licensure candidates from
underserved and underrepresented backgrounds. Barriers limiting the access and entry of the
recreational adult-use marketplace privilege the business of national cannabis retailers, many of
whom are financially supported by venture capital. We recognize Massachusetts' Social Equity
Fund serves an admirable and practical purpose, but we believe more needs to be done to
deconstruct the barriers preventing access and entry to prospective entrepreneurs from
underserved communities, especially those directly impacted by the War on Drugs. We propose
the normative recommendation that the Cannabis Control Commission and Massachusetts State
Legislature consider limiting the scope of current regulations. They could do so by modeling
regulations for recreational adult-use cannabis on the regulations currently in place for Medical
Treatment Centers, or MTCs. This is not to say there are no legitimate differences between
MTCs and recreational adult-use cannabis businesses that warrant somewhat distinctive
regulations. We believe, nonetheless, that the wide scope of regulations for recreational adult-
use cannabis exceeds the regulations necessary for compliance by cannabis retailers.
We identified two primary avenues for future research: (1) the conduction of primary
research, namely, through interviews or surveys with various actors in the cannabis industry; and
(2) the expansion of systematic criteria for other actors involved in the cannabis supply chain,
such as cultivators and laboratory operators. Future research that employs primary
methodologies, such as interviews or surveys, may develop a better understanding of the local,
state, regional, and national cannabis industries. Direct consultation with the unit of analysis –
cannabis retailers, specifically in the Massachusetts recreational adult-use marketplace – could
provide more intensive and specific artifacts that contribute to the development of systematic
criteria. Researchers should also consider expanding the systematic criteria created in this
capstone thesis. They can do so through altering their unit of analysis to specifically focus on
cultivation facilities and/or laboratories. The expansion of systematic criteria to include
cultivators and laboratory operators would provide additional assistance with regulatory
compliance and continue to challenge barriers to access and entry. As the cannabis industry
continues to evolve, so too should the resources available to retailers to help navigate the
legalese of contemporary regulations.

Appendix A
Overview
The Kushnir’s House will be opening a café
cannabis dispensary in Cambridge, MA in Fall, 2023.
The cannabis at this location will be provided by a local
partner, Curaleaf, which is in Wakefield, Massachusetts
and the food will be diner style provided by
professional culinary staff. With our company’s
innovative ideas and Curaleaf’s reputable product, we’ll
create a special list of CBD and THC products only sold at our Cambridge location. Prices will
average below the Massachusetts average of $341 for an ounce. (Editorial, 2022) Keeping our
average ounce price to around $200 gives our business the advantage of selling high-quality,
unique, high-quality, locally grown products that can’t be found anywhere else. Plus we also
have a comfortable diner with warm nostalgic meals to make memories.
We are currently running our business fully online with secret passwords to our main
social accounts: Instagram, Facebook, TikTok, Pinterest, Twitter, and YouTube. Though
Instagram, Facebook, and TikTok do not allow cannabis ads, we can still advertise our products
on Twitter and Pinterest. And our exclusive CBD products can be advertised on YouTube.
Pinterest will be our main platform for advertisements because it’ll draw millennial cannabis and
CBD users. All of these social media accounts provide the same information on how all of our
products are made (excluding any ads or photos), who we are as a company, what our mission is,
and who our employees are. Cannabis/THC is not mentioned in our bio because of legal reasons
but our location, phone number, and website are. It is essential to provide this information for the
millennial audience we intend to target. The social accounts will be used to tease the opening of
our storefront. They are currently being used to create a customer, employer relationship and
loyalty. We will host a premier party for the friends and family invited to introduce the cafe and
dispensary a week before opening. And we will also hand out fliers with our location, phone
number, website, and social media handles. After the opening, we will still hand out fliers around
Cambridge to advertise different products. Underneath all of the flier information will read:
“Please consumer responsibly. There may be health risks associated with consumption of this
product. For use only by adults 21 years of age or older. Keep out of the reach of children." The
point of the cozy, homey dispensary is to create memories, positive sentiments, and friendly
interaction between the employees and consumers. Our future plans include adding a diner/cafe
by designing the store to be welcoming and immediately nostalgic for the customer.
Mission
Our mission is to provide affordable, high-quality, unique, reputable CBD and THC products
with a fun, friendly and comfortable cafe and dispensary experience to create memories for every
customer. We promise to treat every employee and customer equally with the utmost respect and
kindness no matter their identity.
Target Audience
Demographic (Age, Gender, Education, Income)- Employed millennial men and women with a
steady income. Education is N/A
Psychographic- Stressed unemployed and well-paid cannabis consumers, consumers who want to
know everything about their product, consumers who want to communicate through online and
in-person. These consumers want their cafe dispensary to be clean, organized, and economically
responsible. Consumers are also anyone with mental illness who could use CBD and/or THC for
mental and/or physical relief. (Kustin, 2020)
Ethnographic- White/caucasian, middle-upper class, preppy, hippy, granola
Geographic- Cambridge, MA, Boston, MA and/or South Shore, MA
Pain Points- A higher cost for specially grown cannabis, unfamiliar product, only one physical
storefront location.
Millennials are the generation with the largest cannabis buying habits. Emily Rodgers
predicted that the habit comes from familiarity with cannabis in culture. She wrote, “As young
adults they (millennials) watched the cannabis markets in which they lived transition from
prohibition to legal, regulated markets, and they have collectively played a leading role in the
emergence of the legal cannabis economy, both as consumers and as champions for change.”
While studying the millennial’s purchase, Rodgers found, “Almost half (49%) of Millennial
consumers spend between $50 and $200 per purchase. For context, the national average spend
per transaction across all age groups ranges from $57 (topicals) to $93 (flower), according to the
Retail Dashboard in Equio, New Frontier Data’s business intelligence platform.” But why is the
millennial purchase average so much higher? The basic answer is knowledge. Millennials are
more knowledgeable when it comes to cannabis education because of the constant media around
cannabis during their livelihood. So what is the average millennial consumer looking for from
cannabis? Emily Rodgers says, “focus is an effect most sought out by Millennials, with 32%
identifying that as a goal, compared to 29% among Gen Z, 21% of Gen X, and 14% of Boomers.
As among other age groups, potency is the biggest driver for product choices among Millennials,
followed by effect.”
Marketing Objectives
● Share the opening of our dispensary through fliers distributed across the Boston
area with small type warnings: “Please consumer responsibly. There may be
health risks associated with consumption of this product. For use only by adults
21 years of age or older. Keep out of the reach of children."
● Word-of-mouth advertising with local connections across Boston Area
● Create and establish all social media platforms at least a year before opening to
gain followers and form posting habits and brand aesthetic for clear and direct
profiles
● Design a simple, user friendly website with age confirmation pop-up tab, social
platform tabs, easy online purchase tab, customer service tab, and location tab at
least two years before opening to establish a customer base (no delivery option
available)
● Create a fun, unique, user friendly experience with social platforms, online
purchase and delivery of cannabis products
● Form a friendly, authentic staff that is excited to work with our company
specifically
● Encourage staff to form connections with each customer and make them feel
comfortable and welcome
● Treat staff with the utmost respect and kindness
● Offer staff a generous paycheck and discounts on products
● Provide a home-like cafe cannabis dispensary experience that urges the average
customer to sip their coffee and then go home with some edibles or flower
● Form a brownie points system for frequent CBD and THC customers to receive
discounts on ONLY cannabis accessories and not CBD or THC products
● Form a habit of attending local events and supporting local organizations
Marketing Strategies
● Invest in SEO for the website and invest in the website design and data to track
traffic and customer satisfaction
● Have a daily posting schedule for social platforms with employee of the week and
the company's mission
● Connect with each customer online and in-person by finding one thing in common
● Design a comfortable cottage cafe that exemplifies the natural beauty of New
England’s cannabis and its breakfast comfort foods
● Use word-of-mouth advertising by spreading news, deals, or dispensary updates
with local connections, word-of-mouth, and email/text updates
● Use journalism and connections with local corporations to fund promotional pop-
up events
Competition
The Kushnir’s House’s immediate competition when it comes to weed resourcing is Agrify,
since Curaleaf and Agrify are the top cannabis providers primarily for Massachusetts. With
Agrify and Curaleaf as the top providers, I’m not worried about the frequency of Curaleaf’s
income. My primary focus is to make Curaleaf the top provider with our specialized cannabis
products and put them on top to replace Agrify. When it comes to cafè cannabis dispensary
competition, there is a cafè dispensary opening within Faneuil Hall, which will automatically
provide profit for that cafe due to the tons of traffic the hall receives each week.
We can focus all we want on the multiple surrounding dispensaries that are opening
around Boston and Cambridge, but as Porter said, “A competitive strategy needs to “establish a
profitable and sustainable position against the forces that determine industry competition”
(Porter, 1985, p. 1). According to Porter, there are three generic strategies to achieve competitive
advantage: cost leadership, differentiation, and focus (ibid., p. 12).” (34) In order to differentiate
my own company, we will provide a store design that is unlike the rising age of Apple-store-
looking-dispensaries. The Kushnir’s House will be designed like a traditionally modern New
England cottage to give the sense of home to New Englanders and a sense of comfort and
belonging to tourists. It’ll require strong connections around Boston, but from growing up on the
South Shore, my network is strong enough to succeed.
My main priority is to provide a unique experience with exceptional prices for high
quality products that cater to each consumer. With our specialized cannabis menu, our diner, and
our devotion to customer service, consumers with a preference for comfort and community will
continue to return. Further, by designing a clear, concise, and organized website we can guide
each customer to buy more and be intrigued to visit in-person. We will invest in SEO so our
website is a prioritized link on Google. The staff, family, and friends will spread our socials to
other connections to bring more foot traffic. We will also have an email/text update sign-up sheet
at live events and will continue to share news of our company with millennial attendees.
Campaigns
Get to know us
This campaign will be focused on connecting our customers with the employees, the
product, and the employer of The Kushnir’s House. The month before our storefront opening,
our socials will introduce our employees, who we are and what our mission is, and Curaleaf, our
provider, each for a week. Doing these introductions will create a more one on one and personal
connection between the viewer and employees and employers. This will set our vision for a
friendly and comfortable cafe dispensary. Everything needs to be easily accessible and product
nutrition facts and ingredients need to be revealed and known on our website. Being transparent
about our mission, products, etc. before opening will allow our company to cater a relationship
with consumers before we connect with them in person. We want each customer to feel heard
and understood and by focusing upfront on our customer service and employee appreciation,
customers will notice our intent and values are focused on them. An example post would include
a video of an employee or employer explaining who they are, what they do, and what their
favorite Curaleaf product is.
Brownie Points
Our dispensary will have a Brownie Points system for any customer that purchases
products and decides to opt in on points. Customers will be given a number of brownie points
based on how much product they bought and they can redeem any of those points at any time for
a discount on potless baked goods at the café or accessories at the dispensary. THC and CBD
discounts will not be available through brownie points. Only non-THC and non-CBD products
are able to be discounted through brownie points. This campaign won’t be as large and
advertised as the Get to Know Us campaign, but it’ll be posted each week before opening to
explain our Brownie Points system. People who purchase goods online will already be familiar,
but as articles are released throughout the month of opening, new customers brought to our
private socials will need a tutorial. These tutorials will be posted as stories/posts on all socials
once a week.
Summer Pop-Up Events
Our Pop-Up events will be at local farmers markets and local events around Cambridge
during the summer. Before the storefront opens, the goal is to attend as many local events as
possible and nurture local connections. We will also support local organizations by matching a
10% donation to any local organization on every purchase made in-person at each pop-up event.
We will only be selling CBD products and potless baked goods during our pop-up events.
The Pop-Up will allow the staff to get familiar with other companies around us and
connect with other company staff. Creating a friendly atmosphere in and around the cafe
dispensary is crucial when growing a business. Showing support for the organizations around the
dispensary will show that we care and want to be active participants in the surrounding culture.
Naturally supporting organizations and having a strong stance in creating a community will bring
publicity and attention to our own company in a positive way and make a great impression.
Social Media Plan Après Opening
Instagram & Facebook: Daily instagram shareable posts of memes about cannabis with weekly
upcoming event story posts or story posts announcing our hours and theme for the week.
Twitter: A daily tweet with the same subject as the meme post about cannabis and the weekly
sale announced every Wednesday for Weed Wednesday.
YouTube: Employees of The Kushnir’s House will post YouTube Shorts weekly with the hottest
or newest CBD product and info about that product.
TikTok: Employees of The Kushnir’s House will post TikToks weekly to introduce themselves.
Pinterest: A group of pins will be posted weekly to provide some information on the hottest
weekly product.
Review
Since the pandemic started in March 2020, there has been a rise in cannabis sales and a
slump in socialization. In hopes to decrease the stress prevalent in our everyday lives, at The
Kushnir’s House, we will sell comforting breakfast meals and baked goods along with high
quality THC and CBD to guarantee a decrease in your daily stress cycle. The combination will
allow customers to eat and drink and peruse our cannabis menu as they do so. Our main mission
is to create a sense of comfort and relaxation within the cafe dispensary while also establishing
great memories and connections with the customers. “A brand is what your customers and
partners think of when they think of your company. It’s also the way your team thinks about the
company they work for. Your brand supports your reputation when working with partners,
influencers, vendors, contractors and most importantly, customers” (Alpina, 2022).
The difficulty of advertising and marketing cannabis products means making sure that all
advertisements do not: “jeopardize public health, welfare, or safety, promote the use of
marijuana by individuals under 21 years of age” (Stuart, 2018) along with a lengthy warning
label to emphasize the prevention of underage consumption. “Research has demonstrated that the
majority of youth (90%) report exposure to some form of cannabis marketing. A previous study
of cannabis marketing found a higher frequency of passive exposure to cannabis ads, or exposure
by those not actively seeking cannabis ads, (66%) compared to actively seeking ads (31%).
Prevention strategies for cannabis promotions on social media suggested by youth included more
restrictions around social media content for youth under the age of 21.” (Binger, 2021) By using
private social accounts for only people 21 and up and restricting purchases online to only adults
with valid IDs, we can avoid underage purchases. Also by using word of mouth advertising and
deliberately targeting our ads for millennial devices, we can avoid any products being desired by
minors.
Before the opening of the dispensary, there is lots to be done to spread the word about the
opening and our products, employees and employers. They all need to be introduced to our
surrounding community, so our company will attend and volunteer and support as many local
events as possible. We will use these events to create friends, partners, connections, and allies.
We will get to know the surrounding companies and communities and during the live events, we
can spread the word about our company. Caroline Merritt spoke on Lisa Buffo’s podcast on
marketing and provided the following advice:
I think it’s an opportunity for brands to take to actually build community in the real world
and to create sort of opportunities to host events… For instance, in Michigan, we worked
with a cannabis brand and we partnered with yoga studios. And so we actually use
outside partners and, you know, entities that really fit within certain products to help kind
of further build that community and to also create association. So it wasn’t just kind of
through the lens of cannabis, but it was through the lens of wellness (Merritt, 2022)
Cannabis has so many laws and policies surrounding the publication and advertising of it all, but
if it’s paired up with a shared hobby like eating, it can soar by just word of mouth and strong
connections with the community. As Catherine Merritt said, “there’s tremendous power in
harnessing word of mouth.”
And guess what else has tremendous power, parallel to word of mouth? The press. And
even though the press is often shamed and seen as old fashioned, “print advertising is still one of
the most trusted types of advertising in the U.S. Print's trustworthiness is a big asset for cannabis
and CBD brands, as it can normalize and help reduce some of the stigma associated with the
industry.” And so from there, we intend to use the tangibility of print to spread the news bout our
dispensary opening and our new menu of products. It’s true that: “readers tend to be more
focused on what they're looking at and, thus, are likely to fully digest your advertising message.
You can target effectively by placing ads in the publications your audience reads, getting
creative with eye-catching visuals, and playing around with a variety of positions and formats.”
(marketing.sfgate)
Predicted Outcomes
● 50% increase in online cannabis sales during the first month of opening
● 100% increase in social platform traffic
● 100% increase in website traffic
● 100% increase for in-person cannabis sales

Appendix B
Overview
The Kushnir’s House will be opening a café cannabis
dispensary in Cambridge, MA in Fall, 2023. The cannabis at this
location will be provided by a local partner, Curaleaf, which is in
Wakefield, Massachusetts and the food will be diner style
provided by professional culinary staff. With our company’s
innovative ideas and Curaleaf’s reputable product, we’ll create a
special list of CBD and THC products only sold at our Cambridge location. Prices will average
below the Massachusetts average of $341 for an ounce. (Editorial, 2022) Keeping our average
ounce price to around $200 gives our business the advantage of selling affordable, unique, high
quality, locally grown products that can’t be found anywhere else. Plus we also have a
comfortable diner with warm nostalgic meals to make memories.
We are currently running our business fully online with secret passwords to our main
social accounts: Instagram, Facebook, TikTok, Pinterest, Twitter, and YouTube. Though
Instagram, Facebook, and TikTok do not allow cannabis ads, we can still advertise our products
on Twitter and Pinterest. And our exclusive CBD products can be advertised on YouTube.
Pinterest will be our main platform for advertisements because it’ll draw millennial cannabis and
CBD users. All of these social media accounts provide the same information on how all of our
products are made (excluding any ads or photos), who we are as a company, what our mission is
and who our employees are. Cannabis/THC is not mentioned in our bio because of legal reasons
but our location, phone number and website are. It is essential to provide this information for the
millennial audience we intend to target. The social accounts will be used to tease the opening of
our store front. They are currently being used to create a customer, employer relationship and
loyalty. We will host a premier party for the friends and family invited to introduce the cafe and
dispensary a week before opening. And we will also hand out fliers with our location, phone
number, website, and social media handles. After the opening, we will still hand out fliers around
Cambridge to advertise different products. Underneath all of the flier information will read:
“Please consumer responsibly. There may be health risks associated with consumption of this
product. For use only by adults 21 years of age or older. Keep out of the reach of children." The
point of the cozy, homey dispensary is to create memories, positive sentiments, and friendly
interactions between employees and consumers. Our future plans include adding a diner/cafe by
designing the store to be welcoming and immediately nostalgic for the customer.
Mission
Our mission is to provide affordable, high-quality, unique, reputable CBD and THC products
with a fun, friendly and comfortable cafe and dispensary experience to create memories for every
customer. We promise to treat every employee and customer equally with the utmost respect and
kindness no matter their identity.
Target Audience
Demographic (Age, Gender, Education, Income)- Employed millennial men and women with a
steady income. Education is N/A
Psychographic- Stressed unemployed and well-paid cannabis consumers, consumers who want to
know everything about their product, consumers who want to communicate through online and
in person. These consumers want their cafe dispensary to be clean, organized, and economically
responsible. Consumers are also anyone with mental illness who could use CBD and/or THC for
mental and/or physical relief. (Kustin, 2020)
Ethnographic- White/caucasian, middle-upper class, preppy, hippy, granola
Geographic- Cambridge, MA, Boston, MA, and/or South Shore, MA
Pain Points- A higher cost for specially grown cannabis, unfamiliar product, and only one
physical storefront location.
Millennials are the generation with the largest cannabis buying habits. Emily Rodgers
predicted that the habit comes from familiarity with cannabis in culture. She wrote, “As young
adults they (millennials) watched the cannabis markets in which they lived transition from
prohibition to legal, regulated markets, and they have collectively played a leading role in the
emergence of the legal cannabis economy, both as consumers and as champions for change.”
When studying the millennial’s purchase, Rodgers found, “Almost half (49%) of Millennial
consumers spend between $50 and $200 per purchase. For context, the national average spend
per transaction across all age groups ranges from $57 (topicals) to $93 (flower), according to the
Retail Dashboard in Equio, New Frontier Data’s business intelligence platform.” But why is the
millennial purchase average so much higher? The basic answer is knowledge. Millennials are
more knowledgeable when it comes to cannabis education because of the constant media around
cannabis during their livelihood. So what is the average millennial consumer looking for from
cannabis? Emily Rodgers says, “focus is an effect most sought out by Millennials, with 32%
identifying that as a goal, compared to 29% among Gen Z, 21% of Gen X, and 14% of Boomers.
As among other age groups, potency is the biggest driver for product choices among Millennials,
followed by effect.”
Marketing Objectives
● Share the opening of our dispensary through fliers distributed across the Boston
area with small type warnings: “Please consumer responsibly. There may be
health risks associated with consumption of this product. For use only by adults
21 years of age or older. Keep out of the reach of children."
● Word-of-mouth advertising with local connections across Boston Area
● Create and establish all social media platforms at least a year before opening to
gain followers and form posting habits and brand aesthetic for clear and direct
profiles
● Design a simple, user friendly website with an age confirmation pop-up tab, social
platform tabs, an easy online purchase tab, a customer service tab, and a location
tab at least two years before opening to establish a customer base (no delivery
option available)
● Create a fun, unique, user-friendly experience with social platforms, online
purchases, and delivery of cannabis products
● Form a friendly, authentic staff that is excited to work with our company
specifically
● Encourage staff to form connections with each customer and make them feel
comfortable and welcome
● Treat staff with the utmost respect and kindness
● Offer staff a generous paycheck and discounts on products

● Provide a home-like cafe cannabis dispensary experience that urges the average
customer to sip their coffee and then go home with some edibles or flower
● Form a brownie points system for frequent CBD and THC customers to receive
discounts on ONLY cannabis accessories and not CBD or THC products
● Form a habit of attending local events and supporting local organizations
Marketing Strategies
● Invest in SEO for the website and invest in the website design and data to track
traffic and customer satisfaction
● Have a daily posting schedule for social platforms with an employee of the week
and the company's mission
● Connect with each customer online and in person by finding one thing in common
● Design a comfortable cottage cafe that exemplifies the natural beauty of New
England’s cannabis and its breakfast comfort foods
● Use word-of-mouth advertising by spreading news, deals, or dispensary updates
with local connections, word-of-mouth, and email/text updates
● Use journalism and connections with local corporations to fund promotional pop-
up events
Competition
The Kushnir’s House’s immediate competition when it comes to weed resourcing is
Agrify, since Curaleaf and Agrify are the top cannabis providers primarily for Massachusetts.
With Agrify and Curaleaf as the top providers, I’m not worried about the frequency of Curaleaf’s
income. My primary focus is to make Curaleaf the top provider of our specialized cannabis
products and put them on top to replace Agrify. When it comes to cafè cannabis dispensary
competition, there is a cafè dispensary opening within Faneuil Hall, which will automatically
provide profit for that cafe due to the tons of traffic the hall receives each week.
We can focus all we want on the multiple surrounding dispensaries that are opening
around Boston and Cambridge, but as Porter said, “A competitive strategy needs to “establish a
profitable and sustainable position against the forces that determine industry competition”
(Porter, 1985, p. 1). According to Porter, there are three generic strategies to achieve competitive
advantage: cost leadership, differentiation, and focus (ibid., p. 12).” (34) In order to differentiate
my own company, we will provide a store design that is unlike the rising age of Apple-store-
looking-dispensaries. The Kushnir’s House will be designed like a traditionally modern New
England cottage to give a sense of home to New Englanders and a sense of comfort and
belonging to tourists. It’ll require strong connections around Boston, but from growing up on the
South Shore, my network is strong enough to succeed.
My main priority is to provide a unique experience with exceptional prices for high-
quality products that cater to each consumer. With our specialized cannabis menu, our diner, and
our devotion to customer service, consumers with a preference for comfort and community will
continue to return. Further, by designing a clear, concise, and organized website we can guide
each customer to buy more and be intrigued to visit in person. We will invest in SEO so our
website is a prioritized link on Google. The staff, family, and friends will spread our socials to
other connections to bring more foot traffic. We will also have an email/text update sign-up sheet
at live events and will continue to share news about our company with millennial attendees.
Campaigns
Get to know us
This campaign will be focused on connecting our customers with the employees, the
product, and the employer of The Kushnir’s House. The month before our storefront opening,
our socials will introduce our employees, who we are and what our mission is, and Curaleaf, our
provider, each for a week. Doing these introductions will create a more one on one and personal
connection between the viewer and employees and employers. This will set our vision for a
friendly and comfortable cafe dispensary. Everything needs to be easily accessible and product
nutrition facts and ingredients need to be revealed and known on our website. Being transparent
about our mission, products, etc. before opening will allow our company to cater a relationship
with consumers before we connect with them in person. We want each customer to feel heard
and understood and by focusing upfront on our customer service and employee appreciation,
customers will notice our intent and values are focused on them. An example post would include
a video of an employee or employer explaining who they are, what they do, and what their
favorite Curaleaf product is.
Brownie Points
Our dispensary will have a Brownie Points system for any customer that purchases
products and decides to opt-in on points. Customers will be given a number of brownie points
based on how much product they bought and they can redeem any of those points at any time for
a discount on potless baked goods at the café or accessories at the dispensary. THC and CBD
discounts will not be available through brownie points. Only non-THC and non-CBD products
are able to be discounted through brownie points. This campaign won’t be as large and
advertised as the Get to Know Us campaign, but it’ll be posted each week before opening to
explain our Brownie Points system. People who purchase goods online will already be familiar,
but as articles are released throughout the month of opening, new customers brought to our
private socials will need a tutorial. These tutorials will be posted as stories/posts on all socials
once a week.
Summer Pop-Up Events
Our Pop-Up events will be at local farmers’ markets and local events around Cambridge
during the summer. Before the storefront opens, the goal is to attend as many local events as
possible and nurture local connections. We will also support local organizations by matching a
10% donation to any local organization on every purchase made in person at each pop-up event.
We will only be selling CBD products and potless baked goods during our pop-up events.
The Pop-Up will allow the staff to get familiar with other companies around us and
connect with other company staff. Creating a friendly atmosphere in and around the cafe
dispensary is crucial when growing a business. Showing support for the organizations around the
dispensary will show that we care and want to be active participants in the surrounding culture.
Naturally supporting organizations and having a strong stance in creating a community will bring
publicity and attention to our own company in a positive way and make a great impression.
Social Media Plan Après Opening
Instagram & Facebook: Daily Instagram shareable posts of memes about cannabis with weekly
upcoming event story posts or story posts announcing our hours and theme for the week.
Twitter: A daily tweet with the same subject as the meme post about cannabis and the weekly
sale announced every Wednesday for Weed Wednesday.
YouTube: Employees of The Kushnir’s House will post YouTube Shorts weekly with the hottest
or newest CBD product and info about that product.
TikTok: Employees of The Kushnir’s House will post TikToks weekly to introduce themselves.
Pinterest: A group of pins will be posted weekly to provide some information on the hottest
weekly product.
Review
Since the pandemic started in March 2020, there has been a rise in cannabis sales and a
slump in socialization. In hopes to decrease the stress prevalent in our everyday lives, at The
Kushnir’s House, we will sell comforting breakfast meals and baked goods along with high-
quality THC and CBD to guarantee a decrease in your daily stress cycle. The combination will
allow customers to eat and drink and peruse our cannabis menu as they do so. Our main mission
is to create a sense of comfort and relaxation within the cafe dispensary while also establishing
great memories and connections with the customers. “A brand is what your customers and
partners think of when they think of your company. It’s also the way your team thinks about the
company they work for. Your brand supports your reputation when working with partners,
influencers, vendors, contractors and most importantly, customers” (Alpina, 2022).
The difficulty of advertising and marketing cannabis products means making sure that all
advertisements do not: “jeopardize public health, welfare, or safety, promote the use of
marijuana by individuals under 21 years of age” (Stuart, 2018) along with a lengthy warning
label to emphasize the prevention of underage consumption. “Research has demonstrated that the
majority of youth (90%) report exposure to some form of cannabis marketing. A previous study
of cannabis marketing found a higher frequency of passive exposure to cannabis ads, or exposure
by those not actively seeking cannabis ads, (66%) compared to actively seeking ads (31%).
Prevention strategies for cannabis promotions on social media suggested by youth included more
restrictions around social media content for youth under the age of 21.” (Binger, 2021) By using
private social accounts for only people 21 and up and restricting purchases online to only adults
with valid IDs, we can avoid underage purchases. Also by using word-of-mouth advertising and
deliberately targeting our ads for millennial devices, we can avoid any products being desired by
minors.
Before the opening of the dispensary, there are lots to be done to spread the word about
the opening and our products, employees, and employers. They all need to be introduced to our
surrounding community, so our company will attend and volunteer and support as many local
events as possible. We will use these events to create friends, partners, connections, and allies.
We will get to know the surrounding companies and communities and during the live events, we
can spread the word about our company. Caroline Merritt spoke on Lisa Buffo’s podcast on
marketing and provided the following advice:
I think it’s an opportunity for brands to actually build community in the real world and to
create sort of opportunities to host events… For instance, in Michigan, we worked with a
cannabis brand and we partnered with yoga studios. And so we actually use outside
partners and, you know, entities that really fit within certain products to help kind of
further build that community and to also create association. So it wasn’t just kind of
through the lens of cannabis, but it was through the lens of wellness (Merritt, 2022)
Cannabis has so many laws and policies surrounding the publication and advertising of it all, but
if it’s paired up with a shared hobby like eating, it can soar by just word of mouth and strong
connections with the community. As Catherine Merritt said, “there’s tremendous power in
harnessing word of mouth.”
And guess what else has tremendous power, parallel to word of mouth? The press. And
even though the press is often shamed and seen as old fashioned, “print advertising is still one of
the most trusted types of advertising in the U.S. Print's trustworthiness is a big asset for cannabis
and CBD brands, as it can normalize and help reduce some of the stigma associated with the
industry.” And so from there, we intend to use the tangibility of print to spread the news bout our
dispensary opening and our new menu of products. It’s true that: “readers tend to be more
focused on what they're looking at and, thus, are likely to fully digest your advertising message.
You can target effectively by placing ads in the publications your audience reads, getting
creative with eye-catching visuals, and playing around with a variety of positions and formats.”
(marketing.sfgate).
Predicted Outcomes
● 50% increase in online cannabis sales during the first month of opening
● 100% increase in social platform traffic
● 100% increase in website traffic
● 100% increase for in-person cannabis sales

References
935 CMR 500.00: Adult use of marijuana | Mass.gov. (n.d.). Www.mass.gov; Cannabis Control
Commission. https://www.mass.gov/regulations/935-CMR-50000-adult-use-of-marijuana
Advertising guidelines. (n.d.). Pinterest Policy.
https://policy.pinterest.com/en/advertising-guidelines
Alpina, Ella. CANNABIS MARKETING PLAN: ULTIMATE GUIDE FOR COMMERCIAL
GROWERS, (2022). https://trym.io/cannabis-marketing/.
Austin, N. (2018, July). Uncertainty surrounds new ad rules in Massachusetts: Rescission of
Cole Memo complicates the subject. Marijuana Venture, 5(7), 168.
https://link.gale.com/apps/doc/A628407919/ITOF?u=mlin_c_clarkunv&sid=bookmark-
ITOF&xid=5c4f7c11
Baye, Lawrence, Bednarz, Mark. KEY RISKS AND CHALLENGES FACING CANNABIS
BUSINESSES SERVING THE GROWING U.S. MARKET, (2021).
https://www.pkfod.com/insights/key-risks-and-challenges-facing-cannabis-businesses-
serving-the-growing-u-s-market/
Binger, Kole, Jenkins, Marina C., Kelly, Lauren, Moreno, Megan A. Cyber-Ethnography of
Cannabis Marketing on Social Media, (2021).
https://substanceabusepolicy.biomedcentral.com/articles/10.1186/s13011-021-00359-w
Buffo, Lisa, Merritt, Catherine. Growth Marketing Strategies for Cannabis Entrepreneurs and
Marketers, (2022).
https://thecannabismarketingassociation.com/podcast/episode-30-growth-marketing-
strategies-for-cannabis-entrepreneurs-and-marketers/
DeMarco, C. (2022). Hear Here! The Case for Podcasting in Research. Journal of Research
Administration, 53(1).
Drugs and drug paraphernalia. (n.d.). Business.twitter.com.
https://business.twitter.com/en/help/ads-policies/ads-content-policies/drugs-and-drug-
paraphernalia.html
Eckfeldt, B. (2020, July). Lisa Buffo, CEO, Cannabis Marketing Association. Retrieved April 27,
2023, from https://open.spotify.com/episode/58QUHOdJdkPlYjQyqWDddh
Eden Kinkaid, Kelsey Emard & Nari Senanayake. (2019). The Podcast-as-Method?: Critical
Reflections on Using Podcasts to Produce Geographic Knowledge. Geographical Review,
110:1-2, 78-91, DOI: 10.1111/gere.12354
Editorial Staff. The Average Cost of Marijuana by State, (2022).
https://oxfordtreatment.com/substance-abuse/marijuana/average-cost-of-marijuana/
Equity Programs. (n.d.). Cannabis Control Commission Massachusetts. Retrieved April 27,
2023, from https://masscannabiscontrol.com/equity/
FDA Regulation of Cannabis and Cannabis-Derived Products, Including Cannabidiol (CBD),
(2023).
https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-
cannabis-derived-products-including-cannabidiol-cbd
Fertig, N. (2020, March 6). Local rule is undermining Massachusetts’ attempt to create equity in
The cannabis industry. POLITICO. https://www.politico.com/news/2020/03/06/local-
rule-is-undermining-massachusetts-attempt-to-create-equity-in-the-cannabis-industry-
122655
First Self-Regulatory Organization for the U.S. Cannabis Industry, National Association of
Cannabis Businesses, Launches Voluntary National Standards for Advertising. (2018,
November 6). PR Newswire.
https://link.gale.com/apps/doc/A561239983/ITBC?u=mlin_c_clarkunv&sid=bookmark-
ITBC&xid=f984ca7f
Forzley, Samer. Cannabis and Web Marketing Strategies- A Study of Colorado Cannabis
Vendors, (2021). https://www.proquest.com/docview/2585200311?accountid=10152
Hannah, A. L., Mallinson, D. J., & Azevedo, L. (2022). Maximizing social equity as a pillar of
public administration: An examination of cannabis dispensary licensing in Pennsylvania.
Public Administration Review. https://doi.org/10.1111/puar.13521
Heaton, J. (2008). Secondary Analysis of Qualitative Data: An Overview. Historical Social
Research / Historische Sozialforschung, 33(3), (125), 33–45.
http://www.jstor.org/stable/20762299
Hill, J. K., M. Paula Fitzgerald, Joshua Dorsey, Ronald Paul. (2019, August 6). Navigating the
Uncharted Territory of Cannabis Marketing. American Marketing Association.
https://www.ama.org/2019/08/06/navigating-the-uncharted-territory-of-cannabis-
marketing/
Hoffman, S., Doyle, K., Flanagan, J., Mcbride, B., Title, S., Collins, S., Doonan, S., Analyst, R.,
Hamilton, J., & Johnson, J. (2019). A Baseline Review and Assessment of Cannabis Use
and Youth: Literature Review and Preliminary Data in Massachusetts. Cannabis Control
Commission. https://mass-cannabis-control.com/wp-content/uploads/2019/09/A-
Baseline-Review-and-Assessment-of-Cannabis-Use-and-Youth-Literature-Review-and-
Preliminary-Data-in-MA_Sept19.pdf
How to Win at Cannabis Marketing: Everything You Need to Know.
https://marketing.sfgate.com/resources/cannabis-marketing-guide
Ilan, Yaron. Digital Medical Cannabis as Market Differentiator: Second-Generation Artificial
Intelligence Systems to Improve Response, (2022).
https://www.frontiersin.org/articles/10.3389/fmed.2021.788777/full
Instagram’s Policy on the Sale of Marijuana. (n.d.). Facebook.com.
https://www.facebook.com/help/instagram/789164081427334
Kees, J., Fitzgerald, P., Dorsey, J. D., & Hill, R. P. (2019). Evidence-Based Cannabis Policy: A
Framework to Guide Marketing and Public Policy Research. Journal of Public Policy &
Marketing, 39(1), 074391561984842. https://doi.org/10.1177/0743915619848422
Kiley, R., & Boedges, J. (2022, July). 055: Solving the Licensing and Regulatory Challenges for
Canna-Businesses with Dr. Sherry Boodram. Retrieved April 27, 2023, from
https://open.spotify.com/episode/0RAKIh5KojvFFDrqjT2GKW
Kustin, Dave. Demographics and Buying Habits of the Cannabis Industry, (2020).
https://www.linkedin.com/pulse/demographics-buying-habits-cannabis-industry-dave-
kustin/
Larkin, Jr., P. (2021). ARTICLE: Cannabis Capitalism, 69 Buffalo L. Rev. 215. Buffalo Law
Review.
Lasi, Arshad. The Next Wave of Cannabis Marketing and Advertising, (2022).
https://www.rollingstone.com/culture-council/articles/next-wave-of-cannabis-marketing-
and-advertising-1234631114/
Mandell, J. (2019, October). Cannabis advertising: What businesses need to know: There is no
one-size-fits-all standard for marketing rules. Marijuana Venture, 6(10), 156.
https://link.gale.com/apps/doc/A628675794/ITOF?u=mlin_c_clarkunv&sid=bookmark-
ITOF&xid=7ca8099d
Mann, M., Ginder, W., & Byun, S.-E. (2021). Highs and Lows of Cannabis Decriminalization:
Twitter Analysis and Ethical and Regulatory Implications for Retailing and Marketing.
Journal of Global Marketing, 1–19. https://doi.org/10.1080/08911762.2021.1958971
Marketing & Cannabis: A Review of some of the Most Effective Tactics in the Industry.
https://www.contentbacon.com/blog/effective-cannabis-marketing-tactics
McCarthy, Justin. What Percentage of Americans Smoke Marijuana? (2022).
https://news.gallup.com/poll/284135/percentage-americans-smoke-marijuana.aspx
Moreno, M. A., Jenkins, M., Binger, K., Kelly, L., Trangenstein, P. J., Whitehill, J. M., &
Jernigan, D. H. (2022). A Content Analysis of Cannabis Company Adherence to
Marketing Requirements in Four States. Journal of Studies on Alcohol and Drugs, 83(1),
27–36. https://doi.org/10.15288/jsad.2022.83.27
National Association of Cannabis Businesses. (2018, November 5). Advertising Standards for
Cannabis & Hemp Businesses. https://nacb.com/wp-content/uploads/2022/04/nacb-02-
Advertising-Standards-for-Cannabis-Hemp-Businesses.pdf
National Association of Cannabis Businesses. (2018, May 17). Packaging & Labeling
Standards. https://nacb.com/wp-content/uploads/2022/04/nacb-01-Cannabis-Safety-
Packaging-and-Labeling.pdf
Noël, C., Armiento, C., Péfoyo, A. K., Klein, R., Bédard, M., & Scharf, D. (2021). Adolescent
exposure to cannabis marketing following recreational cannabis legalization in Canada: A
pilot study using ecological momentary assessment. Addictive Behaviors Reports, 14,
100383. https://doi.org/10.1016/j.abrep.2021.100383
Pharm House & Sugarleaf Business Plan, (2017).
https://www.ci.seaside.ca.us/DocumentCenter/View/4748/PHARM-HOUSE-AND-
SUGARLEAF-APPLICATION-FINAL-REDACTED-S
Rodgers, Emily. 8 Cannabis Marketing Strategies for 2023, (2023).
https://www.driveresearch.com/market-research-company-blog/cannabis-marketing-
strategies/
Sale of illegal or regulated goods or services policies - YouTube Help. (n.d.).
Support.google.com. https://support.google.com/youtube/answer/9229611?hl=en
Sebastian, Kavya. Marketing Your Cannabis Business in Massachusetts, (2023).
https://cannabiscreative.com/blog/marketing-your-cannabis-business-in-massachusetts/
Soudková, Lucie. STRATEGIC PLAN FOR APHRIA INC, (2020).
https://www.aauni.edu/wp-content/uploads/2021/06/sba-thesis-lucie-soudkova.pdf
Stuart, Ian, Thorvaldsen, Kara. Stakes are High for Marijuana Businesses Navigating New
Advertising and Marketing Regulations in Massachusetts, (2018).
https://www.wilsonelser.com/writable/files/Insights/navigatingcannabismarketinginma-
180523.pdf
Sunnyside Rewards and Loyalty | Sunnyside Cannabis Dispensaries. (n.d.).
Www.sunnyside.shop. Retrieved April 27, 2023, from
https://www.sunnyside.shop/page/sunnyside-rewards
The Regulation and Taxation of Marijuana Act, (2016).
https://malegislature.gov/Laws/SessionLaws/Acts/2016/Chapter334
TikTok. (n.d.). Www.tiktok.com. https://www.tiktok.com/community-guidelines?lang=en#32
Torabi, S. (2022, February). 088 New England Cannabis Brand That Sells Good Buds To Great
Neighbors with Alex Mazin of Bud’s Goods. Retrieved April 27, 2023, from
https://open.spotify.com/episode/6nyH9oWBRzdNSAVK6oDnLQ
Trangenstein, P. J., Gora Combs, K., Whitehill, J. M., Jenkins, M. C., Jernigan, D. H., &
Moreno, M. A. (2022). Typology of Adolescents Exposed to Non-medical Cannabis
Marketing and Associations with Consumption Patterns. Prevention Science, 23(7),
1276–1286. https://doi.org/10.1007/s11121-022-01378-0
Unger, J. B. (2022). Regulation of Cannabis Retailers: Facilitating Responsible Adult Use and
Promoting Health Equity While Preventing Access to Minors. American Journal of
Public Health, 112(11), 1532–1534. https://doi.org/10.2105/ajph.2022.307102
Wells, B. (2022, June 8). One on one with the professor of marketing. Marijuana Venture.
https://www.marijuanaventure.com/professor-of-marketing/

Mpa 3999 Capstone Thesis

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Mpa 3999 Capstone Thesis

Uploaded by

Copyright:

Available Formats

Kushnir, Small, Riggio 1

High Stakes: A Guide to Legal and Ethical Cannabis Marketing

Clark University Capstone Practicum

Shea Kushnir, Mo Small, Anabel Riggio

competitive to keep their businesses afloat. However, Massachusetts legislation surrounding

educational information for those branching out into the industry.

Adult use vs. MTCs:

While our research will focus on adult-use recreational cannabis dispensaries, it is

healthcare provider. Conversely, adult-use dispensaries, known by the CCC as marijuana

to strict regulations and policies.

Marketing Plan Evaluation

Existing Legal Research

legal specialty of cannabis law.

The seminal regulation that monitors adult-use cannabis in Massachusetts – and is

enforced by the Cannabis Control Commission – is 935 CMR (Code of Massachusetts

subsection we primarily consulted was Section 4, “Advertising Requirements.” Section 4

of our regulatory framework, which is supplemented by the Regulation and Taxation of

means the maximum percentage of minor exposure permitted is 15 percent (Commonwealth of

popularity of consumer-targeted cannabis advertisements populating in legalized adult-use states

distribution, sale, and/or consumption a felony, whether that advertising is communicated in

The Drug Enforcement Agency, the Department of Justice’s jurisdictional enforcement

CCC, 2019; Mandell, 2019; Larkin, 2021).

to bolster the prospects of cannabis retailers from historically disadvantaged backgrounds

rectify the disproportionate impact wrought by cannabis prohibition on communities of color by

and economic empowerment applicants entering the industry (Commonwealth of Massachusetts,

Existing Ethical Research

While ethical considerations are certainly present in cannabis advertisement legislation,

client’s marketing plan.

our client’s use of Twitter in her marketing plan.

Celebrity endorsements are a difficult form of advertisement to navigate in Massachusetts, as it

minors with inappropriate content.

development of Cannabis Use Disorder, a psychological dependence on cannabis. A major goal

avoiding algorithmically or subliminally targeting minors with our client’s advertisements.

“marihuana” in an attempt to exoticize cannabis so that xenophobic white Americans would

Today, in a post-legalization Massachusetts, social equity programs have been created to

recommendation by Jennifer B. Unger, Ph.D. asks, how can we prevent an over-concentration of

tobacco? While cannabis is widely considered to be minimally problematic to one’s health,

disproportionately harmed by Nixon and Anslinger’s war on drugs. Therefore, we are

client’s marketing plan.

Another policy recommendation explores how we may limit marketing to higher-risk

pregnant or breastfeeding” (CCC, 2023). While there is no conclusive evidence on whether or

cannabis marketing in interstate and intrastate marketplaces, specifically the Massachusetts

Secondary Data Analysis

interviews, responses to open-ended questions in questionnaires, field notes, and research

The use of podcasts in various methodologies, including qualitative ones such as

the methodological benefits of podcasts in their article, “The Podcast-As-Method?: Critical

Reflections on Using Podcasts to Produce Geographical Knowledge.” While their defense

become increasingly commonplace in higher education as tools for knowledge production,

episodes from reputable sources in the field of cannabis marketing.

Our selected podcasts constitute several convergent purposes, namely, digesting

advertising, brick-and-mortar dispensary marketing, digital advertising, print advertising, and

marketing to specific products’ intended methods of consumption; (2) marketing strategies,

especially when crafted alongside ethical considerations.

identified within the three podcast episodes.

responsibility, social equity cannabis, and transparent advertising. Corporate social

paramount. Transparent advertising moves beyond regulatory compliance, challenging cannabis

exposure to cannabis advertisements. We specifically adopt two voluntary regulations published

by the National Association of Cannabis Businesses (NACB), including the “Advertising

Heaton (2008) describes three primary methodological limitations of secondary data

necessarily data verifiable through quantitative methods.

entirely escapable. We considered a methodology employing primary research, specifically

semi-structured interviews with two industry professionals, before transitioning to a qualitative

First Draft Marketing Plan (Appendix A)