Internet Marketing Law Blog

What Marketers Need to Know to Comply with FTC Consumer Review Rule Prohibition on Insider Consumer Reviews

As previously covered here and here, the Federal Trade Commission has recently warned businesses to comply with the FTC Consumer Review Rule. On December 22, 2025, the FTC announced that it sent warning letters to alert a number of companies of potential violations of the Rule on the Use of Consumer Reviews and Testimonials (the…

5 Star Intel: FTC and State AGs Investigating Fake Google and Yelp Reviews

The Federal Trade Commission and State Attorneys General are aggressively investigating the use of fake or false consumer reviews and testimonials – including AI-generated reviews – on consumer review platforms like Google and Yelp.  At both a federal and state level, regulatory agencies are seeking harsh monetary civil penalties and damages against violators of applicable…

FTC Authority to Seek Broad Injunctive Relief for Deceptive Fee Disclosures Affirmed by Federal Court

In January 2026, an U.S. Court of Appeals for the Eleventh Circuit unanimously upheld a federal district court’s summary judgment ruling in favor of the Federal Trade Commission relating to advertising disclosure practices.  In doing so, the court cited “overwhelming” evidence of unfair and deceptive acts and practices. By way of background, in 2019 FTC…

How To Make FTC Compliant U.S. Origin (Made in USA) Claims

The Federal Trade Commission possesses the authority to regulate U.S. origin (“Made in USA”) claims under Section 5 of the Federal Trade Commission Act. The FTC Act prohibits unfair or deceptive acts or practices. Objective advertising claims, including U.S. origin claims, must be truthful and substantiated. The FTC has actual guidelines for making lawful U.S.…

FTC “Means and Instrumentalities” Liability Takes a Hit

The Federal Trade Commission utilizes a number of remedial theories when attempting to hold a bad actor liable for the actions of a third party.  One such theory is known as “means and instrumentalities” liability, where a bad actor can potentially be liable if it provides others with the “means and instrumentalities” for engaging in…

NYC Mayor Mamdani Signs Executive Orders to Stop Junk Fees and Subscription Tricks

On January 5, 2025, NYC Mayor Zohran Mamdani, joined by Attorney General Letitia James, City Council Member Julie Menin, and DCWP Commissioner Sam Levine, announced that it has signed two executive orders: to combat businesses’ deceptive use of junk fees and crackdown on subscription tricks and traps that that drain money from New Yorkers and make…