Showing posts with label Federal Trade Commission. Show all posts
Showing posts with label Federal Trade Commission. Show all posts

February 24, 2025

Request for Comments to Assist in Reviewing and Identifying Unfair Trade Practices and Initiating All Necessary Actions to Investigate Harm From Non-Reciprocal Trade Arrangements

This document and comments section was posted on 2/24/25. It is focused on seeking reason to impose tariffs not really arguments as to why tariff's should not be imposed on a certain segment of consumer goods but I suppose this is a chance to voice your opinion in writing directly with the USTR about tariff's related to specific countries like China. One commenter from the bicycle business brought up de minimis reform which would seem to be an appropriate comment for this request. Specifically the request seeks: "...comments from the public, on a country-by-country basis, to assist the U.S. Trade Representative in reviewing and identifying any unfair trade practices by other countries, and in initiating all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements. This information will assist the U.S. Trade Representative in recommending appropriate actions to remedy such practices and reporting to the President proposed remedies in pursuit of reciprocal trade relations. For additional information, please see USTR’s Federal Register notice."


Law Offices of Steven W. Hansen | www.swhlaw.com | 562 866 6228 © Copyright 1996-2020 Conditions of Use

August 14, 2024

Federal Trade Commission Announces Final Rule Regarding Fake Reviews and Testimonials

There is a lot in this new rule (adopted Aug 14 2024), and as always the devil is in the details. This is the main FTC announcement here and the full 163 page justification, selected outside comments and the actual rule (starting at page 153) here which we have yet to digest. The government is not paid by the word so we are not sure why this is so wordy. I guess anticipating fights with crafty private sector defense attorneys! As always the devil is in the details and the specific wording and interpretation of the rule by the FTC is key. Once of the issues of interest to us is bike and recreational product companies love to use "paid" athletes to post reviews about product (along with endorsements of the product on their private social media accounts like Instagram and the like). I am assuming that those people would be considered "agents" under the rule. (unfortunately the rule itself does not define "agent") Given that understanding this is the FTC's bullet point (one of many):

Insider Reviews and Consumer Testimonials: The final rule prohibits certain reviews and testimonials written by company insiders that fail to clearly and conspicuously disclose the giver’s material connection to the business. It prohibits such reviews and testimonials given by officers or managers. It also prohibits a business from disseminating such a testimonial that the business should have known was by an officer, manager, employee, or agent. Finally, it imposes requirements when officers or managers solicit consumer reviews from their own immediate relatives or from employees or agents – or when they tell employees or agents to solicit reviews from relatives and such solicitations result in reviews by immediate relatives of the employees or agents.

There is sure to be a thorough examination of product reviews and reviewers going forward as well as the process involved in making sure this rule is followed and we all know who is looking at this carefully...Amazon and other big retailers.

Hopefully in the coming weeks we will be adding more to this post above.

Law Offices of Steven W. Hansen | www.swhlaw.com | 562 866 6228 © Copyright 1996-2020 Conditions of Use