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The Internet, Social Networking and the FTC

The FTC new guidelines, published October 5, 2009 state: “The advertiser (your company) is subject to liability for misleading or unsubstantiated representations made through the blogger’s endorsement.”

DSCM offers Internet website, blogging and social networks screening, available on a monthly basis to clients in order to audit all messages being broadcast to the public.

Any shortcomings in the above can contribute to significant liability issues for your company – and all of them draw unnecessary attention from regulators.

Passive and response-driven Compliance efforts are no longer sufficient in the eyes of federal and state regulators. Direct Selling companies must be diligent, pro-active, and thorough in their Compliance efforts. Compliance has become a "bet the farm" proposition, and recent cases clearly indicate that companies now get only "one bite at the apple."

Along with appointed counsel of several client companies, DSCM has responded to complaints and inquiries from States' Attorneys General on consumer issues and met face-to-face with them or their investigators when appropriate. This approach is highly recommended as opposed to “trying to fight city hall”.

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