Submission Number: 00012
Received: 7/11/2012 8:10:10 PM
Commenter: Tom Chernaik
Organization: CMPLY, Inc.
State: New York
Agency: Federal Trade Commission
Initiative: In Short: Advertising & Privacy Disclosures in a Digital World; FTC Project No P114506
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Please see our attached for our complete comments from the In Short Workshop that was held on May 30, 2012.
We strongly urge the Commission to revisit the Dot Com Disclosures to address the issues that advertisers and marketers face in the evolving digital landscape and in social media and networking. We have been working on the forefront of these issues with a mission to help advertisers and influencers comply with disclosure requirements, document their efforts and provide clear and conspicuous methods to ensure that consumers are able to easily understand the context and connections behind the messages that they receive.
In this comment, we address open questions that were raised at the workshop, further clarify some of the key issues for the Commission to consider and highlight updates on both research and developments in the space in the past few months. As the Commission considers the Dot Com Disclosures, we suggest that the Commission ensure its guidance retains flexibility in how advertisers and other parties provide disclosures. The online and mobile environments are dynamic and evolving rapidly. Overly prescriptive guidance or declaring means of notice ineffective would lessen the potential for innovation in providing disclosures. We recommend that the Commission foster the development of new tools and methods for providing disclosures.
We appreciate the opportunity to provide these comments to you and we would be happy to participate in future discussions or answer any questions that you might have.