This article first appeared in Cyberlaw Currents, a Frankfurt Kurnit legal blog.
The Federal Trade Commission ("FTC") has announced that it is updating "Dot Com Disclosures: Information about Online Advertising," its guidance document that advises businesses on how federal advertising law applies to advertising and sales on the Internet. The current "Dot Com Disclosures" guidance is available here. The FTC announced [http://www.ftc.gov/opa/2011/05/dotcom.shtm] that it is seeking public comment about how its guidance should be modified to reflect the dramatic changes in the online world since the "Dot Com Disclosures" guidance was first published in 2000. Comments are due by July 11, 2011.
In announcing the proposed revisions, the FTC noted that when the guidance was first released, "mobile marketing was just a vision, there was not an 'App" economy, the use of 'pop-up blockers' was not widespread, and online social networking was nowhere as sophisticated or extensive as it is today." The FTC is seeking comment on a number of issues, including how the guidance should be revised to address mobile marketing and affiliate marketing.
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