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After Loper Bright, should the FTC's views on advertising interpretation still receive deference?

In 2015, the FTC prevailed in litigation against POM Wonderful, makers of pomegranate juice. POM Wonderful LLC, et al., v. Federal Trade Commission, 773 F.3d 487 (D.C. Cir. 2015). The case involved the FTC's assertions that...more

Kattison Avenue | Issue 12 - Spring 2024

We're thrilled to present a special Spring edition of Kattison Avenue, which delves into highlights and takeaways from the recent Katten-hosted Association of National Advertisers (ANA) 1-Day Conference in our New York...more

New Lawsuit Against AdTech's Contribution to Bots

In a New York State Court lawsuit filed on March 11, 2024, a small digital content developer called Nubai sued its former adtech vendor, Outbrain, for routing to it what it called primarily sophisticated invalid traffic ...more

4/26/2024  /  Advertising , Bots , Fraud , Marketing

Court Dismisses Textile Greenwashing Class Action Against Nike

In a recent decision, the United States District Court for the District of Missouri dismissed a putative class action complaint against Nike, in which the plaintiff had alleged that over 2,000 products in Nike's...more

New York Attorney General Sues JBS for Alleged Greenwashing

On February 28, 2024, the New York Attorney General (“NYAG”) sued JBS USA Food Company and JBC USA Food Company Holdings (collectively, “JBS”), pursuant to New York state consumer protection laws, for alleged greenwashing...more

Anti 'Junk Fee' Lawsuit Risk Already Growing

Everyone hates “junk fees.” Just the name suggests that the junk fee refers to surprise, unnecessary charges, tacked onto advertised prices in a manner that is deceptive or unfair. The Biden Administration has announced a...more

District Court Refuses to Dismiss Putative Class Action Challenging Meaning of 'Carbon Neutral' Claim

Advertisers wishing to emphasize their environmental progressiveness often assert that their products or processes are "carbon neutral." This is meant to convey that there are no net emissions of carbon associated with the...more

ANA Study Finds Over $20 Billion in "Efficiency Gains" Possible in Programmatic Advertising Spend.

In a diplomatically-worded report, yesterday the Association of National Advertisers (ANA) published its updated study: “Programmatic Media Supply Chain Transparency Study: Complete Report.” The report follows and updates...more

Foreign Corruption in Advertising Markets: A Large and Looming Concern

Last week, Shanghai police reportedly raided the offices of WPP subsidiary, Group M, based on allegations of bribery in the placement of media by Group M. In response to the raid, WPP reportedly fired the executive who was...more

California Lawsuit Launches Massive Climate Change Lawsuit Against Major Oil Producers and Their Trade Association

On September 15, California Attorney General Rob Bonta announced the filing of a 135-page complaint against major oil producers and their main trade association. The suit alleges generally that the defendants knew about the...more

Greenwashing? Try 'Greenhushing' – A Look at Recent Developments in Fashion Sustainability Claims

The fashion industry continues to be a target of activist plaintiffs who allege greenwashing, or in other words, false advertising regarding environmental and/or social aspects of clothing manufacturing and sales. While...more

Thoughts from the National Advertising Division (NAD) Annual Conference, 2023

The annual legal conference for the National Advertising Division of the Better Business Bureaus National Programs (NAD) took place over two days this week in Philadelphia. The conclave was well-attended by the advertising...more

9/22/2023  /  Advertising , NAD , NARB

District Court Denies Nestle's Motion to Dismiss False Advertising Class Action Based on Alleged Child Labor in Cocoa Supply Chain

Late last week, the United States District Court for the Southern District of California denied a motion to dismiss a putative class action alleging that Nestle had falsely advertised, in part, that its cocoa as "sustainably"...more

7/20/2023  /  Advertising , Child Labor , Supply Chain

"Aspirational" claims: an alternative to greenhushing?

Major media and consultants are noting the increasing trend towards corporate “greenhushing,” that is, adopting a “radio-silence approach to environmental goals.” For example, a survey late last year reported that one in four...more

7/17/2023  /  Advertising , False Advertising , NAD , NARB

Federal Trade Commission Updates Endorsement Guides and Proposes New Rule on Consumer Reviews

The Federal Trade Commission (FTC) has news for advertisers: for internet and social media disclosures to be effective, they must be “unavoidable.” On June 29, the FTC released final revised Endorsement Guides, the first...more

FTC Secures $18.5 million Settlement and Order In Another "Dark Patterns" Case

On the heels of its lawsuit against Amazon.com, the FTC filed a complaint yesterday against PCH, the marketer behind the venerable Publishers Clearinghouse organization. The complaint alleges that PCH used various deceptive...more

Want to Be a Hero to Your Company? ANA Report on Programmatic Ad Fraud and Digital Ad Waste Suggests How

Between sips of rose at the Cannes Lions Awards in France this week, the ANA revealed a blockbuster report that shames the programmatic advertising industry. It purports to show that of about $88 billion spent each year by...more

6/27/2023  /  Advertising , Fraud , Marketing

If Amazon's Online PRIME Cancellation Process Is Found to Be a Prohibited 'Dark Pattern,' Lots of Other Advertisers Should Be...

The FTC made news yesterday by filing suit against Amazon for allegedly "tricking" consumers into signing up for the company's Prime service and also for allegedly "sabotaging" consumers' efforts to cancel Prime. Prime is...more

Kattison Avenue | Issue 10

Do You Really Intend to Offer NFTs, Digital Collectibles and Virtual Goods? If Not, No Trademark - The NFT explosion has led to a “gold rush” of thousands of new US trademark applications covering NFT-based digital files,...more

Will it work? FTC sends its latest round of Notices of Penalty Offense to 670 companies.

Following the Supreme Court's 2021 decision striking down the FTC's practice of using FTC Act Section 13(b) to obtain monetary redress in AMG Capital Mgmt., LLC v. FTC, 141 S. Ct. 1341 (2021), the FTC has been exploring...more

NAD will now accept implied claims in SWIFT

NAD has revised its SWIFT challenge rules to accept simple "implied" claims. The cases, for now, must still involve a single issue and the implied claims must be very obvious, akin to "necessary implication" matters....more

3/10/2023  /  Advertising , Marketing , NAD , SWIFT

The ESG Backlash is Growing

These days, articles about ESG are often tempered with mentions of a growing anti-ESG movement. Indeed, ESG has become a political wedge issue. The Wall Street Journal has reported that none other than Leonard Leo, of...more

FTC Extends Green Guides Comments Deadline

In response to numerous industry requests, the FTC has extended the deadline for submitting comments to the Green Guides by 60 days, from Feb. 21, 2023, to April 24, 2023. If the FTC decides to convert the Guides into a...more

Q&A with Chris Cole - Kattison Avenue/Katten Kattwalk | Issue 2

Before law school, your academic history shows a strong interest in science, with a bachelor’s degree in biology from Yale University and a masters in marine biology from the University of Miami. Why did you decide to pursue...more

Kattison Avenue/Katten Kattwalk | Issue 2

We’re delighted to welcome in 2023 with our second crossover edition of Katten Kattwalk/Kattison Avenue. In this combined winter issue, we cover top issues affecting brands in fashion, retail and advertising. On the hot...more

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