Comments on: FTC Director Vladeck – Consumer Protection Director in a “target rich environment” http://nutrisuplaw.com/ftc-director-vladeck-consumer-protection-director-in-a-target-rich-environment/ Arnstein & Lehr LLP Sun, 09 Oct 2011 23:47:18 +0000 hourly 1 http://wordpress.org/?v=3.3.1 By: | KEYTLaw http://nutrisuplaw.com/ftc-director-vladeck-consumer-protection-director-in-a-target-rich-environment/comment-page-1/#comment-2407 | KEYTLaw Tue, 03 Nov 2009 17:47:22 +0000 http://nutrisuplaw.com/?p=1341#comment-2407 [...] new Guides Concerning the Use of Endorsements and Testimonials in Advertising creates a “target rich enviornment” in which they intend to pursue violators using all the resources at their....  And when the 1000+ enforcement personnel at the FTC run out, FTC plans to call on the state [...] [...] new Guides Concerning the Use of Endorsements and Testimonials in Advertising creates a “target rich enviornment” in which they intend to pursue violators using all the resources at their….  And when the 1000+ enforcement personnel at the FTC run out, FTC plans to call on the state [...]

]]> By: Target Rich Environment : The Business of Creativity http://nutrisuplaw.com/ftc-director-vladeck-consumer-protection-director-in-a-target-rich-environment/comment-page-1/#comment-2406 Target Rich Environment : The Business of Creativity Tue, 03 Nov 2009 14:30:25 +0000 http://nutrisuplaw.com/?p=1341#comment-2406 [...] For the full article. Visit Joel’s blog HERE. [...] [...] For the full article. Visit Joel’s blog HERE. [...]

]]> By: David A. Mark http://nutrisuplaw.com/ftc-director-vladeck-consumer-protection-director-in-a-target-rich-environment/comment-page-1/#comment-2395 David A. Mark Tue, 27 Oct 2009 11:50:40 +0000 http://nutrisuplaw.com/?p=1341#comment-2395 As a science consultant to the supplement and functional food industries I often trot out a parable for prospective clients "Don't go camping in the woods, because of the bears. If you must go into the woods, don't carry food with you. If you must carry food, don't be the slowest camper." The FTC has made clear that companies depending solely on testimonials to market products are the slowest campers. Other likely targets are companies depending on "vampire science" - research gleaned from the published scientific literature but not replicated with their own product, the flaw being that the tested and marketed products are not equivalent in chemical composition or quantity. As a science consultant to the supplement and functional food industries I often trot out a parable for prospective clients “Don’t go camping in the woods, because of the bears. If you must go into the woods, don’t carry food with you. If you must carry food, don’t be the slowest camper.”

The FTC has made clear that companies depending solely on testimonials to market products are the slowest campers. Other likely targets are companies depending on “vampire science” – research gleaned from the published scientific literature but not replicated with their own product, the flaw being that the tested and marketed products are not equivalent in chemical composition or quantity.

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