Richard A. Quaresima 

Acting Associate Director 

Ms. Adrienne Eliza Houghton 

c/o Mr. Steven Grossman 

Untitled Ente1iainment 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Houghton: 

The Federal Trade Commission is the nation's consumer protection agency. As paii of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1iising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regai·ding your October 2, 2018 Instagrampost endorsing Teami tea: 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

- ad riennebailon o 

254,373 views 

adriennebailon Take care of yourself! '- Give 

your body all the good things, and watch it do 

good for you in return! I have so much ... more 
Ms. Adrienne Eliza Houghton

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. In addition, there was no disclosure in 

the video. Because the video could be viewed without anyone seeing a disclosure, you should 

disclose any material connection in the video itself, and not just the text portion of your post. 

There are many ways you could make a disclosure in a video, such as by saying that, “{Brand}

sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Adrienne Eliza Houghton 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme1a),ftc.gov. Thank you. 

Very 

?&~ 

truly yours, 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Ms. Alexa Pena Vega 

c/o Adam Kaller, Esq. 

Hansen, Jacobson, Teller, Hobennan, Newman, Warren, Richman, Rush & Kaller, LLP 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Pena Vega: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1tising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your July 10, 2018 Instagram post endorsing Teami tea: 

0 vegaalexa o 

vow . 24,005 likes 

vegaalexa SWIPE • As a really busy working 

mom it is not easy to eat healthy all the time, 

and I know I am not the only one who ... more 
Ms. Alexa PenaVega

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. In addition, there was no disclosure in 

the video. Because the video could be viewed without anyone seeing a disclosure, you should 

disclose any material connection in the video itself, and not just the text portion of your post. 

There are many ways you could make a disclosure in a video, such as by saying that, “{Brand}

sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Alexa Pena Vega 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@,ftc.gov. Thank you. 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580 

Richard A. Quaresima

Acting Associate Director

March 5, 2020 

Ms. Brittany Renner 

 Subject: Warning to Prominently Disclose Paid Endorsements

Dear Ms. Renner: 

The Federal Trade Commission is the nation’s consumer protection agency. As part of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under truth-in-advertising laws and standards, including the FTC’s Endorsement 

Guides. 

I am writing regarding your July 30, 2018 and September 24, 2018 Instagram posts 

endorsing Teami tea: 
Ms. Brittany Renner

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram posts include the disclosure “#teamipartner,” the 

disclosures was not visible to followers viewing the posts in their Instagram feeds unless they 

clicked “more.” Thus, they were not clear and conspicuous. In addition, there was no disclosure 

in the video in the September 24, 2018 post. Because the video could be viewed without anyone 

seeing a disclosure, you should disclose any material connection in the video itself, and not just 

the text portion of your post. There are many ways you could make a disclosure in a video, such 

as by saying that, “{Brand} sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging an advertiser in the photo) or 

in the first few lines of a photo caption, you should disclose any material connection above the 

“more” button. There are many ways you could make a disclosure in a caption, including 

through the use of hashtags such as “#Ad,” “#Sponsored,” and “#{Brand}_Partner.”

In addition, you should put a disclosure in each and every social media post and not 

assume that consumers will see and associate multiple posts. A disclosure should not be hidden 

among multiple tags, hashtags, or Instagram handles. I would strongly recommend that you 

review the attached FTC staff publications, Disclosures 101 for Social Media Influencers1 and 

The FTC Endorsement Guides: What People Are Asking.

2

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Brittany Renner 

March 5, 2020 

Page 3 

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@ftc.gov. Thank you. 

Very 

?tfi 

truly yours, 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

Richard A. Quaresima 

Acting Associate Director 

March 5, 2020 

Ms. Belcalis Marlenis Almanzar 

c/o Ms. Stephanie Paciullo 

Creative Ali ists A enc 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Almanzar: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1iising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your November 23, 2018 Instagram post endorsing Teami tea: 

0 iamcardib o 

20,380,128 views 

iamcardib The BEST fuckingggg black friday 

deal. If you spend you $$$ on ANYTHING it 

better be Teami. Thankful to be a ... more 
Ms. Belcalis Marlenis Almánzar

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. In addition, there was no disclosure in 

the video. Because the video could be viewed without anyone seeing a disclosure, you should 

disclose any material connection in the video itself, and not just the text portion of your post. 

There are many ways you could make a disclosure in a video, such as by saying that, “{Brand}

sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Belcalis Marlenis Almanzar 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your c.orrespondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@,ftc.gov. Thank you. 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Ms. Darnell Nicole Thibodeaux 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Darnell Nicole Thibodeaux: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under t:Iuth-in-advertising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your August 21 , 2018 Instagrampost endorsing Teami tea: 

• darnellnicole o 

vO'? 

18,237 likes 

darnellnicole I started another round of my 

@teamiblends 30 day detox a few weeks ago 

and LISTENNN up this tea is my ... more 
Ms. Darnell Nicole Thibodeaux

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the 

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. If you are endorsing a product or 

service in a photo you post to Instagram (such as by prominently featuring a branded product in 

the photo or by tagging an advertiser in the photo) or in the first few lines of a photo caption, you 

should disclose any material connection above the “more” button. There are many ways you 

could make a disclosure in a caption, including through the use of hashtags such as “#Ad,” 

“#Sponsored,” and “#{Brand}_Partner.”

In addition, you should put a disclosure in each and every social media post and not 

assume that consumers will see and associate multiple posts. A disclosure should not be hidden 

among multiple tags, hashtags, or Instagram handles. If you are endorsing a product or service 

in an Instagram video, you should disclose any material connection in the video itself, and not 

just the text portion of your post. I would strongly recommend that you review the attached FTC 

staff publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement 

Guides: What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Darnell Nicole Thibodeaux 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme(al,ftc.gov. Thank you. 

Very 

?cf::2-: 

truly yours, 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Lopez: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1tising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your Febrnaiy 4, 2019 Instagram post endorsing the Teami Green 

Tea Detox Mask. The screenshot below displays the post as it appeared when viewed on a 

desktop computer, and not in the Instagram feed of one of your followers. 

@ jenicka_lopez O • follow 

jenicka_lopez My skin has definitely been a 

little sensitive the last few years. and it's j

been a struggle to find a mask that doesn't 

irritate it or dry it out... I wear a lot of 

makeup so it's so important for me to take 

really good care of it. See the problem? 

Once I found the @teamiblends Green Tea 

Detox mask. I tried it out and immediately 

fell in love!! I have never been so glad to be 

a #teamipartner. This is seriously a miracle 

for me because it doesn't dry out my skin 

AND I see results immediately. I've been 

QO L!J 

138,782 views 

n:9p p .; 

Log in ·o h ke or commen· 
Ms. Jenicka Lopez

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

When followers view your posts in their Instagram feeds, only the first two or three lines 

of text are visible without the need to click “more.” Although the above Instagram post includes 

the disclosure “#teamipartner,” the disclosure was not visible to followers viewing the post in 

their Instagram feeds unless they clicked “more.” Thus, it was not clear and conspicuous. In 

addition, there was no disclosure in the video. Because the video could be viewed without 

anyone seeing a disclosure, you should disclose any material connection in the video itself, and 

not just the text portion of your post. There are many ways you could make a disclosure in a 

video, such as by saying that, “{Brand} sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Jenicka Lopez 

March 5, 2020 

Page 3 

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@ftc.gov. Thank you. 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Ms. Jordin Sparks 

c/o Ms. Stephanie Paciullo 

Creative Ali ists A enc 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Jordin Sparks: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1iising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your August 28, 2018 Instagrampost endorsing the Teami Green 

Tea Detox Mask: 

• jordinsparks o 

15,245 likes 

jordinsparks A Mama's got to multitask! I'm 

pretty sure we've mastered the art of it (SWIPE 

for a smile!) I don't follow a long ... more 
Ms. Jordin Sparks

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the 

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. If you are endorsing a product or 

service in a photo you post to Instagram (such as by prominently featuring a branded product in 

the photo or by tagging an advertiser in the photo) or in the first few lines of a photo caption, you 

should disclose any material connection above the “more” button. There are many ways you 

could make a disclosure in a caption, including through the use of hashtags such as “#Ad,” 

“#Sponsored,” and “#{Brand}_Partner.”

In addition, you should put a disclosure in each and every social media post and not 

assume that consumers will see and associate multiple posts. A disclosure should not be hidden 

among multiple tags, hashtags, or Instagram handles. If you are endorsing a product or service 

in an Instagram video, you should disclose any material connection in the video itself, and not 

just the text portion of your post. I would strongly recommend that you review the attached FTC 

staff publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement 

Guides: What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Jordin Sparks 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme(a),ftc.gov. Thank you. 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Katya Elise Herny: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under t:Iuth-in-advertising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your August 16, 2018 Instagrampost endorsing Teami tea: 

~ katyaelisehenry o 

241,114 views 

katyaelisehenry Traveling & eating outtt! {i) 

My tummy has been feeling so bad lately, I've 

been bloated and really uncomfortable ... more 
Ms. Katya Elise Henry

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. In addition, there was no disclosure in 

the video. Because the video could be viewed without anyone seeing a disclosure, you should 

disclose any material connection in the video itself, and not just the text portion of your post. 

There are many ways you could make a disclosure in a video, such as by saying that, “{Brand}

sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Katya Elise Hemy 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure tha

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@,:ftc.gov. Thank you. 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 

t 
United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580 

Richard A. Quaresima

Acting Associate Director

March 5, 2020 

Ms. Leyla Milani-Khoshbin 

 Subject: Warning to Prominently Disclose Paid Endorsements

Dear Ms. Leyla Milani-Khoshbin: 

The Federal Trade Commission is the nation’s consumer protection agency. As part of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under truth-in-advertising laws and standards, including the FTC’s Endorsement 

Guides. 

I am writing regarding your July 24, 2018 Instagram post endorsing Teami tea-infused 

facial oil. The screenshot below displays the post as it appeared when viewed on a desktop 

computer, and not in the Instagram feed of one of your followers.
Ms. Leyla Milani-Khoshbin

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

When followers view your Instagram posts in their feeds, only the first two or three lines 

of text are visible without the need to click “more.” Although the above Instagram post includes 

the disclosure “#teamipartner,” the disclosure was not visible to followers viewing the post in 

their Instagram feeds unless they clicked “more.” Thus, it was not clear and conspicuous. In 

addition, there was no disclosure in the video. Because the video could be viewed without 

anyone seeing a disclosure, you should disclose any material connection in the video itself, and 

not just the text portion of your post. There are many ways you could make a disclosure in a 

video, such as by saying that, “{Brand} sponsored this post” or “I’m partnering with {Brand}.”

If you are endorsing a product or service in a photo you post to Instagram (such as by 

prominently featuring a branded product in the photo or by tagging a brand in the photo), the 

same rule applies: the disclosure must be above the “more” button. A disclosure should not be 

hidden among multiple tags, hashtags, or Instagram handles. In addition, you should put a

disclosure in each and every social media post and not assume that consumers will see and 

associate multiple posts. I would strongly recommend that you review the attached FTC staff 

publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement Guides: 

What People Are Asking.

2

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Leyla Milani-Khoshbin 

March 5, 2020

Page 3 

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please proviq.e a written response 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your correspondence to Michael Ostheimer or Christine DeLorme of my

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme(a),ftc.gov. Th� you. 

v�2, 

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices 
Richard A. Quaresima 

Acting Associate Director 

United States of America 

FEDERAL TRADE COMMISSION 

Washington, D.C. 20580 

March 5, 2020 

Subject: Warning to Prominently Disclose Paid Endorsements 

Dear Ms. Princess Mae Sacayanan: 

The Federal Trade Commission is the nation's consumer protection agency. As pali of 

our consumer protection mission, we work to educate marketers and endorsers about their 

responsibilities under trnth-in-adve1tising laws and standards, including the FTC's Endorsement 

Guides. 

I am writing regarding your June 15, 2018 Instagram post endorsing Teami tea: 

e maelovecleo 

64,802 likes 

maelovecleo Keep drinking my @teamiblends 

30 day detox •• haven't been eating right and 

I feel bloated and gross. This detox ... more 
Ms. Princess Mae Sacayanan

March 5, 2020

Page 2

You were paid by Teami, LLC (“Teami”) to create this post. In a federal court complaint 

filed today, the Federal Trade Commission alleged that the post was deceptive because it lacked 

a clear disclosure that you were paid to promote Teami products. I am enclosing a copy of the 

news release that will announce the FTC’s case against Teami.

The FTC’s Endorsement Guides state that if there is a “material connection” between an 

endorser and the marketer of a product – in other words, a connection that might affect the 

weight or credibility that consumers give the endorsement – that connection should be clearly 

and conspicuously disclosed, unless the connection is already clear from the context of the 

communication containing the endorsement. Examples of material connections include a 

business, family, or personal relationship; monetary payment; or the provision of free products or 

services to the endorser.

When you endorse a product on social media, you should make obvious your financial or 

other relationship with the brand by clearly and conspicuously disclosing any material 

connection in the same post that you make the endorsement. “Clear and conspicuous” means 

you should use unambiguous language and the disclosure must stand out. Consumers must be 

able to see the disclosure without having to click to expand additional text.

Although the above Instagram post includes the disclosure “#teamipartner,” the 

disclosure was not visible to followers viewing the post in their Instagram feeds unless they 

clicked “more.” Thus, it was not clear and conspicuous. If you are endorsing a product or 

service in a photo you post to Instagram (such as by prominently featuring a branded product in 

the photo or by tagging an advertiser in the photo) or in the first few lines of a photo caption, you 

should disclose any material connection above the “more” button. There are many ways you 

could make a disclosure in a caption, including through the use of hashtags such as “#Ad,” 

“#Sponsored,” and “#{Brand}_Partner.”

In addition, you should put a disclosure in each and every social media post and not 

assume that consumers will see and associate multiple posts. A disclosure should not be hidden 

among multiple tags, hashtags, or Instagram handles. If you are endorsing a product or service 

in an Instagram video, you should disclose any material connection in the video itself, and not 

just the text portion of your post. I would strongly recommend that you review the attached FTC 

staff publications, Disclosures 101 for Social Media Influencers1 and The FTC Endorsement 

Guides: What People Are Asking.

2

Individual influencers who fail to make adequate disclosures about their connections to 

marketers are subject to legal enforcement action by the FTC. Please provide a written response 

 1

 The influencer guidance document is available at: 

https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

2

 The business guidance document is available at: https://www.ftc.gov/tips-advice/businesscenter/guidance/ftcs-endorsement-guides-what-people-are-asking.
Ms. Princess Mae Sacayanan 

March 5, 2020 

Page 3 

to this letter by March 30, 2020, describing what actions you are or will be taking to ensure that 

your social media posts endorsing brands and businesses with which you have a material 

connection clearly and conspicuously disclose your relationships. 

Please direct your c'orrespondence to Michael Ostheimer or Christine DeLorme of my 

office. If you have any questions, contact Mr. Ostheimer at (202) 326-2699 or 

mostheimer@ftc.gov or Ms. DeLorme at (202) 326-2095 or cdelorme@,ftc.gov. Thank you. 

Very truly yours, 

��--

Richard A. Quaresima 

Acting Associate Director 

Division of Advertising Practices