D T C M

DISCLOSURES

INFORMATION ABOUT ONLINE ADVERTISING

Federal Trade Commission Toll-free 1.877.FTC.HELP For the Consumer www.ftc.gov

D T C M

DISCLOSURES

1

OVERVIEW

A

lthough the number of companies advertising onlineand the number of consumers

shopping onlineare soaring, fraud and deception may dampen consumer confidence

in the e-marketplace. But cyberspace is not without boundaries, and fraud and deception are unlawful no matter what the medium. The FTC has enforced and will continue

enforcing its consumer protection laws online to ensure that products and services are

described truthfully in online ads and that consumers get what they pay for. These

activities benefit consumers as well as sellers, who expect and deserve a fair marketplace.

Many of the general principles of advertising law apply to Internet ads, but new issues

arise almost as fast as technology develops. This booklet describes the information

businesses should consider as they develop online ads to ensure that they comply with

the law. Briefly,

1. The same consumer protection laws that apply to commercial activities in other

media apply online. The FTC Acts prohibition on unfair or deceptive acts or

practices encompasses Internet advertising, marketing and sales. In addition,

many Commission rules and guides are not limited to any particular medium

used to disseminate claims or advertising, and therefore, apply to online activities.

2. Disclosures that are required to prevent an ad from being misleading, to ensure

that consumers receive material information about the terms of a transaction or

to further public policy goals, must be clear and conspicuous. In evaluating

whether disclosures are likely to be clear and conspicuous in online ads, advertisers should consider the placement of the disclosure in an ad and its proximity

to the relevant claim. Additional considerations include: the prominence of the

disclosure; whether items in other parts of the ad distract attention from the

disclosure; whether the ad is so lengthy that the disclosure needs to be repeated;

whether disclosures in audio messages are presented in an adequate volume and

cadence and visual disclosures appear for a sufficient duration; and, whether the

language of the disclosure is understandable to the intended audience.

3. To make a disclosure clear and conspicuous, advertisers should:

❍ Place disclosures near, and when possible, on the same screen as the triggering claim.

❍ Use text or visual cues to encourage consumers to scroll down a Web page

when it is necessary to view a disclosure.

❍ When using hyperlinks to lead to disclosures,

● make the link obvious;

● label the hyperlink appropriately to convey the importance, nature and

relevance of the information it leads to;

● use hyperlink styles consistently so that consumers know when a link is

available;
2

● place the hyperlink near relevant information and make it noticeable;

● take consumers directly to the disclosure on the click-through page;

● assess the effectiveness of the hyperlink by monitoring click-through

rates and make changes accordingly.

❍ Recognize and respond to any technological limitations or unique characteristics of high tech methods of making disclosures, such as frames or

pop-ups.

❍ Display disclosures prior to purchase, but recognize that placement limited

only to the order page may not always work.

❍ Creatively incorporate disclosures in banner ads or disclose them clearly and

conspicuously on the page the banner ad links to.

❍ Prominently display disclosures so they are noticeable to consumers, and

evaluate the size, color and graphic treatment of the disclosure in relation to

other parts of the Web page.

❍ Review the entire ad to ensure that other elementstext, graphics,

hyperlinks or sounddo not distract consumers attention from the disclosure.

❍ Repeat disclosures, as needed, on lengthy Web sites and in connection with

repeated claims.

❍ Use audio disclosures when making audio claims, and present them in a

volume and cadence so that consumers can hear and understand them.

❍ Display visual disclosures for a duration sufficient for consumers to notice,

read and understand them.

❍ Use clear language and syntax so that consumers understand the disclosures.

4. Commission rules and guides that use specific termswritten, writing,

printed or direct mailare adaptable to new technologies.

❍ Rules and guides that apply to written ads or printed materials also apply to

visual text displayed on the Internet.

❍ If a seller uses email to comply with Commission rule or guide notice

requirements, the seller should ensure that consumers understand that they

will receive such information by email and provide it in a form that consumers can retain.

❍ Direct mail solicitations include email. If an email invites consumers to

call the sender to purchase goods or services, that telephone call and subsequent sale must comply with the Telemarketing Sales Rule requirements.
3

I. INTRODUCTION

D

ay in and day out, businesses are going online to advertise and sell their products

and services. The Internet combines aspects of print, television, and radio advertising in an interactive environment, and while it presents a new and fast-paced experience for consumers, it also raises interestingand occasionally complexquestions

about the applicability of laws that were developed long before dot com became a

household phrase.

The Federal Trade Commission has examined how its own consumer protection rules

and guides apply to advertising and sales made via the Internet. This staff working

paper discusses FTC requirements that disclosures be presented clearly and conspicuously, in the context of Internet advertisements. It also discusses how certain rules

and guides apply to online activities, when the rule or guide refers to written ads or

direct mail solicitations or requires notices to be sent to consumers.

The publication of this staff working paper follows a public comment period and a

public workshop which was held to discuss the applicability of FTC rules and guides

to online activities. 1 In evaluating how disclosures can be displayed clearly and

conspicuously in online ads, the comments and workshop discussion focused specifically on disclosures required by the rules and guides. 2

 The same analysis that applies

to rule and guide disclosures also applies to disclosures that are necessary to prevent

deception under Section 5 of the FTC Act. They, too, must be clear and conspicuous.

Therefore, this paper addresses both types of disclosures. 3

II. THE APPLICABILITY OF FTC LAW TO INTERNET ADVERTISING

T

he FTC Acts prohibition on unfair or deceptive acts or practices broadly covers

advertising claims, marketing and promotional activities, and sales practices in

general. 4 The Act is not limited to any particular medium.

Accordingly, the Commissions role in protecting

consumers from unfair or deceptive acts or practices

encompasses advertising, marketing, and sales

online, as well as the same activities in print,

television, telephone and radio. Indeed, since 1994,

the Commission has brought over 100 law enforcement

actions to stop fraud and deception online and is working to

educate businesses about their legal obligations and consumers about

their rights.

For certain industries or subject areas, the Commission issues rules and

guides. Rules prohibit specific acts or practices that the Commission has found to

be unfair or deceptive. 5

 Guides help businesses in their efforts to comply with the

law by providing examples or direction on how to avoid unfair or deceptive acts or

practices. 6

 Many rules and guides address claims about products or services or

INTERNET ADVERTISING
4

CLEAR AND CONSPICUOUS

THE PLAIN LANGUAGE OF MANY

RULES AND GUIDES APPLIES TO

CLAIMS MADE ON THE INTERNET.

advertising in general and are not limited to any particular medium used to disseminate those claims or advertising. 7

 Therefore, the plain language of many

rules and guides applies to claims made on the Internet. 8 For example, the Mail

or Telephone Order Merchandise Rule, which addresses the sale of merchandise

that is ordered by mail, telephone, facsimile or computer, applies to those

sales regardless of the method used to solicit the order. 9

 Solicitations

made in print, on the telephone, radio, TV or online naturally fall

within the Rules scope. In addition, the Guides Concerning the Use

of Endorsements and Testimonials in Advertising apply to endorsements, which are defined as any advertising message . . . [that]

consumers are likely to believe reflects the opinions, beliefs, findings, or experience of a party other than the sponsoring advertiser.10

The Guides refer to advertising without limiting the media in which it

is disseminated, and therefore, encompass online ads.

III. CLEAR AND CONSPICUOUS DISCLOSURES IN ONLINE ADVERTISEMENTS

When it comes to online ads, the basic principles of advertising law apply:

1. Advertising must be truthful and not misleading; 11

2. Advertisers must have evidence to back up their claims (substantiation); 12

and

3. Advertisements cannot be unfair. 13

Unique features in Internet ads also may affect how

an ad and any required disclosures are evaluated.

A. Background on Disclosures

Advertisers must identify all express and implied claims that the ad conveys to

consumers. When identifying claims, advertisers should not focus only on individual phrases or statements, but should consider the ad as a whole, including the

text, product name and depictions. 14 If an ad makes express or implied claims that

are likely to be misleading without certain qualifying information, the information

must be disclosed. Advertisers must determine which claims might need qualification and what information should be provided in a disclosure. If qualifying information is necessary to prevent an ad from being misleading, advertisers must

present the information clearly and conspicuously.

A disclosure only qualifies or limits a claim, to avoid a misleading impression. It

cannot cure a false claim. If a disclosure provides information that contradicts a

claim, the disclosure will not be sufficient to prevent the ad from being deceptive.

In that situation, the claim itself must be modified.
5

Many Commission rules and guides spell out the information that must be disclosed

in connection with certain claims. In many cases, these disclosures prevent a claim

from being misleading or deceptive. 15 Other rules and guides require disclosures to

ensure that consumers receive material information about the terms of a transaction, 16

or to further public policy goals. 17 These disclosures also must be clear and conspicuous.

B. The Clear and Conspicuous Requirement

Disclosures that are required to prevent deceptionor to provide consumers material

information about a transactionmust be presented clearly and conspicuously. 18

Whether a disclosure meets this standard is measured by its performancethat is,

how consumers actually perceive and understand the disclosure within the context of

the entire ad. The key is the overall net impression of the adthat is, whether the

claims consumers take from the ad are truthful and substantiated. 19

In reviewing their online ads, advertisers should adopt the perspective of a reasonable

consumer. 20 They also should assume that consumers dont read an entire Web site,

just as they dont read every word on a printed page. 21 In addition, it is important for

advertisers to draw attention to the disclosure. Making the disclosure available somewhere in the ad so that consumers who are looking for the information might find it

doesnt meet the clear and conspicuous standard.

Even though consumers have control over what and how much information they view

on Web sites, they may not be looking foror expecting to finddisclosures. Advertisers are responsible for ensuring that their messages are truthful and not deceptive.

Accordingly, disclosures must be communicated effectively so that consumers are

likely to notice and understand them.

C. What are Clear and Conspicuous Disclosures?

There is no set formula for a clear and conspicuous disclosure. In all media, the best

way to disclose information depends on what information must be provided and the

nature of the advertisement. Some disclosures are quite short, while others are more

detailed. Some ads use only text, while others use graphics, video and audio. Advertisers have the flexibility to be creative in designing their ads, so long as necessary

disclosures are communicated effectively and the overall message conveyed to consumers is not misleading.

To evaluate whether a particular disclosure is clear and conspicuous, consider:

● the placement of the disclosure in an advertisement and its proximity to the

claim it is qualifying,

● the prominence of the disclosure,
6

Ex.

1

Refer to Example #

in the Appendix.

Ex.

● whether items in other parts of the advertisement distract attention from

the disclosure,

● whether the advertisement is so lengthy that the disclosure needs to be

repeated,

● whether disclosures in audio messages are presented in an adequate volume

and cadence and visual disclosures appear for a sufficient duration, and

● whether the language of the disclosure is understandable to the intended

audience.

The following discussion uses these traditional factors to evaluate whether disclosures are likely to be clear and conspicuous in the context of online ads. In the

online version of this booklet, the underlined hyperlinks link to mock ads. In the

printed booklet, the circles in the margin correspond to mock ads in the appendix.

Each mock ad presents a scenario to illustrate one or more particular factors.

Advertisers must consider all of the factors, however, and evaluate an actual

disclosure in the context of the ad as a whole.

1. Proximity and Placement

A disclosure is more effective if it is placed near the claim it qualifies or other

relevant information. Proximity increases the likelihood that consumers will see

the disclosure and relate it to the relevant claim or product. For print ads, an

advertiser might measure proximity in terms of whether the disclosure is placed

adjacent to the claim, or whether it is separated from the claim by text or graphics. The same approach can be used for Internet ads. Web sites, however, are

interactive and have a certain depthwith multiple pages linked together and

pop-up screens, for examplethat may affect how proximity is evaluated.

a. Evaluating Proximity in the Context of a Web Page

Some disclosures must be made when an ad contains a certain claim (often

referred to as a triggering claim). On a Web page, the disclosure is more

likely to be effective if consumers view the claim and disclosure together on

the same screen. Even if a disclosure is not tied to a particular word or

phrase, it is more likely that consumers will notice it if it is placed next to the

information, product, or service to which it relates.

In some circumstances, it may be difficult to ensure that a disclosure appears

on the same screen as a claim or product information. Some disclosures are

long and difficult to place next to the claims they qualify. In addition, computers and other information appliances have varying screen sizes that

display Web sites differently. 22 In these situations, consumers may need to

scroll to view a disclosure. If scrolling is necessary, advertisers should ask

whether consumers are likely to do it. If consumers dont scroll, they may

miss important qualifying information and be misled.
7

Ex.

2

Ex.

3

Ex.

4

In these circumstances, advertisers are advised to:

Use text or visual cues to encourage consumers to scroll.

Text prompts can indicate that more information is available. An explicit instruction like see below for important information on diamond weights will alert

consumers to scroll and look for the information. The text prompt should be tied

to the disclosure that it refers to. General or vague statements, such as see below

for details, provide no indication about the subject matter or importance of the

information that consumers will find and are not adequate cues.

The visual design of the page also could help alert consumers to the availability of

more information. For example, text that clearly continues below the screen,

whether spread over an entire page or in a column, would indicate that the reader

needs to scroll for additional information. Advertisers should consider how the

Web page is displayed by the default Web browser setting for which the ad is

designed, as well as for different display options.

A scroll bar on the side of a computer screen is not a sufficiently effective visual

cue. Although the scroll bar may indicate to some consumers that they have not

reached the end of a page, many consumers may not look at the scroll bar. In

fact, some consumers access the Internet with devices that dont display a scroll

bar.

Avoid Web page formats that discourage scrolling.

The design of some pages might indicate that there is no more information on the

page and no need to continue scrolling. If the text ends before the bottom of the

screen or readers see several inches of blank space, chances are they will stop

scrolling and miss the disclosure. In addition, if there is a lot of unrelated informationeither words or graphicsseparating a claim and a disclosure, even a

consumer who is prompted to scroll might miss the disclosure or not relate it to a

distant claim theyve already read.

b. Hyperlinking to a Disclosure

With hyperlinks, additional information, including disclosures, might be placed

on a Web page entirely separate from the relevant claim. Disclosures that are an

integral part of a claim or inseparable from it, however, should be placed on the

same page and immediately next to the claim. In these situations, the claim and

the disclosure should be read at the same time, without referring the consumer

somewhere else to obtain the disclosure. This is particularly true for cost information or certain health and safety disclosures. For example, if the total cost of a

product is advertised on one page, but there are significant additional fees that the

consumer would not expect to be charged, the existence of those additional fees

should be disclosed on the same page and immediately adjacent to the total cost

claim. 23 In other situations, it may not even be necessary to use a hyperlink to

convey disclosures. Often, disclosures consist of a word or phrase that may be
8

Ex.

5

Ex.

6

Ex.

7

MAKE IT OBVIOUS.

LABEL THE LINK. DONT BE SUBTLE.

DONT BE COY.

easily incorporated into the text, along with the claim. This placement

increases the likelihood that consumers will see the disclosure and relate

it to the relevant claim.

Under some conditions, however, a disclosure accessible by a hyperlink may

be sufficiently proximate to the relevant claim. Hyperlinked disclosures may

be particularly useful if the disclosure is lengthy or if it needs to be repeated

(because of multiple triggers, for example). The key considerations for effective hyperlinks are:

● the labeling or description of the hyperlink,

● the consistency in the use of hyperlink styles,

● its placement and prominence on the Web page, and

● the handling of the disclosure on the click-through page.

Choosing the right label for the hyperlink. A hyperlink that leads to a

disclosure should be labeled clearly and conspicuously. The hyperlinks

labelthe text or graphic assigned to itaffects whether consumers actually

click on it and see and read the disclosure.

● Make it obvious. Consumers should be able to tell that they can click

on a hyperlink to get more information.

● Label the link to convey the importance, nature and relevance of

the information it leads to. The hyperlink should give consumers a

reason to click on it. That is, the label should make clear that the link

is related to a particular advertising claim or product and indicate the

nature of the information to be found by clicking on it. The hyperlink

label should use clear, understandable text. Although the label itself

does not need to contain the complete disclosure, it may be useful to

incorporate part of the disclosure to indicate the type and importance

of the information the link leads to.

● Dont be coy. Some text links may provide

no indication about why a claim is

qualified or the nature of the

disclosure. In most cases, simply

hyperlinking a single word or

phrase in the text of an ad may

not be effective. Although some

consumers may understand that there

is additional information available, they

may have different ideas about the nature of

the information and its significance. The same
9

Ex.

8-10

Ex.

11-12

Ex.

13-14

Ex.

15

Ex.

16

may be true of hyperlinks that simply say disclaimer, more information, details, or terms and conditions.

● Dont be subtle. Asterisks or other symbols by themselves may not be

effective. Typically, they provide no clues about why the claim is qualified or the nature of the disclosure. 24 In fact, consumers may view an

asterisk or another symbol as just another graphic on the page. Even if a

Web site explains that a particular symbol is a hyperlink to important

information, consumers might miss the explanation, depending on where

they enter the site and how they navigate through it.

Using hyperlink styles consistently allows consumers to know when a link is

available. Although the text or graphics used to signal a hyperlink may differ

among Web sites, treating hyperlinks inconsistently within a single site can increase the chances that consumers will not noticeor click ona disclosure

hyperlink. For example, if hyperlinks usually are underlined in a site, chances are

consumers wouldnt recognize italicized text as being a link, and could miss the

disclosure.

Placing the link near relevant information and making it noticeable. The

hyperlink should be proximate to the claim that triggers the disclosure so that

consumers can notice it easily and relate it to the claim. Typically, this means that

the hyperlink is adjacent to the triggering term or other relevant information.

Consumers may miss disclosure hyperlinks that are separated from the relevant

claim by text, graphics, blank space, or intervening hyperlinks. Format, color or

other graphics treatment also can help to ensure that consumers notice the link.

(See below for more information on prominence.)

Getting to the disclosure on the click-through page should be easy. The

click-through pagethat is, the page the hyperlink leads tomust contain the

complete disclosure. The disclosure must be displayed prominently. Distracting

visual factors, extraneous information, and many click-away opportunities to

link elsewhere before viewing the disclosure can obscure an otherwise adequate

disclaimer.

● Get consumers to the message quickly. The hyperlink should take consumers directly to the disclosure. They shouldnt have to search a

click-through page or go to other pages for the information. In addition,

the disclosure should be easy to understand.

● Assessing the effectiveness of a hyperlink disclosure is important.

Tools are available to allow advertisers to evaluate the effectiveness of

disclosures through hyperlinks. For example, advertisers can monitor

click-through rateshow often consumers click on a hyperlink and view

the click-through pagefor accurate data on the efficacy of the hyperlink.

Advertisers also can evaluate the amount of time visitors spend on a

certain page, which may indicate whether consumers are reading the

disclosure.
10

Ex.

17-18

Ex.

19

● Dont ignore your data. If hyperlinks are not followed, another

method of conveying the required information would be necessary.

c. Using High Tech Methods For Proximity and Placement

Disclosures may be displayed on Web sites in many ways. For example, a

disclosure may be placed in a frame that remains constant even as the consumer scrolls down the page or navigates through another part of the site. A

disclosure also might be displayed in a window that pops-up or on interstitial

pages that appear while another Web page is loading. New techniques for

displaying information are being unveiled all the time. But there are special

considerations for evaluating whether a technique is appropriate for providing

required disclosures.

● Dont ignore technological limitations. A scrolling marqueeinformation that scrolls through a box on a Web sitemay display differently depending on the type of browser a consumer uses. Similarly,

some browsers or information appliances may not support or display

frames properly, so a disclosure placed in one portion of the frame

may not be viewable. Certain Internet tools may overcome this limitation by determining if a consumers Web browser can view frames and

if not, serving a page that is formatted differently. Without such tools,

advertisers should be concerned about whether a required disclosure

will appear; if it wont, they should choose different ways to communicate the disclosure.

● Recognize and respond to characteristics of each technique. Some

consumers may miss information presented in a pop-up window or on

an interstitial page if the window or page disappears and they are

unable or unaware of how to access it. Others may inadvertently

minimize a pop-up screen by clicking on the main page and may not

know how to make the pop-up screen reappear. There may be ways to

get around these drawbacks, such as requiring the consumer to take

some affirmative action to proceed past the pop-up or interstitial (for

example, by clicking on a continue button).

● Research can help. Research may be useful to help advertisers determine whether a particular technique is an effective method of communicating information to consumers. For example, research may show

that consumers dont actually read information in pop-up windows

because they immediately close the pop-up on the page they want to

view. It also may indicate whether consumers relate information in a

pop-up window or on an interstitial page to a claim or product they

havent encountered yet. Advertisers should consider this information

in determining effective methods of presenting required disclosures.
11

Ex.

20

DISCLOSURES MUST BE EFFECTIVELY

COMMUNICATED TO CONSUMERS BEFORE

THEY MAKE A PURCHASE OR INCUR A

FINANCIAL OBLIGATION.

d. Displaying Disclosures Prior to Purchase

Disclosures must be effectively communicated to consumers before they make a

purchase or incur a financial obligation. Disclosures are more likely to be effective if they are provided in the context of the ad, when the consumer is considering the purchase. Where advertising and selling are combined

on a Web site, disclosures should be provided before

the consumer makes the decision to buy, say,

before clicking on an order now button or

a link that says add to shopping cart.

● Dont focus only on the order page.

Some disclosures must be made in

connection with a particular claim or

product. Consumers may not relate a

disclosure on the order page to information

they viewed many pages earlier. It also is possible

that after surfing a companys Web site, some consumers may decide to

purchase the product from the companys bricks and mortar store.

Those consumers would miss any disclosures placed only on the ordering

page.

e. Evaluating Proximity With Banner Ads

Most banner ads displayed today are teasers. Because of their small size, they

generally do not provide complete information about a product or service. Instead, consumers must click through to the Web site to get more information and

learn the terms of an offer. In some instances, a banner may contain a claim that

requires qualification.

● Disclose required information in the banner itself or clearly and conspicuously on the Web site it links to. In some cases, a required disclosure can be incorporated into a banner ad easily. Because of the space

constraints of banner ads, other disclosures may be too detailed to be

disclosed effectively in the banner. In some instances, these disclosures

may be communicated effectively to consumers if they are made clearly

and conspicuously on the Web site the banner links to and while consumers are deciding whether to buy a product or service. In determining

whether the disclosure should be placed in the banner itself or on the Web

site the banner links to, advertisers should consider how important the

information is to prevent deception, how much information needs to be

disclosed, the burden of disclosing it in the banner ad, how much information the consumer may absorb from the ad, and how effective the disclosure would be if it was made on the Web site. 25
12

Ex.

21

Ex.

22-23

USE CREATIVITY TO INCORPORATE

OR FLAG REQUIRED INFORMATION.

● Use creativity to incorporate or flag required information. Scrolling

text or rotating panels in a banner can present an abbreviated version

of a required disclosure that indicates that

there is additional important information

and a more complete disclosure available

on the click-through page. With lengthier

disclosures, the banner can direct consumers to the Web site for more information.

The full disclosure then must be clearly

and conspicuously displayed on the Web

site.

● Provide any required disclosures in

interactive banners. Some banner

ads allow consumers to interact

within the banner, so that they may

conduct a transaction without clicking

through to a Web site. If consumers can get complete information

about a product or make a purchase within an interactive banner, all

required disclosures should be included in the banner.

2. Prominence

Its the advertisers responsibility to draw attention to the required disclosures.

● Display disclosures prominently so they are noticeable to consumers.

The size, color, and graphics of the disclosure affect its prominence.

● Size Matters. Disclosures that are at least as large as the advertising

copy are more likely to be effective.

● Color Counts. A disclosure in a color that contrasts with the background emphasizes the text of the disclosure and makes it more noticeable. Information in a color that blends in with the background of the

ad is likely to be missed.

● Graphics Help. Although using graphics to display a disclosure is not

required, they may make the disclosure more prominent.

● Evaluate the size, color, and graphics of the disclosure in relation to

other parts of the Web site. 26 The size of a disclosure should be compared to the type size of the claim and other text on the page. If a claim

uses a particular color or graphic treatment, the disclosure can be formatted the same way to help ensure that consumers who view the claim are

able to view the disclosure as well. In addition, the graphic treatment of

the disclosure may be evaluated in relation to how graphics are used to

convey other items in the ad.
13

Ex.

24

● Dont bury it. The prominence of the disclosure also may be affected by

other factors. A disclosure that is buried in a long paragraph of unrelated text

would not be effective. The unrelated text detracts from the message and

makes it unlikely that a consumer would notice the disclosure or recognize its

importance. Even though the unrelated information may be useful, advertisers

must ensure that the disclosure is communicated effectively.

3. Distracting Factors in Ads

The clear and conspicuous analysis does not focus only on the disclosure itself. It also

is important to consider the entire ad. Elements like graphics, sound, text or even

hyperlinks that lead to other pages or sites, may result in consumers not noticing,

reading or listening to the disclosure.

● Dont let other parts of an ad get in the way. On television, moving visuals

behind a text message make the text hard to read and may distract consumers

attention from the message. Using graphics online raises similar concerns:

flashing images or animated graphics may reduce the prominence of a disclosure. Graphics on a Web page alone may not undermine the effectiveness of a

disclosure. It is important, however, to consider all the elements in the ad, not

just the text of the disclosure.

4. Repetition

It may be necessary to disclose important information more than once in an advertisement to convey a non-deceptive message. Repeating a disclosure makes it more likely

that a consumer will notice and understand it. Still, the disclosure need not be repeated so often that consumers would ignore it and that it would clutter the ad.

● Repeat disclosures on lengthy Web sites, as needed. Consumers can access

and navigate Web sites differently. Many consumers may access a site through

its homepage, but others might enter in the middle, perhaps by linking to that

page from a search engine or another Web site. Consumers also might not

click-on every page of the site and may not choose to scroll to the bottom of

each page. And many may not read every word on every page of a Web site.

As a result, advertisers should question whether consumers who see only a

portion of their ad are likely to miss a necessary disclosure and be misled. 27

● Repeat disclosures with repeated claims, as needed. If claims requiring

some qualification are repeated throughout an ad, it may be necessary to

repeat the disclosure too. In some situations, a disclosure is tied so closely to a

claim that it must always accompany the claim to prevent deception. Depending on the disclosure, a clearly-labeled hyperlink could be repeated on various

pages so that the full disclosure would be placed on only one page of the site.
14

5. Multimedia Messages

Internet ads may contain audio messages, video clips and other animated segments

with claims that require qualification. As with radio and television ads, the disclosure should accompany the claim. In evaluating whether disclosures in these

multimedia portions of online ads are clear and conspicuous, advertisers should

evaluate all of the factors discussed in this paper and these special considerations: 

● For audio claims, use audio disclosures. The disclosure should be in a

volume and cadence sufficient for a reasonable consumer to hear and

understand it. The volume of the disclosure can be evaluated in relation to

the rest of the message, and in particular, the claim. Of course, consumers

who do not have speakers, appropriate software, or appliances with audio

capabilities will not hear the claim or the disclosure. Because some consumers may miss the audio portion of an ad, disclosures triggered by a

claim or other information in an ads text should not be placed solely in an

audio clip.

● Display visual disclosures for a sufficient duration. Visual disclosures

presented in video clips or other dynamic portions of online ads should

appear for a duration sufficient for consumers to notice, read and understand them. As with brief video superscripts in television ads, fleeting

disclosures on Web sites are not likely to be effective.

6. Understandable Language

To ensure that disclosures are effective, consumers must be able to understand

them. Advertisers should use clear language and syntax and avoid legalese or

technical jargon. Disclosures should be as simple and straightforward as possible.

Incorporating extraneous material into the disclosure also may diminish the message that must be conveyed to consumers.
15

IV. SPECIFIC ISSUES IN APPLYING CERTAIN RULES AND GUIDES TO INTERNET

ACTIVITIES

A. Its Not Just Paper Anymore

Some Commission rules and guides use certain termssuch as written, writing

and printedthat connote words or information on paper. With the increasing use

of computers and other electronic devices, that meaning is changing. In addition,

thanks to email, businesses are no longer limited to using traditional communications

vehicles like mail or the telephone to comply with rule or guide requirements to

notify consumers.

1. Rules and Guides that Use the Terms Written, Writing or Printed

Many rules and guides use the terms written, writing and printed, but in

different ways. Some apply to written ads or transactions, using the term written to

connote visual text. Others require information to be disclosed in writing, signaling

the importance of text and the ability to retain and refer to the information more than

once. Because each term must be analyzed within the context of the rule and guide

itself, the Commission will continue to examine the exact nature of how these rules

and guides apply to the paperless world of e-commerce and online advertising on a

case-by-case basis and through periodic rule and guide reviews. 28

For the most part, however, Commission rules and guides that use the words written, writing and printed will apply online. In many cases, an Internet ad that

uses visual text is the equivalent of a written ad. Consumers expect to receive the

same information and protections whether theyre looking at a paper catalog or an

online one. For example:

● Claims in writing . . . or in any broadcast advertisement about an

appliances energy use or efficiency must be tested in accordance with the

Appliance Labeling Rule. 29 Common sense dictates that this includes online

claims. An energy use claim presented in visual text on a Web site should be

treated the same as a claim in a print ad.

● If certain information about energy efficiency must be provided in printed

catalogs featuring appliances, 30 the information also should be provided

online. There are no more constraints to providing this information on a Web

site than there would be on paper.
16

2. Using New Technologies to Comply with Rules & Guides

As more activities and transactions take place online, businesses are using email

to communicate with their customers. In some cases, email may be used to comply

with a rule or guide requirement to provide or send required notices or documents

to consumers. A key consideration for choosing this method of delivery is

whether consumers understand or expect that they will

receive important information by email. In addition,

information should be provided in a form that consumers

can retain, either by saving or printing. Here are examples

of how these considerations apply to particular rules:

● If a seller cannot ship goods ordered by mail, telephone, or

computer within the time promised (or otherwise 30 days), the

seller must inform consumers of the delay and give them the option

to agree to the delay or cancel the order and get a refund. 31 Sellers are

not required to use a particular method to send delay notices and online

merchants may use email to send these notices. Consumers often provide

their email address as part of an online order form. It may make good

business sense for a seller to tell consumers that they plan to send any

delay notices to that email address. This information may be added to an

online order form without substantial cost or difficulty and may alert

consumers that future communications about the order will occur online.

● Online sellers of negative option planssuch as book-of-the-month clubs

also may use email to communicate with consumers. With these plans,

sellers send announcements that identify the merchandise that will be

shipped and billed for that month unless the consumer declines by a certain

date. 32 These monthly notices are an important part of the plan. If consumers dont understand that notices are sent by email, they may not

respond and may incur charges for merchandise they dont want. Because

sellers are required to clearly and conspicuously disclose the material

terms of the plan in their promotional materials, they should clearly inform consumers about how the notices will be sent before consumers

enroll in the plan.

● Sellers that offer written warranties on consumer products must include

certain information in their warranties and make them available for review

at the point of purchase. 33 Warranties communicated through visual text

on Web sites are no different than paper versions and the same rules

apply. The requirement to make warranties available at the point of purchase can be accomplished easily on the Internet. For example, Internet

merchants may use a clearly-labeled hyperlink such as click here for

warranty information to lead to the full text of the warranty. Because

consumers may need to refer to the warranty while comparison shopping

or after the purchase, the warranty should be presented in a way that is

capable of being preserved, either by downloading or printing. This is

especially important if a paper warranty is not included with the product.
17

CONSUMER CONFIDENCE

B. Direct Mail Solicitations Online

Direct mail solicitations generally refer to promotional materials that consumers

receive through traditional mail. With technological advances, these kinds of solicitations have moved online.

Although the Telemarketing Sales Rule applies largely to telemarketing calls from

business-to-consumer, it also applies to telephone calls the consumer places in response to a direct mail advertisement. 34 As with direct mail sent by traditional

means, email can convey the false impression that the recipient has been specially

selected for an offer not available to the general public. That impression may be

exploited in a telemarketing call, particularly if the direct mail piece omits important

information about the products or services offered. Therefore, if an email invites

consumers to telephone the sender to purchase goods or services, the phone call is

subject to the Telemarketing Sales Rule 35as is the subsequent sale.

Not all online advertisements are considered direct mail solicitations. Consumers

who view most Web sites, newsgroups, or electronic bulletin board postings are

likely to understand that the goods or services are being offered on the same terms

and conditions to all consumersand that they havent been specially selected for

the offer. Like television and newspaper advertisements, Web sites generally,

newsgroups, and electronic bulletin board postings are different forms of advertising

than direct mail. 36 Telephone calls placed in response to these types of ads would

generally be exempt from the Telemarketing Sales Rule. 37

V. CONCLUSION

A

lthough the number of companies advertising onlineand the number of consumers

shopping onlineare soaring, fraud and deception may dampen consumer

confidence in the e-marketplace. To ensure that products and

services are described truthfully in online ads and

that consumers get what they pay for, the

FTC has, and will continue to, enforce its

consumer protection laws. Many of the

general principles of advertising law

apply to online ads, but new issues

arise almost as fast as technology develops.

The FTC will continue to evaluate online

advertising, using traditional criteria, while

recognizing the uniqueness of the new medium.

Businesses as well should consider these criteria when

developing online ads and ensuring they comply with the law.
18

ENDNOTES

1 The Commission initially requested written comment on a proposal that discussed how it would apply its rules and guides to online activities. 63 Fed.

Reg. 24998 (May 6, 1998). After reviewing the comments, the Commission

held a public workshop on May 14, 1999, to explore the issues further. See 64

Fed. Reg. 14156 (Mar. 24, 1999) (announcing the workshop). Twenty-five

groups, including businesses, trade associations and consumer organizations,

participated in the workshop discussion. The focus of the workshop was an

evaluation of how disclosures required by FTC rules and guides can be displayed clearly and conspicuously in Internet advertisements. A shorter session

examined how terms such as written, writing and printed are used in

FTC rules and guides and should be interpreted in light of the use of electronic

media. Additional written comments were submitted after the workshop. The

public comments and the workshop transcript are available at http://

www.ftc.gov/bcp/rulemaking/elecmedia/index.htm or from the FTCs

Consumer Response Center, 600 Pennsylvania Avenue, NW, Room 130,

Washington, DC 20580.

2 With the rules and guides, the content of the disclosure generally is prescribed.

Thus, it was unnecessary to examine broader issues that might arise in examining advertising in generalfor example, whether a disclosure is even necessary

or what it should say.

3 This working paper, however, does not address disclosures required by regulations issued by the Federal Reserve Board: Regulation B, 12 C.F.R. Part 202;

Regulation E, 12 C.F.R. Part 205; Regulation M, 12 C.F.R. Part 213; Regulation Z, 12 C.F.R. Part 226. This paper also does not address which countrys

laws govern a particular transaction or sale. The FTC and other countries and

organizations have been evaluating these issues and will continue to work

cooperatively in this area. See http://www.ftc.gov/bcp/icpw/index.htm for

more information about international issues.

4 The Commissions authority covers virtually every sector of the economy,

except for certain excluded industries, such as the business of insurance and

banks.

5 The Commission issues rules pursuant to Section 5 of the FTC Act when it has

reason to believe that certain unfair or deceptive acts or practices are prevalent

in an industry. 15 U.S.C. § 57a(a)(1)(B). The Commission may seek civil

penalties from any person or company that violates a rule with actual knowledge or knowledge fairly implied on the basis of objective circumstances that

such act is unfair or deceptive and is prohibited by such rule. 15 U.S.C.

§ 45(m)(1)(A). The Commission also may seek redress for consumers. 15

U.S.C. § 57b(a)(1). In addition, the Commission promulgates rules pursuant to

specific statutes, which are designed to further particular policy goals. The

remedies available to enforce these rules vary.
19

6 Guides are administrative interpretations of the laws administered by the Commission. 16 C.F.R. § 1.5. Although the guides do not have the force and effect

of law, the Commission may bring an enforcement action if a person or company

fails to comply with a guide and engages in an unfair or deceptive practice in

violation of the FTC Act.

7 The following rules and guides are included in this category: Guides for the Nursery Industry (16 C.F.R. Part 18); Guides for the Rebuilt, Reconditioned and Other

Used Automobile Parts Industry (16 C.F.R. Part 20); Guides for the Jewelry,

Precious Metals, and Pewter Industries (16 C.F.R. Part 23); Guides for Select

Leather and Imitation Leather Products (16 C.F.R. Part 24); Tire Advertising and

Labeling Guides (16 C.F.R. Part 228); Guides Against Deceptive Pricing (16

C.F.R. Part 233); Guides Against Bait Advertising (16 C.F.R. Part 238); Guides

for the Advertising of Warranties and Guarantees (16 C.F.R. Part 239); Guides for

the Household Furniture Industry (16 C.F.R. Part 250); Guide Concerning Use of

the Word Free and Similar Representations (16 C.F.R. Part 251); Guides for

Private Vocational and Distance Education Schools (16 C.F.R. Part 254); Guides

Concerning Use of Endorsements and Testimonials in Advertising (16 C.F.R. Part

255); Guides Concerning Fuel Economy Advertising for New Automobiles (16

C.F.R. Part 259); Guides for the Use of Environmental Marketing Claims (16

C.F.R. Part 260); Rules and Regulations Under the Wool Products Labeling Act

of 1939 (16 C.F.R. Part 300); Rules and Regulations Under Fur Products Labeling

Act (16 C.F.R. Part 301); Rules and Regulations Under the Textile Fiber Products

Identification Act (16 C.F.R. Part 303); Rule Concerning Disclosures Regarding

Energy Consumption and Water Use of Certain Home Appliances and Other

Products Required Under the Energy Policy and Conservation Act (Appliance

Labeling Rule) (16 C.F.R. Part 305); Rule Concerning Automotive Fuel Ratings,

Certification and Posting (16 C.F.R. Part 306); Labeling Requirements for Alternative Fuels and Alternative Fueled Vehicles (16 C.F.R. Part 309); Telemarketing

Sales Rule (16 C.F.R. Part 310); Deceptive Advertising as to Sizes of Viewable

Pictures Shown by Television Receiving Sets (16 C.F.R. Part 410); Retail Food

Store Advertising and Marketing Practices (16 C.F.R. Part 424); Use of

Prenotification Negative Option Plans (16 C.F.R. Part 425); Power Output Claims

for Amplifiers Utilized in Home Entertainment Products (16 C.F.R. Part 432);

Preservation of Consumers Claims and Defenses (16 C.F.R. Part 433); Mail or

Telephone Order Merchandise Rule (16 C.F.R. Part 435); Credit Practices Rule

(16 C.F.R. Part 444); Used Motor Vehicle Trade Regulation Rule (16 C.F.R. Part

455); Labeling and Advertising of Home Insulation (16 C.F.R. Part 460); Interpretations of Magnuson-Moss Warranty Act (16 C.F.R. Part 700); Disclosure of

Written Consumer Product Warranty Terms and Conditions (16 C.F.R. Part 701);

Pre-Sale Availability of Written Warranty Terms (16 C.F.R. Part 702); Informal

Dispute Settlement Procedures (16 C.F.R. Part 703).

8 A rule or guide applies to online activities if its scope is not limited by how claims

are communicated to consumers, how advertising is disseminated, or where commercial activities occur. As needed, the Commission will amend or clarify the

scope of any particular rule or guide in more detail during its regularly scheduled
20

review. The Commission has a program in place to periodically review its rules

and guides to evaluate their continued need and to make any necessary changes.

9 16 C.F.R. § 435.2(a).

10 16 C.F.R. § 255(b).

11 As explained in the FTCs Deception Policy Statement [hyperlink], an ad is

deceptive if it contains a statementor omits informationthat is likely to

mislead consumers acting reasonably under the circumstances and is material

or important to a consumers decision to buy or use the product. See FTC

Policy Statement on Deception, appended to Cliffdale Associates, Inc., 103

F.T.C. at 174 (Deception Policy Statement). A statement also may be

deceptive if the advertiser does not have a reasonable basis to support the

claim. Advertising Substantiation Statement [hyperlink]. See FTC Policy

Statement on Advertising Substantiation, appended to Thompson Medical Co.,

104 F.T.C. 648, 839 (1984), affd, 791 F.2d 189 (D.C. Cir. 1986), cert.

denied, 479 U.S. 1086 (1987).

12 Before disseminating an ad, advertisers must have reasonable support for all

express and implied objective claims that the ad conveys to consumers. When

an ad lends itself to more than one reasonable interpretation, there must be

substantiation for each interpretation. The type of evidence needed to substantiate a claim may depend on the product, the claims, and what experts believe is

necessary. If an ad specifies a certain level of support for a claimtests show

xthe advertiser must have at least that level of support.

13 According to the FTC Act, 15 U.S.C. § 45(n) and the FTCs Unfairness

Policy Statement [hyperlink], an advertisement or business practice is unfair if

it causes or is likely to cause substantial consumer injury that consumers could

not reasonably avoid and that is not outweighed by the benefit to consumers or

competition. See FTC Policy Statement on Unfairness, appended to International Harvester Co., 104 F.T.C. 949, 1070 (1984).

14 Copy tests or other evidence of how consumers actually interpret an ad can be

valuable. In many cases, however, the implications of the ad are clear enough

to determine the existence of the claim by examining the ad alone, without

extrinsic evidence.

15 For example, if an endorsement is not representative of the performance that

consumers can generally expect to achieve with a product, advertisers must

disclose this fact so that consumers are not misled. Guides Concerning the Use

of Endorsements and Testimonials in Advertising, 16 C.F.R. § 255.2.

16 For example, any solicitation for the purchase of consumer products with a

warranty must disclose the text of the warranty offer or how consumers can

obtain it for free. Pre-Sale Availability of Written Warranty Terms, 16 C.F.R.

§ 702.3.
21

17 For example, the required energy efficiency disclosures in the Appliance Labeling

Rule, 16 C.F.R. § 305.4, further the public policy goal of promoting energy

conservation.

18 Some rules and guides, as well as some FTC cases, use the phrase clearly and

prominently instead of clearly and conspicuously. These two phrases are

synonymous.

19 Deception Policy Statement at 175-76.

20 Deception Policy Statement at 178.

21 Deception Policy Statement at 180-81.

22 Web pages can vary in length, and one Web page may be the equivalent of many

printed pages.

23 In some cases, the details about the additional fees might be too complex to describe

adjacent to the price claim and may be provided by using a hyperlink. But, a clear

statement about the existence and nature of the extra fees should appear adjacent to

the price. Of course, all cost information should be presented to consumers at the

time of purchase. Consumers should understand the exact amount they will be

charged and should not have to learn this information by clicking on hyperlinks.

24 Asterisks and other symbols also are used in different ways on Web pages, which

may confuse consumers as to where the related disclosure may be found. Some

online asterisks and symbols are hyperlinks that click-through to a separate page

and others are static, referring to a disclosure at the bottom of the page.

25 This approach is consistent with Commission policy for disclosures in other media.

For example, the Commission has required fuller disclosures in print ads and a

shorter disclosure in a short television ad with a referral to another location for

more complete information. See, e.g., Nutri/System, Inc., 116 F.T.C. 1408 (1993)

(consent order requiring a shorter disclosure for 15 second television ads).

26 Web sites may display differently depending on the browser, computer screen, or

other information appliance used. Advertisers may be working with a default view,

but also evaluating different display options so that the site will be attractive and

accessible to most consumers. Considering different display options also may be

necessary to ensure that qualifying information is displayed clearly and conspicuously. Evaluating the prominence of the disclosure in relation to the rest of the ad

helps ensure that consumers are able to view the disclosure.

27 See, e.g., Kent & Spiegel Direct, Inc., 124 F.T.C. 300 (1997); Synchronal Corp.,

116 F.T.C. 1189 (1993) (consent orders requiring disclosures to be repeated

during television infomercials).
22

28 For example, the Commission specifically amended the Textile Rules requirement to disclose textile origin in print catalogs to clarify that these disclosures must be made in online catalogs as well. See 63 Fed. Reg. 7507 (Feb.

13, 1998) or http://www.ftc.gov/os/1998/9802/textile.htm for a discussion of

the amendments to the Rules and Regulations Under the Textile Fiber Products

Identification Act, 16 C.F.R. Part 303.

29 16 C.F.R. § 305.1(d).

30 16 C.F.R. §§ 305.2(m), 305.14.

31 Mail or Telephone Order Merchandise Rule, 16 C.F.R. § 435.1(b).

32 Rule Concerning Use of Prenotification Negative Option Plans, 16 C.F.R.

§ 425(a)(2).

33 Disclosure of Written Consumer Product Warranty Terms and Conditions, 16

C.F.R. § 701.3, and Pre-Sale Availability of Written Warranty Terms, 16

C.F.R. § 702.3. According to the Rule Regarding Pre-Sale Availability of

Written Warranty Terms, an alternative to making the warranty terms available

prior to purchase is for sellers to provide information about how consumers

may obtain the written warranty for free by mail. 16 C.F.R. § 702.3(c)(2).

34 16 C.F.R. § 310.6. The Telemarketing Sales Rule prohibits deceptive and

abusive telemarketing practices. Among other things, it requires that certain

information be disclosed in telemarketing calls. The scope of the Rule does not

extend to transactions that take place entirely online. The sales transaction must

involve a traditional voice telephone call. See 60 Fed. Reg. 30,406, 30,411

(June 8, 1995). In addition, in most situations, the Rule does not apply if a

consumer calls a business in response to an advertisement. However, if a

consumer calls a business in response to a direct mail advertisement, that

call is subject to the Rule.

35 The telephone call may be exempt from the Rules coverage if the direct mail

piece contains certain disclosures, such as the total cost to purchase the goods

or services.

36 Whether certain types of online ads, such as targeted banner ads or personalized solicitations on Web sites, constitute direct mail should be evaluated on a

case-by-case basis.

37 A small number of telemarketing transactions relating to specific types of

goods or services are covered by the Telemarketing Sales Rule, regardless of

the advertising method or manner in which the telemarketing calls were initiated. For example, credit repair services and advance fee loan services sold

through telemarketing are covered by the Telemarketing Sales Rule, regardless

of whether the consumer called in response to a direct mail piece, television

advertisement, or Web site. 16 C.F.R. § 310.6(e) and (f).
APPENDIX: MOCK ADS
The disclosure "imitation" needs to accompany the triggering term "pearl" so that

consumers are not misled about the type of pearls being sold. The disclosure would not

be as effective if it was separated from the word pearl or placed on a different page. The

FTC’s Guides for the Jewelry, Precious Metals, and Pewter Industries, 16 C.F.R.

§ 23.19, recognize this and advise that the disclosure "imitation" immediately precede

the word pearl. In this situation, there is no reason to evaluate proximity differently in

Internet ads than with other types of ads.

FTC FASHION JEWELRY 

 Imitation Pearl Hoop Earrings

 

 Retail Price - $45.99

 Our Low Price - $29.99

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

 

Lustrous imitation pearl hoop earrings. The highest quality imitation pearls fall

delicately from these classically styled 14K gold hoops. The perfect fashion

accessory for any occasion.
This ad contains visual cues that may indicate that more information is available. The

vertical blue bar continues "below the fold" -- the end of the screen on the monitor -- and

the text on the left column is continuous. A consumer who is already scrolling to read DJ

Blackhand’s endorsement, is also likely to see the disclosure that follows it.

 

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

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Quick DDRIP uses a special

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caching techniques, to

manipulate and speed up data

transmissions.

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enhances the gaming experience for all

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and I’m still #1 this year. Whether you’ve

got a 486 or a Pentium, QD can improve

your "see-and-react" abilities. Soon you'll

be winning all your matches."

-- D.J. Blackhand

(QuickDDRIP, Inc. has paid D.J.

Blackhand for his endorsement.)
Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --

Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download

in a fraction of the time it takes you now! Try it with

your next online video purchase!

• ENHANCED streaming audio and video quality for

live Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment -

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WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the rental.

Find your favorite pay-per-view movies on the Web -

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 CONCERT IN A CAN! Buy a VIRTUAL TICKET

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you won’t believe the difference in audio and video

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Live Concert Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
 

This ad must disclose that the diamond weights are not exact and that a 3/4 carat

diamond may weigh between .70 and .84 carats. Because of the blank space between

the textual description of the product and the disclosure, even consumers who scroll

down the page will probably think that there is no more information to view and are likely

to miss the disclosure.

 FTC FASHION JEWELRY 

 3/4 Ct. Diamond Earrings

 Retail Price 

- $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

 

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.

Diamond weights may not be exact. A 3/4 ct. diamond may weigh between .70 -

.84 carat. 
Although QuickDDRIP’s advertised price is $129.95, there are additional conditions and fees

associated with purchasing the product, including obtaining a rebate and contracting for 2 years of

QD Internet Service. The Internet Service contract itself has significant costs and conditions.

Although the details about these additional fees and conditions are described on the click through

page, their existence is properly disclosed on the same page as and adjacent to the price claim.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

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 Instant Play

ORDER NOW

Make the Internet

FUN again.

Priced At Only $129.95*

*After $200 Rebate. Requires 2 year (24 month) QD 

Internet Service contract at $19.99/month. 

Early cancellation of Internet Service will result in substantial penalties. 

You may have to pay significant telephone charges to use the Internet Service.

Click here for more information.

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200 000" by Corel Corporatio
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

 

REBATE AND INTERNET SERVICE INFORMATION

The $200 Mail-In Rebate requires that you agree to a 2 year (24 month) contract for

QD Internet service at $19.99 per month.

If you cancel your contract for QD Internet service before your 2 year membership

expires, you will be required to repay the rebate according to the following time

schedule:

- If you cancel in months 1-6, you must repay the entire $200 rebate.

- If you cancel in months 7-12, you must repay $150.

- If you cancel in months 13-24, you must repay $100.

You may incur significant telephone charges to access QD Internet service

depending on your location and your calling plan. You may visit our web site or call

1-800-QNUMBER to learn the telephone access numbers available in your area.

You must contact your local telephone company to find out any applicable charges

for these numbers.

To obtain the $200 rebate, you must send the completed required mail-in rebate

form and a copy of your dated sales receipt to the address provided on the rebate

form. The rebate form will be included with your Quick DDRIP. Allow 4-6 weeks to

receive your rebate. To be eligible for the rebate, you must agree to the QD

Internet service membership agreement and you must have a major credit card.

The $19.99 per month service charge will be billed to your credit card. 

This offer is valid only in the United States. All customers must be 18 years or

older.

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
The disclosure "imitation" needs to accompany the triggering term "pearl" so that

consumers are not misled about the type of pearls being sold. It is not difficult to

incorporate this one word disclosure in the text of this ad.

FTC FASHION JEWELRY 

 Imitation Pearl Hoop Earrings

 

 Retail Price - $45.99

 Our Low Price - $29.99

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

 

Lustrous imitation pearl hoop earrings. The highest quality imitation pearls fall

delicately from these classically styled 14K gold hoops. The perfect fashion

accessory for any occasion.
 

The hyperlink incorporates part of the required disclosure -- that diamond weights are

not exact -- and indicates the information (about weight ranges) that the link leads to.

The label notifies consumers about the type and importance of the information

accessible by this link.

 FTC FASHION JEWELRY 

Diamond Weights are Not Exact

Click here for Weight Ranges.

 3/4 Ct. Diamond Earrings

 Retail Price - $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.
Click-through page

 FTC FASHION JEWELRY 

JEWELRY INFORMATION

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5

gram). A carat is divided into 100 points. Therefore, a .25 carat diamond may

be referred to as a 25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we

sell our diamonds in size ranges. The following chart shows the range of weight

for each size diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
 

This ad must disclose that the diamond weights are not exact and that a 3/4 carat

diamond may weigh between .70 and .84 carats. Underlining the "3/4 carat" may

indicate that it is a hyperlink, but it does not identify the relevance of the information it

leads to. Consumers may expect to find additional information about "carats" or

diamond weights generally, but not necessarily qualifying information.

 FTC FASHION JEWELRY 

 3/4 Ct. Diamond Earrings

 

 Retail Price - $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.
Click-through page

 FTC FASHION JEWELRY 

JEWELRY INFORMATION

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5

gram). A carat is divided into 100 points. Therefore, a .25 carat diamond may

be referred to as a 25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we

sell our diamonds in size ranges. The following chart shows the range of weight

for each size diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
This ad must disclose that DJ Blackhand was paid for his endorsement. The name "DJ

Blackhand" is underlined to indicate that it is a hyperlink. Consumers may have different

understandings about what this link leads to -- for example, biographical information about

DJ or his picture -- and may see no reason to click on the link.

 

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

 Record

 Instant Play

ORDER NOW

Make the Internet

FUN again.

Quick DDRIP is the REVOLUTIONARY

device that easily hooks up to your home

computer and phone line.

Quick DDRIP uses a special processing

chip, and proprietary compression,

decoding and caching techniques, to

manipulate and speed up data

transmissions.

"QD’s superior real-time

performance enhances the

gaming experience for all levels of

players. After I installed QD, it

didn’t take long for me to win my

first Wrath of Thor national

championship - and I’m still #1 this

year. Whether you’ve got a 486 or

a Pentium, QD can improve your

"see-and-react" abilities. Soon

you'll be winning all your

matches."

-- D.J. Blackhand
Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --

Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download

in a fraction of the time it takes you now! Try it with

your next online video purchase!

• ENHANCED streaming audio and video quality for

live Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment -

All From Home

WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the rental.

Find your favorite pay-per-view movies on the Web -

and let QD do the rest. With QD, streaming

pay-per-view movies start playing instantaneously --

Quick DDRIP’s built in decoder sees to that!

Pay-Per-View Movie

Releases

 CONCERT IN A CAN! Buy a VIRTUAL TICKET

and go on a LIVE WEB CONCERT TOUR with the

best musicians without ever leaving your home! And

you won’t believe the difference in audio and video

quality over existing technology! Whether you are a

movie buff or an audiophile, Quick DDRIP is

technology made for you.

Live Concert Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Important Information About D.J. Blackhand's 

Endorsement of Quick DDRIP

QuickDDRIP, Inc. has paid D.J. Blackhand for his endorsement.
Because many of the experiences described in the testimonials may not be typical of what

consumers generally will experience with the product, a disclosure regarding this fact is

needed. The hyperlink, "Disclaimer" does not indicate that the testimonial claims are

qualified and does not indicate what consumers can expect to learn by clicking on it.

 Quick DDRIP 

Stop the Waiting - Get in the Game

 Home How QD Works What Customers Say Experts Privacy Policy 

SEE WHAT OUR SATISFIED CUSTOMERS HAVE TO SAY

ABOUT QUICK DDRIP 

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds are up by

90-95%. Now, I’m downloading from the Web in much less than 1/16 the time,

which is important in my line of work. The install was flawless and now, so are my

downloads. Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^) 

"My elderly father has had trouble reading ever since cataract surgery two years

ago. I’ve tried sending him books on tape, but it was always a cumbersome

process and I was never sure if he’d like my selections. We tried downloading

audio books from the Internet, but the process took FOREVER. Last month I sent

him the Quick DDRIP and he’s never been happier. He has instant (well, about 10

to 15 minutes as opposed to an hour or more before) access to digital quality

sound recordings of all his favorites, and new releases too. Now Mom is

threatening to move his LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI 

"WOW! With Quick DDRIP I can watch any pay-per-view movie anytime I want

and the quality is great. When I tried to watch a pay-per-view movie streamed over

the Internet before, I experienced lost or delayed movie frames. No more. Now it’s

just like watching my own personal screening. And whatever movie I choose starts

playing in seconds. The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA 

"Quick DDRIP is amazing! I converted the home video of my son’s birth to a digital

file and sent it via email to all the relatives. Almost all of them had problems

downloading the attached video file. But my Mom has a QD unit. Thanks to QD,

she was able to download the whole 9 hours of my son’s delivery in less than a

half hour, and then watch it just as if she was there. And we’ve got more video files

on the way - baby’s first smile, his first bath, his first visit from grandma, his first

trip to the doctor, his first bottle from daddy, . . . ."
-- Sam and Nancy, new parents in Tallahassee, FL 

"Where can I invest? I’ve been sold since I saw a demonstration at the INTERNET

NOW Conference. I bought one as soon as they came out and it more than lives

up to the hype. No more problems with stop and start video feeds and I’ve never

been "disconnected" from the Internet during a live event because of slow

transmission speeds. Heck, I’ve never been disconnected during a download of a

movie for that matter - which may be because movies download 8 times faster with

Quick DDRIP than they did before." 

-- Hugo P, Las Vegas, NV 

"WHAT A CONCEPT! I’ve seen a lot of computer products, software and hardware

in my day and the Quick DDRIP really delivers. I frequently listen to Blues radio

stations on the Internet and have always had problems with fidelity and distortion.

Not any more -- with QD’s higher speeds, I get hi-fidelity, Dolby-quality sound at

analog prices. And it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO 

"Quick DDRIP is a life saver - its real time access to football games on the Internet

is incredible. No more of those irritating jerky delays when I’m watching my

favorite games (you know, where the missing frame is the part showing the

completion of the pass) - and the picture is sharp enough to tell if the running

back’s foot was out of bounds when he caught that long pass (no instant replay

needed!!) And the best part is I’m no longer limited to watching East Coast games

broadcast on TV - but can keep up with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD 

"Quick DDRIP outperforms the other equipment on the market. I listen to a lot of

high fidelity symphonic recordings and I must say that Quick DDRIP really lives up

to its reputation. I can download performances of the Berlin Symphony Orchestra

off the Internet in just a few minutes and the sound quality is unbeatable. Without

Quick DDRIP, I just didn’t have the patience to wait for the entire symphony to

download. Now there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL 
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Important Information About Quick DDRIP's Performance

Speed Improvements and Audio/Video Quality will vary depending on your

individual computer equipment and phone line conditions. You should not expect

to achieve results as good as those described in the testimonials.
Although this hyperlink indicates that more information is available, it does not indicate

the importance of this information or the fact that it is related to the diamond weight.

Consumers may believe, for example, that this link takes them to shipping and ordering

information, rather than information about the diamond’s weight.

 

 FTC FASHION JEWELRY

Click here for more details

on the jewelry item you are purchasing.

 3/4 Ct. Diamond Earrings

 Retail Price - $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.
Click-through page

 FTC FASHION JEWELRY 

JEWELRY INFORMATION

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5

gram). A carat is divided into 100 points. Therefore, a .25 carat diamond may

be referred to as a 25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we

sell our diamonds in size ranges. The following chart shows the range of weight

for each size diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
This ad must disclose that DJ Blackhand was paid for his endorsement. The

asterisk next to DJ's name does not suggest the importance and relevance of

information that the link leads to. Because many consumers may easily miss the

asterisk hyperlink, it is not clear and conspicuous.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

 Record

 Instant Play

ORDER NOW

Make the Internet

FUN again.

Quick DDRIP is the REVOLUTIONARY

device that easily hooks up to your home

computer and phone line.

Quick DDRIP uses a special processing

chip, and proprietary compression,

decoding and caching techniques, to

manipulate and speed up data

transmissions.

"QD’s superior real-time

performance enhances the

gaming experience for all levels of

players. After I installed QD, it

didn’t take long for me to win my

first Wrath of Thor national

championship - and I’m still #1 this

year. Whether you’ve got a 486 or

a Pentium, QD can improve your

"see-and-react" abilities. Soon

you'll be winning all your

matches."

-- D.J. Blackhand*
Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --

Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download

in a fraction of the time it takes you now! Try it with

your next online video purchase!

• ENHANCED streaming audio and video quality for

live Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment -

All From Home

WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the rental. Find

your favorite pay-per-view movies on the Web - and let

QD do the rest. With QD, streaming pay-per-view movies

start playing instantaneously -- Quick DDRIP’s built in

decoder sees to that!

Pay-Per-View Movie

Releases

 CONCERT IN A CAN! Buy a VIRTUAL TICKET and

go on a LIVE WEB CONCERT TOUR with the best

musicians without ever leaving your home! And you won’t

believe the difference in audio and video quality over

existing technology! Whether you are a movie buff or an

audiophile, Quick DDRIP is technology made for you. Live Concert Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Important Information About D.J. Blackhand's 

Endorsement of Quick DDRIP

QuickDDRIP, Inc. has paid D.J. Blackhand for his endorsement.
This ad must disclose that DJ Blackhand was paid for his endorsement. It is not

clear that the red star next to DJ’s name is a hyperlink. It is also confusing because

the same type of star is used on another part of the page solely as a graphic.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

 Record

 Instant Play

ORDER NOW

Make the Internet

FUN again.

Quick DDRIP is the REVOLUTIONARY

device that easily hooks up to your home

computer and phone line.

Quick DDRIP uses a special processing

chip, and proprietary compression,

decoding and caching techniques, to

manipulate and speed up data

transmissions.

"QD’s superior real-time

performance enhances the

gaming experience for all levels of

players. After I installed QD, it

didn’t take long for me to win my

first Wrath of Thor national

championship - and I’m still #1 this

year. Whether you’ve got a 486 or

a Pentium, QD can improve your

"see-and-react" abilities. Soon

you'll be winning all your

matches."

-- D.J. Blackhand 
Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --

Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download

in a fraction of the time it takes you now! Try it with

your next online video purchase!

• ENHANCED streaming audio and video quality for

live Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment -

All From Home

WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the rental. Find your

favorite pay-per-view movies on the Web - and let QD do the

rest. With QD, streaming pay-per-view movies start playing

instantaneously -- Quick DDRIP’s built in decoder sees to

that!

Pay-Per-View Movie

Releases

 CONCERT IN A CAN! Buy a VIRTUAL TICKET and

go on a LIVE WEB CONCERT TOUR with the best

musicians without ever leaving your home! And you won’t

believe the difference in audio and video quality over existing

technology! Whether you are a movie buff or an audiophile,

Quick DDRIP is technology made for you. Live Concert Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Important Information About D.J. Blackhand's 

Endorsement of Quick DDRIP

QuickDDRIP, Inc. has paid D.J. Blackhand for his endorsement.
 

The descriptive hyperlink in this ad is placed adjacent to the 3/4 carat diamond weight

claim. This helps to ensure that consumers notice the link and relate it to the

testimonial.

 FTC FASHION JEWELRY 

Diamond Weights are Not Exact

Click here for Weight Ranges.

 3/4 Ct. Diamond Earrings

 Retail Price - $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.
Click-through page

 FTC FASHION JEWELRY 

JEWELRY INFORMATION

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5

gram). A carat is divided into 100 points. Therefore, a .25 carat diamond may

be referred to as a 25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we

sell our diamonds in size ranges. The following chart shows the range of weight

for each size diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
This hyperlink may be easily missed by consumers because it is separated from the 3/4

carat claim and because it appears below blank space that suggests that there is no

further information to view.

 

 FTC FASHION JEWELRY 

 3/4 Ct. Diamond Earrings

 

 Retail Price - $1365.00

 Our Low Price - $ 975.00

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington

DC diamond mines. Set in a stylish six-prong setting of 14 karat gold. The

perfect fashion accessory for that special occasion.

Diamond Weights Are Not Exact. Click Here for Weight Ranges.
Click-through page

 FTC FASHION JEWELRY 

JEWELRY INFORMATION

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5

gram). A carat is divided into 100 points. Therefore, a .25 carat diamond may

be referred to as a 25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we

sell our diamonds in size ranges. The following chart shows the range of weight

for each size diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
The disclosure on the click-through page -- concerning DJ Blackhand’s endorsement -- is

included in the middle of unrelated text and large amounts of graphics. It is not obvious to

a consumer who clicked to this page where the disclosure is and its relevance.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

 Record

 Instant Play

ORDER NOW

Make the Internet

FUN again.

Quick DDRIP is the REVOLUTIONARY

device that easily hooks up to your home

computer and phone line.

Quick DDRIP uses a special processing

chip, and proprietary compression,

decoding and caching techniques, to

manipulate and speed up data

transmissions.

"QD’s superior real-time

performance enhances the gaming

experience for all levels of players.

After I installed QD, it didn’t take

long for me to win my first Wrath of

Thor national championship - and

I’m still #1 this year. Whether

you’ve got a 486 or a Pentium, QD

can improve your "see-and-react"

abilities. Soon you'll be winning all

your matches."

--D.J. Blackhand

Paid Endorsement

Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --
Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download in a

fraction of the time it takes you now! Try it with your next

online video purchase!

• ENHANCED streaming audio and video quality for live

Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment

All From Home

WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the rental. 

Find your favorite pay-per-view movies on the Web -

and let QD do the rest. With QD, streaming

pay-per-view movies start playing instantaneously --

Quick DDRIP’s built in decoder sees to that! Pay-Per-View Movie

Releases

 CONCERT IN A CAN! Buy a VIRTUAL TICKET

and go on a LIVE WEB CONCERT TOUR with the best

musicians without ever leaving your home! And you

won’t believe the difference in audio and video quality

over existing technology! Whether you are a movie buff

or an audiophile, Quick DDRIP is technology made for

you.

Live Concert Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Priced at just 

 $129.95 

+ Shipping and Handling

($9.95, 2 days shipping, $.4.95 for 5 days shipping)

 HOT HOT HOT!!! 

Over 40,000 satisfied customers - and the numbers keep growing! 
* D.J. Blackhand has been involved in the gaming world since he was 12 years

old. After purchasing Quick DDRIP, he rapidly ascended the Wrath of Thor

tournament levels to become the intergalactic champion several years running.

D.J. loves all kinds of games and plays several hours daily. His interests also

include playing with his Briard dog, Thunder, and running on the beach.

 QuickDDRIP, Inc. has paid D.J. Blackhand for his endorsement.

Reviewers in Web Surfer Pro, Families Online, and 

Moviemag.com are unanimous in their praise of QD:

"Easy setup, good performance, reasonable price - what more

could you want?" Moviemag.com Click here to read review

"Quick DDRIP is truly revolutionary. It will turn the PC into the

Family Entertainment Center" Families Online (February 21,

1999) Click here to read review

"A great alternative to waiting for hi-speed phone or cable Internet

services to reach your neighborhood." 

Web Surfer Pro (March 1999) Click here to read review
 

The hyperlink on this page takes consumers to the top of the click-through page. The

disclosure about diamond weights is provided in the middle of the page and consumers

must scroll down to find this information. The hyperlink should bring consumers directly

to the disclosure.

 FTC FASHION JEWELRY 

Diamond Weights are Not Exact

Click here for Weight Ranges.

 3/4 Ct. Diamond Earrings

 Retail Price - $1365.00

 Our Low Price - $ 975.00 

Item#: GRTDEAL

Shipping Weight: 0.1 Lbs.

 

Classic diamond solitaire earrings. Our sparkling round-cut diamonds are

colorless and have only slight inclusions. Straight from the FTC's Washington DC

diamond mines. Set in a stylish six-prong setting of 14 karat gold. The perfect

fashion accessory for that special occasion.
Click-through page

FTC FASHION JEWELRY

JEWELRY INFORMATION 

Colored Gemstones Pearls Diamonds

Colored Gemstones

Colored gemstones may be treated to enhance their color or durability. These treatments

may not be permanent and the effects of some treatments may lessen or change over time. 

You need to take special care of treated gemstones. Do not use ultrasonic cleaners or

harsh solvents to clean your gemstone. Also, do not expose your gemstone to sudden,

extreme changes in temperature.

Our gemstone rings are available in the standard sizes, 5 through 8. For an additional

charge of $2, you may order rings in other sizes. Please contact a customer service

representative to place this special order.

Pearls

Natural or real pearls are made by oysters and other mollusks. Cultured pearls also are

grown by mollusks, but with human intervention; that is, an irritant introduced into the

shells causes a pearl to grow. Imitation pearls are man-made with glass, plastic, or organic

materials. Because natural pearls are very rare, most pearls used in jewelry are either

cultured or imitation pearls. 

To clean your pearls, simply wipe them with a soft, dry cloth. You should not use any

commercial cleaners for your pearls.

Diamonds

Diamond weights are stated in "carats." A carat is equal to 200 milligrams (or 1/5 gram). A

carat is divided into 100 points. Therefore, a .25 carat diamond may be referred to as a
25-point diamond. 

Diamond weights may not be exact. For us to offer you these low FTC prices, we sell our

diamonds in size ranges. The following chart shows the range of weight for each size

diamond.

1/10 ct. can range from .09 to .11 carat

1/8 ct. can be .11 to .13 carat

1/7 ct. can be .13 to .15 carat

1/6 ct. can be .15 to .17 carat

1/5 ct. can be .18 to .22 carat

1/4 ct. can be .21 to .29 carat

1/3 ct. can be .30 to .36 carat

1⁄2 ct. can be .45 to .59 carat

5/8 ct. can be .59 to .67 carat

3/4 ct. can be .70 to .84 carat

7/8 ct. can be .85 to .95 carat

1 ct. can be .95 to 1.10 carat

1 1/4 ct. can be 1.20 to 1.29 carat

1 1⁄2 ct. can be 1.45 to 1.55 carat

1 3/4 ct. can be 1.70 to 1.82 carat

2 ct can be 1.95 to 2.05 carat
This disclosure appears as scrolling text when viewed with one browser, Microsoft

Explorer, but it may not appear when viewed with another browser, Netscape.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

 

Hi-speed

Internet can

now reach

YOUR door.

 Quick DDRIP

 Download

 Decode

 Record

 Instant Play

ORDER NOW

Make the Internet

FUN again.

Quick DDRIP is the REVOLUTIONARY

device that easily hooks up to your home

computer and phone line.

Quick DDRIP uses a special processing

chip, and proprietary compression, decoding

and caching techniques, to manipulate and

speed up data transmissions.

QD’s superior real-time

performance enhances the gaming

experience for all levels of players.

After I installed QD, it didn’t take

long for me to win my first Wrath of

Thor national championship - and

I’m still #1 this year. Whether

you’ve got a 486 or a Pentium, QD

can improve your "see-and-react"

abilities. Soon you'll be winning all

your matches."

--D.J. Blackhand

QuickDDRIP, Inc.

has paid D.J.

Blackhand for his

endorsement. 
Quick DDRIP Gives You Unparalleled

Internet Performance

• NO DELAY waiting for images to load --

Graphics-intensive Web pages load FAST!

• SPEEDY file downloads -- even huge files download in a

fraction of the time it takes you now! Try it with your next

online video purchase!

• ENHANCED streaming audio and video quality for live

Web events!

• UNBELIEVABLY FAST "action" in online games!

• FAST DELIVERY of graphics for FANTASTIC virtual

reality experiences!

Enjoy The Best Entertainment -

All From Home

WATCH A FULL-LENGTH MOVIE ONLINE!

No more waiting in line for a ticket or for the

rental. Find your favorite pay-per-view movies on

the Web - and let QD do the rest. With QD,

streaming pay-per-view movies start playing

instantaneously -- Quick DDRIP’s built in

decoder sees to that!

Pay-Per-View Movie

Releases

 CONCERT IN A CAN! Buy a VIRTUAL

TICKET and go on a LIVE WEB CONCERT

TOUR with the best musicians without ever

leaving your home! And you won’t believe the

difference in audio and video quality over existing

technology! Whether you are a movie buff or an

audiophile, Quick DDRIP is technology made for

you.

Live Concert

Webcasters

 Home How QD Works What Customers Say Experts Privacy Policy 

Some images are from "Corel Gallery Magic 200,000" by Corel Corporation
 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy

SEE WHAT OUR SATISFIED

CUSTOMERS HAVE TO SAY ABOUT

QUICK DDRIP

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds

are up by 90-95%. Now, I’m downloading from the Web in much less

than 1/16 the time, which is important in my line of work. The install was

flawless and now, so are my downloads. Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^)

"My elderly father has had trouble reading ever since cataract surgery

two years ago. I’ve tried sending him books on tape, but it was always a

cumbersome process and I was never sure if he’d like my selections.

We tried downloading audio books from the Internet, but the process

took FOREVER. Last month I sent him the Quick DDRIP and he’s

never been happier. He has instant (well, about 10 to 15 minutes as

opposed to an hour or more before) access to digital quality sound

recordings of all his favorites, and new releases too. Now Mom is

threatening to move his LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI

"WOW! With Quick DDRIP I can watch any pay-per-view movie

anytime I want and the quality is great. When I tried to watch a

pay-per-view movie streamed over the Internet before, I experienced

lost or delayed movie frames. No more. Now it’s just like watching my

own personal screening. And whatever movie I choose starts playing in

seconds. The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA

"Quick DDRIP is amazing! I converted the home video of my son’s

birth to a digital file and sent it via email to all the relatives. Almost all of

them had problems downloading the attached video file. But my Mom

has a QD unit. Thanks to QD, she was able to download the whole 9

hours of my son’s delivery in less than a half hour, and then watch it

just as if she was there. And we’ve got more video files on the way -

baby’s first smile, his first bath, his first visit from grandma, his first trip

to the doctor, his first bottle from daddy, . . . ."

-- Sam and Nancy, new parents in Tallahassee, FL

"Where can I invest? I’ve been sold since I saw a demonstration at the

INTERNET NOW Conference. I bought one as soon as they came out

and it more than lives up to the hype. No more problems with stop and

start video feeds and I’ve never been "disconnected" from the Internet

during a live event because of slow transmission speeds. Heck, I’ve

never been disconnected during a download of a movie for that matter

- which may be because movies download 8 times faster with Quick
DDRIP than they did before." 

-- Hugo P, Las Vegas, NV

"WHAT A CONCEPT! I’ve seen a lot of computer products, software

and hardware in my day and the Quick DDRIP really delivers. I

frequently listen to Blues radio stations on the Internet and have always

had problems with fidelity and distortion. Not any more -- with QD’s

higher speeds, I get hi-fidelity, Dolby-quality sound at analog prices.

And it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO

"Quick DDRIP is a life saver - its real time access to football games on

the Internet is incredible. No more of those irritating jerky delays when

I’m watching my favorite games (you know, where the missing frame is

the part showing the completion of the pass) - and the picture is sharp

enough to tell if the running back’s foot was out of bounds when he

caught that long pass (no instant replay needed!!) And the best part is

I’m no longer limited to watching East Coast games broadcast on TV -

but can keep up with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD

"Quick DDRIP outperforms the other equipment on the market. I listen

to a lot of high fidelity symphonic recordings and I must say that Quick

DDRIP really lives up to its reputation. I can download performances of

the Berlin Symphony Orchestra off the Internet in just a few minutes

and the sound quality is unbeatable. Without Quick DDRIP, I just didn’t

have the patience to wait for the entire symphony to download. Now

there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL
Quick DDRIP

Stop the Waiting - 

Get in the Game

Important Information 

About 

Quick DDRIP's

Performance

Speed Improvements and

Audio/Video Quality will vary

depending on your individual

computer equipment and phone

line conditions. You should not

expect to achieve results as good

as those described.
The pop-up screen that contains the disclosure appears when you first access this page. If

you click on another portion of the page, the pop-up window minimizes and disappears

from the display area. The pop-up screen may not reappear if you re-access this page.

Consumers may miss the disclosure, especially if they do not understand how to display a

minimized pop-up window (by clicking on its button at the bottom of the screen).

 Quick DDRIP 

Stop the Waiting - Get in the Game

 Home How QD Works What Customers Say Experts Privacy Policy 

SEE WHAT OUR SATISFIED CUSTOMERS HAVE TO SAY

ABOUT QUICK DDRIP 

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds are up by

90-95%. Now, I’m downloading from the Web in much less than 1/16 the time,

which is important in my line of work. The install was flawless and now, so are my

downloads. Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^) 

"My elderly father has had trouble reading ever since cataract surgery two years

ago. I’ve tried sending him books on tape, but it was always a cumbersome process

and I was never sure if he’d like my selections. We tried downloading audio books

from the Internet, but the process took FOREVER. Last month I sent him the Quick

DDRIP and he’s never been happier. He has instant (well, about 10 to 15 minutes

as opposed to an hour or more before) access to digital quality sound recordings of

all his favorites, and new releases too. Now Mom is threatening to move his

LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI

"WOW! With Quick DDRIP I can watch any pay-per-view movie I want any time I

want and the quality is great. When I tried to watch a pay-per-view movie streamed

over the Internet before, I experienced lost or delayed movie frames. No more. Now

it’s just like watching my own personal screening. And whatever movie I choose

starts playing in seconds. The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA

"Quick DDRIP is amazing! I converted the home video of my son’s birth to a digital

file and sent it via email to all the relatives. Almost all of them had problems

downloading the attached video file. But my Mom has a QD unit. Thanks to QD, she

was able to download the whole 9 hours of my son’s delivery in less than a half

hour, and then watch it just as if she was there. And we’ve got more video files on

the way - baby’s first smile, his first bath, his first visit from grandma, his first trip to

the doctor, his first bottle from daddy, . . . ."

-- Sam and Nancy, new parents in Tallahassee, FL 
"Where can I invest? I’ve been sold since I saw a demonstration at the INTERNET

NOW Conference. I bought one as soon as they came out and it more than lives up

to the hype. No more problems with stop and start video feeds and I’ve never been

"disconnected" from the Internet during a live event because of slow transmission

speeds. Heck, I’ve never been disconnected during a download of a movie for that

matter - which may be because movies download 8 times faster with Quick DDRIP

than they did before." 

-- Hugo P, Las Vegas, NV

"WHAT A CONCEPT! I’ve seen a lot of computer products, software and hardware

in my day and the Quick DDRIP really delivers. I frequently listen to Blues radio

stations on the Internet and have always had problems with fidelity and distortion.

Not any more -- with QD’s higher speeds, I get hi-fidelity, Dolby-quality sound at

analog prices. And it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO 

"Quick DDRIP is a life saver - its real time access to football games on the Internet

is incredible. No more of those irritating jerky delays when I’m watching my

favorite games (you know, where the missing frame is the part showing the

completion of the pass) - and the picture is sharp enough to tell if the running

back’s foot was out of bounds when he caught that long pass (no instant replay

needed!!) And the best part is I’m no longer limited to watching East Coast games

broadcast on TV - but can keep up with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD

"Quick DDRIP outperforms the other equipment on the market. I listen to a lot of

high fidelity symphonic recordings and I must say that Quick DDRIP really lives up

to its reputation. I can download performances of the Berlin Symphony Orchestra

off the Internet in just a few minutes and the sound quality is unbeatable. Without

Quick DDRIP, I just didn’t have the patience to wait for the entire symphony to

download. Now there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL
QuickDDRIP - POP-UP

Important Information About Quick DDRIP's Performance:

Speed Improvements and Audio/Video Quality will vary

depending on your individual computer equipment and phone line

conditions. You should not expect to achieve results as good as

those described in the testimonials.
Because many of the experiences described in the testimonials may not be typical of what

consumers generally will experience with the product, a disclosure regarding this fact is

needed. Consumers visiting this site might read the testimonials, reach a conclusion about

the product based on them, click on and review numerous other pages on the site, and

then finally decide to buy the product. They therefore might not relate a disclosure placed

on the ordering page to the claims on the testimonial page.

 Quick DDRIP 

Stop the Waiting - Get in the Game

 Home How QD Works What Customers Say Experts Privacy Policy 

SEE WHAT OUR SATISFIED CUSTOMERS HAVE TO SAY

ABOUT QUICK DDRIP

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds are up by

90-95%. Now, I’m downloading from the Web in much less than 1/16 the time, which is

important in my line of work. The install was flawless and now, so are my downloads.

Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^) 

"My elderly father has had trouble reading ever since cataract surgery two years ago.

I’ve tried sending him books on tape, but it was always a cumbersome process and I

was never sure if he’d like my selections. We tried downloading audio books from the

Internet, but the process took FOREVER. Last month I sent him the Quick DDRIP and

he’s never been happier. He has instant (well, about 10 to 15 minutes as opposed to an

hour or more before) access to digital quality sound recordings of all his favorites, and

new releases too. Now Mom is threatening to move his LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI 

"WOW! With Quick DDRIP I can watch any pay-per-view movie anytime I want and the

quality is great. When I tried to watch a pay-per-view movie streamed over the Internet

before, I experienced lost or delayed movie frames. No more. Now it’s just like watching

my own personal screening. And whatever movie I choose starts playing in seconds.

The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA

"Quick DDRIP is amazing! I converted the home video of my son’s birth to a digital file

and sent it via email to all the relatives. Almost all of them had problems downloading

the attached video file. But my Mom has a QD unit. Thanks to QD, she was able to

download the whole 9 hours of my son’s delivery in less than a half hour, and then

watch it just as if she was there. And we’ve got more video files on the way - baby’s first

smile, his first bath, his first visit from grandma, his first trip to the doctor, his first bottle
from daddy, . . . ."

-- Sam and Nancy, new parents in Tallahassee, FL 

"Where can I invest? I’ve been sold since I saw a demonstration at the INTERNET

NOW Conference. I bought one as soon as they came out and it more than lives up to

the hype. No more problems with stop and start video feeds and I’ve never been

"disconnected" from the Internet during a live event because of slow transmission

speeds. Heck, I’ve never been disconnected during a download of a movie for that

matter - which may be because movies download 8 times faster with Quick DDRIP than

they did before." 

-- Hugo P, Las Vegas, NV 

"WHAT A CONCEPT! I’ve seen a lot of computer products, software and hardware in

my day and the Quick DDRIP really delivers. I frequently listen to Blues radio stations

on the Internet and have always had problems with fidelity and distortion. Not any more

-- with QD’s higher speeds, I get hi-fidelity, Dolby-quality sound at analog prices. And

it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO 

"Quick DDRIP is a life saver - its real time access to football games on the Internet is

incredible. No more of those irritating jerky delays when I’m watching my favorite

games (you know, where the missing frame is the part showing the completion of the

pass) - and the picture is sharp enough to tell if the running back’s foot was out of

bounds when he caught that long pass (no instant replay needed!!) And the best part is

I’m no longer limited to watching East Coast games broadcast on TV - but can keep up

with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD 

"Quick DDRIP outperforms the other equipment on the market. I listen to a lot of high

fidelity symphonic recordings and I must say that Quick DDRIP really lives up to its

reputation. I can download performances of the Berlin Symphony Orchestra off the

Internet in just a few minutes and the sound quality is unbeatable. Without Quick

DDRIP, I just didn’t have the patience to wait for the entire symphony to download. Now

there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL 
Click-through page

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Please Note: Speed Improvements and Audio/Video Quality will vary depending on

your individual computer equipment and phone line conditions. You should not

expect to achieve results as good as those described in the testimonials.

Order Form

Name: 

Address:

Address2:

City:

State:

Zip Code:

Telephone

Home:

Telephone

Work:

Quantity:

Price: $

Tax:

Total Price: $
The banner ad indicates that there are shipping and handling costs associated with

receiving the "free" flowers. The actual costs are described on the click-through page.

The disclosure in this ad is placed in blue text, which contrasts with the background and

helps make it stand out.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy

SEE WHAT OUR SATISFIED CUSTOMERS HAVE TO SAY

ABOUT QUICK DDRIP *

* Speed Improvements and Audio/Video Quality will vary depending on your

individual computer equipment and phone line conditions. You should not expect to

achieve results as good as those described.

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds are up by

90-95%. Now, I’m downloading from the Web in much less than 1/16 the time,

which is important in my line of work. The install was flawless and now, so are my

downloads. Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^)

"My elderly father has had trouble reading ever since cataract surgery two years

ago. I’ve tried sending him books on tape, but it was always a cumbersome

process and I was never sure if he’d like my selections. We tried downloading

audio books from the Internet, but the process took FOREVER. Last month I sent

him the Quick DDRIP and he’s never been happier. He has instant (well, about 10

to 15 minutes as opposed to an hour or more before) access to digital quality

sound recordings of all his favorites, and new releases too. Now Mom is

threatening to move his LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI

"WOW! With Quick DDRIP I can watch any pay-per-view movie anytime I want

and the quality is great. When I tried to watch a pay-per-view movie streamed

over the Internet before, I experienced lost or delayed movie frames. No more.

Now it’s just like watching my own personal screening. And whatever movie I

choose starts playing in seconds. The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA

"Quick DDRIP is amazing! I converted the home video of my son’s birth to a digital

file and sent it via email to all the relatives. Almost all of them had problems

downloading the attached video file. But my Mom has a QD unit. Thanks to QD,

she was able to download the whole 9 hours of my son’s delivery in less than a

half hour, and then watch it just as if she was there. And we’ve got more video files

on the way - baby’s first smile, his first bath, his first visit from grandma, his first

trip to the doctor, his first bottle from daddy, . . . ."
-- Sam and Nancy, new parents in Tallahassee, FL

"Where can I invest? I’ve been sold since I saw a demonstration at the INTERNET

NOW Conference. I bought one as soon as they came out and it more than lives

up to the hype. No more problems with stop and start video feeds and I’ve never

been "disconnected" from the Internet during a live event because of slow

transmission speeds. Heck, I’ve never been disconnected during a download of a

movie for that matter - which may be because movies download 8 times faster with

Quick DDRIP than they did before." 

-- Hugo P, Las Vegas, NV

"WHAT A CONCEPT! I’ve seen a lot of computer products, software and hardware

in my day and the Quick DDRIP really delivers. I frequently listen to Blues radio

stations on the Internet and have always had problems with fidelity and distortion.

Not any more -- with QD’s higher speeds, I get hi-fidelity, Dolby-quality sound at

analog prices. And it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO

"Quick DDRIP is a life saver - its real time access to football games on the

Internet is incredible. No more of those irritating jerky delays when I’m watching

my favorite games (you know, where the missing frame is the part showing the

completion of the pass) - and the picture is sharp enough to tell if the running

back’s foot was out of bounds when he caught that long pass (no instant replay

needed!!) And the best part is I’m no longer limited to watching East Coast games

broadcast on TV - but can keep up with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD

"Quick DDRIP outperforms the other equipment on the market. I listen to a lot of

high fidelity symphonic recordings and I must say that Quick DDRIP really lives up

to its reputation. I can download performances of the Berlin Symphony Orchestra

off the Internet in just a few minutes and the sound quality is unbeatable. Without

Quick DDRIP, I just didn’t have the patience to wait for the entire symphony to

download. Now there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL
The disclosure in this ad is placed in grey text, which blends in with the background and is

hard to read. The disclosure is not prominent and is therefore easy to miss.

 Quick DDRIP 

Stop the Waiting - Get in the Game

 Home How QD Works What Customers Say Experts Privacy Policy 

SEE WHAT OUR SATISFIED CUSTOMERS HAVE TO SAY

ABOUT QUICK DDRIP *

* Speed Improvements and Audio/Video Quality will vary depending on your individual

computer equipment and phone line conditions. You should not expect to achieve results as

good as those described.

"This product is AWESOME!!!!!!!!!!!!!! I like the Internet again. Speeds are up by

90-95%. Now, I’m downloading from the Web in much less than 1/16 the time,

which is important in my line of work. The install was flawless and now, so are my

downloads. Thanks Quick DDRIP!" 

– AlphaGeek, Silicon Alley ;^)

"My elderly father has had trouble reading ever since cataract surgery two years

ago. I’ve tried sending him books on tape, but it was always a cumbersome

process and I was never sure if he’d like my selections. We tried downloading

audio books from the Internet, but the process took FOREVER. Last month I sent

him the Quick DDRIP and he’s never been happier. He has instant (well, about 10

to 15 minutes as opposed to an hour or more before) access to digital quality

sound recordings of all his favorites, and new releases too. Now Mom is

threatening to move his LazyBoy to the PC." 

-- Evelyn M., concerned daughter in Detroit, MI

"WOW! With Quick DDRIP I can watch any pay-per-view movie anytime I want

and the quality is great. When I tried to watch a pay-per-view movie streamed

over the Internet before, I experienced lost or delayed movie frames. No more.

Now it’s just like watching my own personal screening. And whatever movie I

choose starts playing in seconds. The convenience and quality can’t be beat." 

-- Joe H., Movie Buff in Dubuque, IA

"Quick DDRIP is amazing! I converted the home video of my son’s birth to a digital

file and sent it via email to all the relatives. Almost all of them had problems

downloading the attached video file. But my Mom has a QD unit. Thanks to QD,

she was able to download the whole 9 hours of my son’s delivery in less than a

half hour, and then watch it just as if she was there. And we’ve got more video files

on the way - baby’s first smile, his first bath, his first visit from grandma, his first

trip to the doctor, his first bottle from daddy, . . . ."

-- Sam and Nancy, new parents in Tallahassee, FL
"Where can I invest? I’ve been sold since I saw a demonstration at the INTERNET

NOW Conference. I bought one as soon as they came out and it more than lives

up to the hype. No more problems with stop and start video feeds and I’ve never

been "disconnected" from the Internet during a live event because of slow

transmission speeds. Heck, I’ve never been disconnected during a download of a

movie for that matter - which may be because movies download 8 times faster with

Quick DDRIP than they did before." 

-- Hugo P, Las Vegas, NV

"WHAT A CONCEPT! I’ve seen a lot of computer products, software and hardware

in my day and the Quick DDRIP really delivers. I frequently listen to Blues radio

stations on the Internet and have always had problems with fidelity and distortion.

Not any more -- with QD’s higher speeds, I get hi-fidelity, Dolby-quality sound at

analog prices. And it’s so fast and reliable!"

-- Skip J., audiophile, St Louis, MO

"Quick DDRIP is a life saver - its real time access to football games on the

Internet is incredible. No more of those irritating jerky delays when I’m watching

my favorite games (you know, where the missing frame is the part showing the

completion of the pass) - and the picture is sharp enough to tell if the running

back’s foot was out of bounds when he caught that long pass (no instant replay

needed!!) And the best part is I’m no longer limited to watching East Coast games

broadcast on TV - but can keep up with the Big 12. (GO WILDCATS!!)"

-- Jerry W., transplanted K-State fan, Baltimore, MD

"Quick DDRIP outperforms the other equipment on the market. I listen to a lot of

high fidelity symphonic recordings and I must say that Quick DDRIP really lives up

to its reputation. I can download performances of the Berlin Symphony Orchestra

off the Internet in just a few minutes and the sound quality is unbeatable. Without

Quick DDRIP, I just didn’t have the patience to wait for the entire symphony to

download. Now there’s a whole new world of music for me to explore!" 

– Curt D., music lover in Mobile, AL
The disclosure on this click-through page is buried in the middle of text and is surrounded by

large graphics that may distract consumers’ attention away from the disclosure.

 Quick DDRIP 

Stop the Waiting - Get in the Game

Home How QD Works What Customers Say Experts Privacy Policy 

Priced at just 

 $129.95 

+ Shipping and Handling

($9.95, 2 days shipping, $.4.95 for 5 days shipping)

 HOT HOT HOT!!! 

Over 40,000 satisfied customers - and the numbers keep growing! 
* D.J. Blackhand has been involved in the gaming world since he was 12 years

old. After purchasing Quick DDRIP, he rapidly ascended the Wrath of Thor

tournament levels to become the intergalactic champion several years running.

D.J. loves all kinds of games and plays several hours daily. His interests also

include playing with his Briard dog, Thunder, and running on the beach.

 QuickDDRIP, Inc. has paid D.J. Blackhand for his endorsement.

Reviewers in Web Surfer Pro, Families Online, and 

Moviemag.com are unanimous in their praise of QD:

"Easy setup, good performance, reasonable price - what more

could you want?" Moviemag.com Click here to read review

"Quick DDRIP is truly revolutionary. It will turn the PC into the

Family Entertainment Center" Families Online (February 21,

1999) Click here to read review

"A great alternative to waiting for hi-speed phone or cable Internet

services to reach your neighborhood." 

Web Surfer Pro (March 1999) Click here to read review
Federal Trade Commission

May 2000

www.ftc.gov