Understanding the FTC’s position on social media endorsements

The Federal Trade Commission updated its endorsement guidelines in 2009 to address social media

The hashtag: #WanderingSole. The event: High-end shoe company Cole Haan challenges its Pinterest followers to post pictures of themselves wearing the shoe brand in unique and creative places, with the accompanying clever hashtag. Innocent enough, right? Not so fast.

Cole Haan created the #WanderingSole challenge within the context of a contest, the winner of which would be awarded a $1,000 Cole Haan shopping spree. And that’s when the Federal Trade Commission (FTC) stepped in — slapping Cole Haan with a warning that it was in violation of Section 5 of the FTC Act for failure to disclose a material connection between Cole Haan and the endorsers.

Contributing Author

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Mary Wasik

Mary Wasik is a partner and chair of the Corporate & Securities Group of Levenfeld Pearlstein LLC. Her corporate representation is extensive and includes advising clients...

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