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Kenny Fraser's avatar

Another great newsletter. Thanks for everything you have shared this year.

Amber M's avatar

Loved the newsletter. One small clarification on the FTC point: you note that “it was pretty obvious to a lot of people following along that Citius was almost certainly being compensated.” That’s actually the key threshold the FTC uses.

Under the FTC’s Endorsement Guides, disclosure is required only when a material connection is not reasonably expected by the audience and could affect how they evaluate an endorsement (16 C.F.R. § 255.5). The FTC’s analysis is context- and audience-dependent, not a blanket requirement to disclose on every piece of content.

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