On March 12, 2013, the Federal Trade Commission (“FTC”) issued an update to its “Dot Com Disclosures” guide to advertisers on making effective online disclosures. In doing so, the FTC has driven home the points that:

• The consumer protection laws apply to all advertisers, regardless of the medium used—and including social media, even where there is limited space;

• Disclosures required to avoid deception or to otherwise comply with the law must be presented in a clear and conspicuous manner...