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FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy Satterfield Federal Trade Commission Peter Marinello National Advertising Division, BBB

FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

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Page 1: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop:

Effective Disclosures in Advertising

May 22, 2001

Making Disclosures Clear and Conspicuous

Lee PeelerFederal Trade Commission

Randy SatterfieldFederal Trade Commission

Peter MarinelloNational Advertising Division, BBB

Page 2: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Making Disclosures Clear and Conspicuous

LetsGoTV

Page 3: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Television Advertising

LetsGoTVTelevision Advertising Storyboard

30 Seconds

Page 4: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: Don’t you wish you could watch TV anywhere you want?

Page 5: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: At the beach.

SFX: crashing

Page 6: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: At the game.

SFX: cheering sounds

Page 7: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: On the road.

SFX: crickets

Page 8: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: Now you can. With LetsGoTV. You’ll get your favorite local channels anywhere, anytime. And all the best cable has to offer.

Super: LetsGoTV

Page 9: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: Like Box Seats Sports, BNN and ShoMax.

Super: LetsGoTV

Super: Direct satellite reception of stations such as Box Seat Sports Channel, Broadcast News Network, ShoMax, and other cable channels requires a subscription to LetsGoTV Premium Service available at a cost of $49.95 per month. Additional equipment required. Reception limitations may apply. “LetsGoTV” is a registered trademark of B3 Innovations, Inc.

Page 10: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: All for $199.

Super: $199.

Super: With mail-in rebate. Restrictions apply.

Page 11: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: Just call 1-800-LetsGoTV.

Super: 1-800-LetsGoTV

Page 12: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

VO: You’re on the go. Shouldn’t your TV go with you? LetsGoTV from B3 Innovations.

Super: LetsGoTV.

Page 13: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues Raised by TV Ad

The Claim:

The Fine Print:

“Don’t you wish you could watch TV anywhere you want?”

“Reception limitations may apply.”

Page 14: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues Raised by TV Ad

The Claim:

The Fine Print:

“…favorite local channels.… And all the best cable has to offer.”

Satellite reception for cable service “…available at a cost of $49.95 per month.”

Page 15: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues Raised by TV Ad

The Fine Print: Three lines of

important disclosures On screen for only two

seconds

“Direct satellite reception of stations such as Box Seat Sports Channel, Broadcast News Network, ShoMax, and other cable channels requires a subscription to LetsGoTV Premium Service available at a cost of $49.95 per month. Additional equipment required. Reception limitations may apply. “LetsGoTV” is a registered trademark of B3 Innovations, Inc.”

Page 16: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues Raised by TV Ad

The Claim:

The Fine Print:

LetsGoTV shown with an antenna.

“Additional equipment required.”

Page 17: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

The Claim:

The Fine Print:

The Issues: Before rebate cost is $399 Must subscribe to satellite

service for a year Rebate paid at end of one

year $50 cable cancellation fee

Issues Raised by TV Ad

Cost: $199

“With mail-in rebate. Restrictions apply.”

Page 18: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Print Advertising

LetsGoTVPrint Advertising

LetsGoTV.Never miss your favorite programs.Cable Sports. 24-Hour News.First-Run Movies.

LetsGoTV.Watch whatever you want.Wherever you want.

LetsGoTV.goes everywhere you go.

But it’s more than just convenient. is all about performance. With the largest screen of any handheld TV, gives you crystal clear satellite reception. And unlike the others, has your favorite cable channels, like Box Seat Sports, Broadcast News Network and ShoMax.

LetsGoTV

LetsGoTVLetsGoTV

$199

•Weighs less than two pounds• Thin Film Transistor active-matrix technology• Anti-glare screen for the clearest color and contrast even in bright sunlight• Digitreck headphones included!

You’re on the go.Shouldn’t you TV go with you?$199 after rebate*To order, call 1-800-LetsGoTV. www.LetsGoTV.comLetsGoTV is a registered trademark of B3 Innovations, Inc.

With twelve-month contract for LetsGoTV Premium Service. Advertised price reflects $399 purchase price after $200 rebate. Termination of contract within twelve-month period voids the rebate and requires a cancellation fee of $50. Direct satellite reception of stations like Box Seat Sports Channel, Broadcast News Network, ShoMax and other cable channels requires a subscription to LetsGoTV Premium Service available for $49.95 per month. Call 1-800-LetsGoTV for more information. Additional equipment required.

*

Page 19: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues with Print Ad

The Claims: $199 advertised price “Watch whatever you

want. Wherever you want.”

Product shown with antenna…

“…favorite cable channels…”

LetsGoTV.Never miss your favorite programs.Cable Sports. 24-Hour News.First-Run Movies.

LetsGoTV.Watch whatever you want.Wherever you want.

LetsGoTV.goes everywhere you go.

But it’s more than just convenient. is all about performance. With the largest screen of any handheld TV, gives you crystal clear satellite reception. And unlike the others, has your favorite cable channels, like Box Seat Sports, Broadcast News Network and ShoMax.

LetsGoTV

LetsGoTVLetsGoTV

$199

•Weighs less than two pounds• Thin Film Transistor active-matrix technology• Anti-glare screen for the clearest color and contrast even in bright sunlight• Digitreck headphones included!

You’re on the go.Shouldn’t you TV go with you?$199 after rebate*To order, call 1-800-LetsGoTV. www.LetsGoTV.comLetsGoTV is a registered trademark of B3 Innovations, Inc.

With twelve-month contract for LetsGoTV Premium Service. Advertised price reflects $399 purchase price after $200 rebate. Termination of contract within twelve-month period voids the rebate and requires a cancellation fee of $50. Direct satellite reception of stations like Box Seat Sports Channel, Broadcast News Network, ShoMax and other cable channels requires a subscription to LetsGoTV Premium Service available for $49.95 per month. Call 1-800-LetsGoTV for more information. Additional equipment required.

*

Page 20: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop: Effective Disclosures in Advertising

Issues with Print Ad

The Fine Print: Price in small point size

has an asterisk Important disclosures

in 6 point orange type on red background

• Satellite service costs $49.95 a month

• One year satellite service subscription required

• $50 early cancellation fee

• Additional equipment required

LetsGoTV.Never miss your favorite programs.Cable Sports. 24-Hour News.First-Run Movies.

LetsGoTV.Watch whatever you want.Wherever you want.

LetsGoTV.goes everywhere you go.

But it’s more than just convenient. is all about performance. With the largest screen of any handheld TV, gives you crystal clear satellite reception. And unlike the others, has your favorite cable channels, like Box Seat Sports, Broadcast News Network and ShoMax.

LetsGoTV

LetsGoTVLetsGoTV

$199

•Weighs less than two pounds• Thin Film Transistor active-matrix technology• Anti-glare screen for the clearest color and contrast even in bright sunlight• Digitreck headphones included!

You’re on the go.Shouldn’t you TV go with you?$199 after rebate*To order, call 1-800-LetsGoTV. www.LetsGoTV.comLetsGoTV is a registered trademark of B3 Innovations, Inc.

With twelve-month contract for LetsGoTV Premium Service. Advertised price reflects $399 purchase price after $200 rebate. Termination of contract within twelve-month period voids the rebate and requires a cancellation fee of $50. Direct satellite reception of stations like Box Seat Sports Channel, Broadcast News Network, ShoMax and other cable channels requires a subscription to LetsGoTV Premium Service available for $49.95 per month. Call 1-800-LetsGoTV for more information. Additional equipment required.

*

Page 21: FTC-NAD Workshop: Effective Disclosures in Advertising May 22, 2001 Making Disclosures Clear and Conspicuous Lee Peeler Federal Trade Commission Randy

FTC-NAD Workshop:

Effective Disclosures in Advertising

May 22, 2001

Making Disclosures Clear and Conspicuous

Lee PeelerFederal Trade Commission

Randy SatterfieldFederal Trade Commission

Peter MarinelloNational Advertising Division, BBB