Careful Consideration is Advised, as FTC’s Guidance May Inform Federal and/or State Enforcement Actions

Comments Deadline: July 11, 2011

This post was written by Christopher G. Cwalina, Amy S. Mushahwar, and Frederick Lah.

The Federal Trade Commission (“FTC”) seeks public comment, as it considers updating and reissuing “Dot Com Disclosures: Information about Online Advertising”, its business guidance document for online marketers on how to provide clear and conspicuous disclosures to consumers.

In its request for comment, the FTC cites the dramatic changes in the online world since the guidance was originally published in 2000, particularly the emergence of mobile marketing, the “App” economy, the use of “pop-up blockers,” and online social networking. (This recognition of mobile is particularly important in light of last week’s letter by Senator Al Franken (D-MN) to Google (maker of the Android) and Apple (maker of the iPhone and iPad) asking that all mobile apps for their devices provide “clear and understandable privacy policies.”)

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