Ad Law Access

Updates on advertising law and privacy law trends, issues, and developments

FTC Staff Report on MLM Income Disclosures: Many Observations Lead to Many Questions

Yesterday, the Federal Trade Commission issued a staff report documenting its review of 70 publicly available income disclosure statements from a wide range of multi-level marketing (MLM) and direct selling companies…

FTC Staff’s Revised MLM Guidance—More Content, Less Clarity

Yesterday FTC Staff released updated Business Guidance Concerning Multi-Level Marketing that provides a detailed account of their current perspective on applicable standards governing the direct selling and multi-level…

FTC Staff Doubles Down on Rejected Koscot Standard for Pyramiding Claims, Challenges DSSRC IDS Guidance

Over the past two years, we have seen FTC staff express its opinions on the state of the law in multiple ways. In December 2022, for example, staff issued its Health Products Compliance Guidance, intended to supersede…

What We Learned From … Illinois

Our State AG webinar series continues. After spending time in the Centennial State, we went east to the Land of Lincoln. We met with Illinois Attorney General Kwame Raoul, Susan Ellis, Consumer Protection Division…

Neora Prevails In Landmark Decision For Direct Selling Industry

Big, BIG win for the direct selling industry, as Judge Barbara Lynn (N.D. Texas) grants judgment for Neora, LLC (formerly Nerium) on all of the FTC’s claims, including that the company was operating an illegal pyramid…