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US FTC Targets Fake Online Reviews, Expanded Liability, With Proposed Endorsement Guides Update

Executive Summary

Proposed changes to the FTC’s “Guides Concerning the Use of Endorsements and Testimonials in Advertising” depict an agency looking to crack down on fake reviews and suppression of negative ones, tighten its definition of “clear and conspicuous” disclosures, and clarify that advertisers, endorsers, intermediaries and platforms all can be held liable for their endorsement roles.

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