FTC Seeks Input for Revising Its Guidance to Businesses About Online Advertising, FTC Matter No. P114506 #00004 

Submission Number:
Tim Franklin
Initiative Name:
FTC Seeks Input for Revising Its Guidance to Businesses About Online Advertising, FTC Matter No. P114506
I would hope to see equal protection for all consumers, both online and offline deceptive, advertisements on TV can be seen that promote subliminal methods of advertising, however it appears that enforcement may be an issue if disclosure is not required for all advertisers, not just internet advertisers, clear and conspicuous disclosure must apply to all advertisers, equally, including enforcement of the same standards for all. I would hope that before measures are taken to protect consumers online that there could be some measure of protection afforded the millions of television viewers. including commercials, that make use of excessive loudness and depict impossibly large food items, graphics and pictures, of pizza that are over 24 inches in diameter, yet, when the consumer goes to purchase the product, the actual product is often less than 12 inches with substantially less product and toppings. Is this not deceptive advertising? Another example is the 12 inch hamburger, that is shown in many fast food television commercials. Consumers may understand at some level that they are not going to actually get what they are seeing on TV, however, is it not deceptive to show such large depictions of food? When consumers are not actually getting what they are being show? What about the psychological considerations of showing overly large food items on video commercials, in broadcast television? The human Subconscious, is highly susceptible to conditioning, in video advertising, will the FTC begin to require clear and conspicuous disclosure for all forms of advertising,with such a large percentage of Americans now falling into the obese category, do we not have the duty to protect all consumers from messages that these types of commercials send to the consuming public? I would like to understand the concern that is being directed at online advertisers and yet no such precautions for protecting consumers that are exposed to deceptive video advertising in broadcast, that use highly technical and sophisticated subliminal advertising methods, frame rates in excess of 120 frames per second often with highly suggestive use of graphics in video content, these things should be the concern of a highly motivated organization. I would be in favor for such additional measures to protect consumers, if all broadcast media were also subject to the same disclosure requirements as what is currently being proposed for online advertising content, does it not make more sense to provide a safe experience for all consumers? Clear and conspicuous, disclosures for Television Advertising must also apply to broadcast and be enforced not just applied to online advertisers without applying If we require clear and conspicuous, disclosure for online advertisers, should we not also require this same level of protection for consumers that are not able to access online advertising? These questions should be carefully considered and answered before we can consider the idea of proposing such disclosure and legal requirements for online advertisers alone. Should we not apply the same protection for all consumers? Can we apply one set of guides for the internet yet ignore clearly deceptive advertising for broadcast advertisers, the same level of enforcement must be applied to both online My question and concern, is will such disclosures be required of all commercial producers, Radio, Television, Cable, Internet or just online? If no such disclosure notices are proposed for broadcast advertisers, then this is something that is a serious issue and concern. How can we not protect all consumers with the same passion and the same level of protection as the FTC guides propose for online consumers? Should we not have equal protection of all consumers? To apply, an unequal burden for online advertisers without providing equal enforcement for all advertisers. This is a question that we must answer before we consider these additional disclosure guides