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Following a public comment period, the Federal Trade Commission finalized the Order settling charges that Legacy Learning Systems Inc. and its owner, Lester Gabriel Smith, deceptively advertised the “Learn and Master Guitar” program through online affiliate marketers who falsely posed as ordinary consumers or independent reviewers without clearly disclosing they were paid substantial commissions for every sale they generated.  Under the final order, Smith and Legacy Learning will pay $250,000, and maintain a system to review and monitor their affiliate marketers’ representations and disclosures.

The Commission vote approving the final Order was 5-0.  (File No. 1023055; the staff contacts are Stacey Ferguson or Victor DeFrancis, Bureau of Consumer Protection,  202-326-2361 or 202-326-3495.)

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