UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Lina M. Khan, Chair

Rebecca Kelly Slaughter

Christine S. Wilson

Alvaro M. Bedoya

FTC Matter No. P224500

ORDER TO FILE A SPECIAL REPORT

Pursuant to a resolution of the Federal Trade Commission (“FTC” or “the Commission”) 

dated March 16, 2023, titled “Resolution Directing Use of Compulsory Process to Collect 

Information Regarding Social Media and Video Streaming Platforms’ Advertising Review and 

Monitoring of Commercial Advertising to Detect, Prevent, and Reduce Deceptive Advertisements, 

Including Related to Fraudulent Health-Care Products, Financial Scams, and the Sale of Fake

Goods,” a copy of which is enclosed, [COMPANY NAME] (“the Company,” “You,” or “Your”)

is ordered to file with the Commission, no later than 45 days after date of service, a Special Report 

containing the information and Documents specified herein.

The information provided in the Special Report will assist the Commission in conducting a 

study of the Social Media and Video Streaming Platforms’ policies, procedures, and practices to 

detect, prevent, and reduce deceptive Commercial Advertising and online shopping fraud, 

including the Platforms’ maintenance and enforcement of advertising standards; verification and 

authentication of advertisers; screening for misleading, deceptive, and fraudulent ads; and use of 

disclosures and other techniques to ensure commercial messages are identifiable as advertising. 

The Commission also is seeking information concerning the range of advertising formats offered 

to advertisers on Social Media and Video Streaming Platforms, including Shoppable Ads and ads 

using extended or virtual reality media, and the consumer groups most affected by deceptive 

Commercial Advertising and online shopping fraud on the Platforms.

The Special Report should restate each item of this Order with which the corresponding 

answer is identified. If You already have provided the same information in response to another 

Section 6(b) order from the Commission, and that information remains current and accurate, in 

lieu of reproducing it, You may specify the relevant order by name and matter number, and 

provide the date of Your response, the item of the other order to which the response pertained, and 

the bates number(s) for any responsive documents. Your Special Report must be subscribed and 

sworn to by an official of the Company who has prepared or supervised the preparation of the 

report from books, records, correspondence, and other data and material in Your possession. If any 

questions cannot be answered fully, give the information that is available and explain in what 

respects and why the answer is incomplete. The Special Report and all accompanying 

documentary responses should be bates-stamped and electronic submissions of documents should 

conform with the attached “Federal Trade Commission, Bureau of Consumer Protection 

Production Requirements.” Unless otherwise directed in the specifications, the Applicable 

Time Period for the request shall be from January 1, 2019 until the date of full and complete 
2 

compliance with this Order.

You are required to respond to this Order using information in Your possession, custody, 

or control. However, You should not seek any responsive information and data from separately 

incorporated subsidiaries or affiliates or from individuals (other than in their capacity as Your 

employee or as Your agent). Your response as it relates to separately incorporated subsidiaries or 

affiliates should only include information from or about such entities if You already have access to 

it, including information maintained in a central data repository. No later than 14 days from the 

date of service, You should contact Commission staff and indicate whether all of the information 

required to respond to this Order is in Your possession, custody, or control. If certain information 

is not in Your possession, custody, or control, no later than 14 days from date of service, You also 

must: (1) Identify, both orally and in writing, each question or sub-question that You are not able 

to answer fully because such information is not in Your possession, custody, or control, and (2) for 

each, provide the full names and addresses of all entities or individuals who have possession, 

custody, or control of such information. 

Confidential or privileged commercial or financial information will be reported by the 

Commission on an aggregate or anonymous basis, consistent with Sections 6(f) and 21(d) of the 

FTC Act. 15 U.S.C. §§ 46(b), 57b-2(d). Individual submissions responsive to this Order that are 

marked “confidential” will not be disclosed without first giving the Company ten (10) days’ notice 

of the Commission’s intention to do so, except as provided in Sections 6(f) and 21(d) of the FTC 

Act. Id. 

SPECIFICATIONS

Produce the following information, Documents, and items, consistent with the 

definitions, instructions, and formatting requirements contained in Attachment A.

Identification of Report Author 

1. Identify by full name, business address, telephone number, and official capacity the 

individual(s) who prepared or supervised the preparation of the Company’s response to 

this Order, and Describe in Detail the steps taken by the Company to respond to this 

Order. For each Specification, Identify the individual(s) who assisted in preparation of 

the response. Provide a list Identifying the individual(s) whose files were searched and

Identify the individual(s) who conducted the search.

Responses to Specifications 2-17 should be provided no later than thirty days from the date 

that this Order issued.

Company Information 

2. State the Company’s complete legal name and all other names under which it has done 

business, its corporate mailing address, all addresses from which it does or has done 

business, and the dates and states of its incorporation. 
3 

3. Describe in Detail the Company’s corporate structure, and state the names of all 

parents, subsidiaries, divisions, affiliates, branches, joint ventures, franchises, 

operations under assumed names, websites, and entities over which it exercises 

supervision or control. For each such entity, Describe in Detail the nature of its 

relationship to the Company and the date it was created, acquired, sold, or otherwise 

changed ownership or control. Produce organizational charts sufficient to detail the 

Company’s corporate structure.

4. If the Company is not publicly traded, Identify each individual or entity having an 

ownership interest in the Company, as well as their individual ownership stakes and

their positions and responsibilities within the Company. 

5. Identify each Social Media and Video Streaming Service provided or sold by the 

Company. 

In responding to Specifications 6 through 53, provide the following for each Social Media 

and Video Streaming Service Identified in response to Specification 5.

General Information Regarding Advertising on Social Media and Video Streaming Services

6. Identification of Digital Advertising Services: Identify each Digital Advertising 

Service offered or sold by the Company that serves, displays, or amplifies Paid Ads on 

the Social Media and Video Streaming Service, and for each such Digital Advertising 

Service, provide the following information: 

a) a description of the Digital Advertising Service, including, but not limited to, 

whether it involves the sale or provision of Boosted Ads; 

b) the Digital Advertising Service’s intended user or user segment;

c) how the Digital Advertising Service is priced (e.g., by cost-per-click,

cost-per-impression, revenue split, or other formula); 

d) the intended focus of the Digital Advertising Service (e.g., brand awareness

advertising, performance advertising, product purchase, or other purposes); 

and

e) the targeting capabilities of the product or service, including, but not limited to, a 

description of all data points that can be used to target (e.g., user information, mobile 

device type, location information, application being used, keywords), and the source 

of that data.

7. Identification of Ad Formats: Identify and Describe in Detail each Ad Format offered or 

sold by the Company to Advertising Customers. For each such Ad Format, Describe in 

Detail how ads are priced (e.g., by cost-per-click, cost-per-impression, revenue split, or 
4

other formula). Produce representative examples of each Ad Format, including, but not 

limited to, through graphic representation (e.g., screenshots and screencasts), and state the 

date the Ad Format was first available and, if applicable, the end date.

8. Other than those Identified in response to Specifications 6 and 7, Describe in Detail any 

product or service offered or sold by the Company that amplifies or promotes to a wider 

audience any existing or already posted content on the Social Media and Video 

Streaming Service, in exchange for consideration from an Advertising Customer

(collectively “Boosted Ads”), including, but not limited to:

a) how the Company refers to the product or service in the ordinary course of business; 

b) how the product or service is priced; 

c) the product or service’s intended purpose and intended user or user segment; and 

d) the product or service’s targeting capabilities. 

Produce representative examples of Boosted Ads sold or offered by the Company to 

advertisers, including, but not limited to, through graphic representation (e.g., screenshots 

and screencasts), and state the date any such Boosted Ad was first available and, if 

applicable, the end date.

9. Ad Account Creation: Describe in Detail, including, but not limited to, through graphic 

representation (e.g., screenshots and screencasts), any processes and mechanisms by which 

Advertising Customers create and manage accounts to publish Paid Ads on the Social 

Media and Video Streaming Service (collectively and hereinafter, “Ad Accounts”),

including, but not limited to:

a) any automated features or tools, including, but not limited to, each manually selectable 

option available to the Advertising Customer; 

b) any information requested from the Advertising Customer (e.g., payment method, 

name, contact information, Tax Identification Number, or other unique identifier) and 

any information the Advertising Customer is required to provide; 

c) any Ad Account support or advice offered by the Company to Advertising Customers

(e.g., advice on structuring ad campaigns, offering payment plans, or other account 

management services); 

d) the eligibility of Advertising Customers to receive any such Ad Account support or 

advice; 

d) any records maintained on any such Ad Accounts created and policies governing 

whether and for how long to preserve such records; and
5

e) whether and how such processes and mechanisms vary based on the characteristics of 

the Advertising Customer (e.g., amount of ad spend; existing relationship).

10. Advertising Customer Categorizations: Describe in Detail any processes to assign a

unique identifier to Advertising Customers (or to the Ad Accounts created by Advertising 

Customers). Describe in Detail any processes, methods, or criteria used by the Company to 

classify or categorize Advertising Customers (or Ad Accounts), including, but not limited 

to, based on the following (collectively and hereinafter, “Relevant Advertising Customer 

Categories”):

a) industry vertical (e.g., ecommerce, consumer packaged goods, professional services, 

affiliate marketer);

b) advertising spend tier or bracket; 

c) active or inactive status;

d) number of active Ad Accounts; and

e) length of time that an entity has been an Advertising Customer of the Social Media 

and Video Streaming Service (e.g., whether a new Advertising Customer).

11. Creating and Publishing Ads: Describe in Detail, including, but not limited to, through 

graphic representation (e.g., screenshots and screencasts), any processes and 

mechanisms for creating or publishing Paid Ads on the Social Media and Video 

Streaming Service, including, but not limited to:

a) any automated features or tools offered by the Company to Advertising Customers 

for content creation, design and formatting, or ad targeting, including all selectable 

options and templates and any information that Advertising Customers are 

prompted to input;

b) any selectable criteria, keywords, or user attributes offered by the Company to 

Advertising Customers to determine the audience for a Paid Ad (e.g., demographics, 

interests, behavior, location, or prior contact with the Advertising Customer), 

including, but not limited to, any audiences based on similar characteristics to a seed 

audience;

c) any information about the Paid Ad requested from Advertising Customers and any 

information the Advertising Customers is required to provide; 

d) any algorithmic, machine learning, or automated systems, including generative 

artificial intelligence systems, used by the Company to create and optimize Paid 

Ads’ content (e.g., wording, images, audio, video, simulations, product placements, 

or code), formatting, or design (e.g., adding disclosures or ad labels);
6

e) any ad support or advice offered by the Company to Advertising Customers, 

including, but not limited to, human support and through any automated features or 

tools, on how to format, design, or target Paid Ads; and

f) eligibility of advertisers to receive any such human support or advice (e.g., 

assistance with designing or developing ad creative or with ad targeting). 

If any such processes or mechanisms vary by Ad Format (including for Boosted Ads)

provide responsive information for each such Ad Format. 

12. Ad Categories Generally: Describe in Detail any methods, processes, and criteria used 

by the Company to classify or categorize Paid Ads based on the content of the Paid Ad

(e.g., the type of good or service advertised, subject matter), including through human 

review or any algorithmic, machine learning, or other automated system, including, but 

not limited to, the following: 

a) the total number and names of each such mutually exclusive classification or 

categorization (collectively and hereinafter, “Ad Categories”) in effect during the 

Applicable Time Period;

b) the Company’s use of any information provided by the Advertising Customer to 

determine the Ad Category for a Paid Ad;

c) any processes for reviewing, evaluating, or validating the Company’s classifications 

of Paid Ads by Ad Category; and

d) whether and how Advertising Customers are informed about any such 

classifications.

13. Describe in Detail how the Company tracks or uses any Ad Categories Identified in 

response to Specification 12, including, but not limited to, in connection with targeting 

Paid Ads to users of the Social Media and Video Streaming Service, allowing the users to 

control the Paid Ads served to them, or enforcing Company Advertising Policies. If any 

methods, processes, or criteria described in response to Specification 12 vary by the 

Relevant Language of the Paid Ad, provide responsive information for each Relevant 

Language. 

14. Identification of Relevant Ad Categories: Of those Ad Categories Identified in 

response to Specification 12, Identify each mutually exclusive Ad Category concerning 

Paid Ads relating to the following (collectively and hereinafter, “Relevant Ad 

Categories”):

a) products or services intended to prevent, cure, or treat substance use disorders;
7

b) products or services intended to prevent, cure, or treat diseases, including, but not 

limited to, COVID-19 or cancer;

c) weight-loss products or services;

d) income opportunities, including participation in multi-level marketing businesses;

e) day-trading or other investment courses or programs;

f) cryptocurrency products or services; and

g) job or employment listings.

If any such Ad Category varies by Relevant Language of the Paid Ad, provide responsive 

information for each Relevant Language. For each Ad Category Identified in response to 

this Specification, provide the time period during which it was in effect.

15. Identification of Advertising Objectives: Identify and Describe in Detail each 

selectable objective offered by the Company to Advertising Customers for conveying or 

establishing the marketing goals of Paid Ad campaigns or individual Paid Ads on the 

Social Media and Video Streaming Service (e.g., brand awareness, reach, website visits, 

lead generation, conversions, store traffic, app installs, store sales or traffic) (collectively 

and hereinafter, “Advertising Objectives”). Describe in Detail how the Company uses 

such information, including, but not limited to, in the targeting of Paid Ads to users of the 

Social Media and Video Streaming Service; in the pricing and tracking of advertising on 

the Social Media and Video Streaming Service; and in developing and enforcing 

Company Advertising Policies. 

16. Relevant Demographic Data: Describe in Detail any methods, processes, and criteria 

used by the Company to classify or categorize users of the Social Media and Video 

Streaming Service based on the following demographic attributes (collectively and 

hereinafter, “Relevant Demographic Data”): 

a) age (e.g., 2-11; 12-17; 18-24; 25-34; 35-44; 45-54; 55-64; 65+);

b) gender;

c) race and ethnicity;

d) sexual orientation and gender identity (“SOGI”);

e) membership in a religious group or religious affiliation;

f) geographic location of the user in the United States (e.g., state, county, metropolitan 

areas, zip code); 
8

g) education level;

h) income;

i) military service status (including veterans and active service members);

j) immigration status; and

k) disability and disease markers.

17. Identification of Advertising Metrics: Identify and Describe in Detail, by each Ad 

Format Identified in response to Specification 7, each metric tracked or used by the 

Company to evaluate the performance, effectiveness, value to the Company, and reach 

of Paid Ads on the Social Media and Video Streaming Service, including, but not limited 

to, metrics for the following (collectively and hereinafter, “Advertising Metrics”):

a) ad revenue;

b) number of impressions (i.e., ads served to a user);

c) number of viewed impressions (i.e., ads shown on a user’s screen);

d) number of unique users of the Social Media and Video Streaming Service who viewed 

the ad (i.e., reach);

e) viral reach (i.e., unique users of the Social Media and Video Streaming Service who 

view an ad due to the action of another user, such as likes, shares, tags, or comments); 

f) click-through rate;

g) any cost-per-action (e.g., cost-per-click, sale, contact request, app installs, or form 

submission);

h) number of user interactions with an ad (e.g., clicks, video plays, unmuting, watching a 

video ad for 10 seconds, shares, likes, taps, swipes, or comments);

i) rate of user interactions with an ad or the engagement rate (i.e., number of times users

of the Social Media and Video Streaming Service interact with an ad divided by the 

number of ad impressions);

j) conversion rate (i.e., number of conversions, such as sales or leads, per user 

interaction or the number of ads before advertiser achieves a desired Advertising 

Objective); 

k) average price determined by the auction for ads shown to a user of the Social Media 

and Video Streaming Service (e.g., average cost-per-click or cost-per-action); and
9

l) ad campaign duration.

If any such Advertising Metrics vary by Ad Format (including for Boosted Ads) or the 

Relevant Language of the Paid Ad, provide responsive information for each Ad Format 

and Relevant Language. For each Advertising Metric Identified in response to this 

Specification, provide the time period during which it was in effect.

18. Affiliate Marketing: Describe in Detail any Company policies, procedures, and practices

concerning the provision or sale of Digital Advertising Services to affiliate marketers or 

lead generators, including, but not limited to:

a) any outreach conducted by the Company (e.g., organizing or attending business 

conferences geared to affiliate marketers or lead generators);

b) any discounts or sales promotions targeted to affiliate marketers or lead generators; 

and

c) any strategic goals or plans to increase sales of Paid Ads to affiliate marketers or lead 

generators. 

Produce Documents showing any such policies, procedures, or practices, including any 

written policies or guidance, or instructions to internal and external staff responsible for ad 

sales and business operations. Produce all presentations, reports, or recommendations 

submitted to or prepared by management committees, executive committees, boards of 

directors, or senior management concerning the subjects described in this Specification. 

19. Company Strategy and Planning Documents: Produce all strategy or planning 

Documents (including, but not limited to, long-term and short-term business strategies or 

goals; objectives and key results; marketing plans or advertising strategies; presentations 

to management committees, executive committees, and boards of directors; and budgets 

and financial projections), relating to:

a) improving Company Advertising Policies and enforcement of those policies;

b) addressing potentially misleading, deceptive, or fraudulent Paid Ads on the Social 

Media and Video Streaming Service, including Paid Ads in the Relevant Ad 

Categories; 

c) the Ad Formats offered or sold by the Company to Advertising Customers, including 

any Ad Formats under development, Shoppable Ads, or ads using extended reality 

media (e.g., virtual, augmented, and mixed reality ads); and

d) using algorithmic, machine learning, or automated systems, including generative 

artificial intelligence systems, to create and optimize Paid Ads’ content (e.g., 
10 

wording, images, audio, video, simulations, product placements, or code), 

formatting, or design (e.g., adding disclosures or ad labels). 

For any regularly prepared budgets or financial projections, the Company need only 

produce one copy of final year-end Documents for prior years, and cumulative year-todate Documents for the current year. 

20. Advertiser Materials and Reports: Produce representative samples of: 

a) reports, analytics, or other Documents provided to Advertising Customers 

concerning the performance and effectiveness of ads or ad campaigns, including any 

Advertising Objectives described in Specification 15 and Advertising Metrics 

described in Specification 17; and

b) reports, analytics, or other Documents provided to Advertising Customers 

concerning any audience insights and other information relating to ad targeting. 

Advertising Standards and Policies 

21. Describe in Detail all Company Advertising Policies, plans, and directives, whether 

formally adopted, informally issued, internal or made public, including, but not limited 

to, relating to the following: 

a) any Paid Ad content or Advertising Customers that are disallowed or restricted on 

the Social Media and Video Streaming Service;

b) any Paid Ad content or advertisers that require pre-approval or other screening 

process;

c) any restrictions on the audiences or demographic groups to whom Paid Ads are 

targeted, including restrictions on the use of targeting based on similarity to a seed 

audience or age of the user, and Identify each mutually exclusive Ad Category subject 

to such restrictions; 

d) whether and how such Company Advertising Policies, plans, and directives apply 

to: 

i) any page or other destination to which a Paid Ad leads users of the Social 

Media and Video Streaming Service (e.g. a landing page to which an ad directs 

users who click on it); and

ii) Paid Ads involving affiliate marketing or lead generation; and

e) the consequences of violating any such Company Advertising Policy, plan, or 

directive (e.g., ad removal; temporary or permanents bans from advertising on the 
11

Social Media and Video Streaming Service; campaign spending limits or caps; 

limitations on ad targeting).

If any such Company Advertising Policy, plan, or directive varies by the Ad Format,

(including for Boosted Ads) or by the Relevant Language of the Paid Ad, provide 

responsive information for each Relevant Language and Ad Format. Describe how any 

such Company Advertising Policy, plan, or directive varies based on the age of the user. 

Describe in Detail the steps taken by the Company to implement such Company 

Advertising Policies, plans, and directives, including guidance or instructions to internal or 

external staff responsible for ad review and sales, and for engineering any related 

algorithmic, machine learning, or other automated systems. Produce copies of any such (i)

Advertising Policies, plans, and directives described in response to this Specification and 

(ii) written guidance or instructions to internal or external staff, including written policies, 

procedures, guidelines, training materials, manuals, or talking points.

22. Describe in Detail the Company’s methods, processes, and criteria for reviewing, updating, 

or changing any Company Advertising Policy, plan, or directive described in response to 

Specification 21 (based, e.g., on marketplace developments; reports or complaints from 

users of the Social Media and Video Streaming Service; new laws or regulations), 

including, but not limited to:

a) any information considered or analyzed to identify deficiencies or gaps in any such 

Company Advertising Policies, plans, and directives; 

b) any criteria or benchmarks used by the Company in evaluating whether to adopt or 

implement any proposed or recommended changes to such Company Advertising 

Policies, plans, or directives; and

c) any recommended or proposed changes to Company Advertising Policies that the 

Company rejected or otherwise failed to implement.

If any such methods, processes, or criteria vary by the Relevant Language of the Paid Ad, 

provide responsive information for each Relevant Language. Produce Documents showing

(i) any such methods, processes, or criteria and (ii) all recommended or proposed changes 

to Company Advertising Policies, including those that the Company rejected or otherwise 

failed to implement. 

23. Other than the Company’s policies, procedures, and practices reported in response to 

Specifications 21 and 22, Describe in Detail Company policies, procedures, and 

practices concerning Paid Ads relating to: 

a) potentially misleading, deceptive, or fraudulent Paid Ads in the Relevant Ad 

Categories;

b) online shopping fraud, including Paid Ads for counterfeit or fake products; 
12 

c) Impersonator Scams; 

d) affiliate marketing or lead generation; and

e) any algorithmic, machine learning, or automated systems, including generative 

artificial intelligence systems, for creating deepfakes, product placements or 

simulations, or falsified content. 

Describe in Detail whether and how any such policies, procedures, or practices vary 

from those for Nonpaid Commercial Advertising relating to the subjects described in this 

Specification. If such policies, procedures, or practices vary by Ad Format (including for 

Boosted Ads) or by the Relevant Language of the ad, provide responsive information for 

each Ad Format and Relevant Language. Produce all presentations, reports, or 

recommendations submitted to or prepared by management committees, executive 

committees, boards of directors, or senior management concerning the subjects 

described in this Specification, including, but not limited to, any recommended or 

proposed changes to any such policies, procedures, and practices that the Company 

rejected or otherwise failed to implement. 

24. Identification of Advertising Policy Violation Codes: Describe in Detail any methods, 

processes, or criteria used by the Company to classify, code, or record violations of 

Company Advertising Policies by violation type or seriousness (e.g., advertised an 

unsafe product; contained potentially deceptive, misleading, or fraudulent claims; 

advertised a prohibited or restricted product; mismatched landing page and ad creative; 

misuse of the Company’s brand) (collectively and hereinafter, “Advertising Policy 

Violation Codes”), including, but not limited to: 

a) the number and name of each mutually exclusive Advertising Policy Violation Code 

tracked or used by the Company and the time period any such code was in effect; 

b) any information or materials relating to any such Advertising Policy Violation Code 

provided to Advertising Customers; and

c) any policies, procedures, or processes followed by the Company to create, maintain, 

and preserve records of violations of Company Advertising Policies, including 

whether and for how long to preserve such records. 

If any such methods or criteria vary by Ad Format or the Relevant Language of the ad, 

provide responsive information for each Ad Format and Relevant Language. 

Complaints and Inquires

25. Describe in Detail, including, but not limited to, through graphic representation (e.g., 

screenshots and screencasts), any feature or mechanism offered by the Company to users 

of the Social Media and Video Streaming Service for reporting or flagging Paid Ads as 
13

violating Company Advertising Policies and the means through which these users specify 

the reason for reporting or flagging a Paid Ad. Provide the menu of any selectable options 

offered by the Company to users of the Social Media and Video Streaming Service during 

this process. Describe in Detail how consumers are notified of any such feature or 

mechanism. If any such feature or mechanism varies by Ad Format (including for Boosted 

Ads) or by the Relevant Language of the ad, provide responsive information for each Ad 

Format and Relevant Language. 

26. Describe in Detail any processes, methods, or criteria used by the Company to track or 

analyze user reports or flags submitted to the Company through the feature(s) or 

mechanism(s) described in response to Specification 25. Describe in Detail the policies, 

procedures, and practices followed by the Company to create, maintain, and preserve 

records of any such user reports or flags, including, but not limited to, policies governing 

whether and for how long to preserve such records. If any such (i) processes, methods, or 

criteria or (ii) policies, procedures, or practices vary by Ad Format (including for Boosted 

Ads) or by the Relevant Language, provide responsive information for each Ad Format 

and Relevant Language.

27. Separately for each Relevant Language, produce any reports, surveys, or summaries

analyzing the volume, rate, and reason for user reports or flags described in response to 

Specification 25.

28. Separately for each Relevant Language, produce any reports, surveys, strategy or planning 

Documents, or analyses relating to the Company’s responses to complaints, inquiries, or 

concerns from: (i) Advertising Customers; (ii) app store and marketplace platforms; and 

(iii) any government or industry self-regulatory group or consumer protection organization 

(e.g., any state or federal government entity; industry self-regulatory organization; or 

Better Business Bureau office or associated organization, such as the National Advertising 

Division) about potentially misleading, deceptive, or fraudulent Commercial Ads on the 

Social Media and Video Streaming Service, including, but not limited to, complaints, 

inquires, or concerns about:

a) potentially misleading, deceptive, or fraudulent Paid Ads in Relevant Ad Categories;

b) online shopping fraud, including Paid Ads for counterfeit or fake products;

c) Impersonator Scams; 

d) Paid Ads that are not recognizable as ads, including Paid Ads deceptively formatted as 

news stories or other independent journalistic content; and

e) consumer deception or fraud relating to any feature, product, or service offered or sold 

by the Company that enables or supports direct selling or buying of advertised 

products or services, including, but not limited to, Shoppable Ads.
14 

29. Describe in Detail the processes or procedures used or followed by the Company to 

respond to: (i) user reports or flags about Paid Ads; and (ii) other complaints, inquiries, and 

concerns submitted to the Company on the subjects described in Specification 28. If such 

processes or procedures vary by Ad Format (including for Boosted Ads) or by the Relevant 

Language of the ad, provide responsive information for each Ad Format and Relevant 

Language. 

Advertising Review and Monitoring

30. Describe in Detail the Company’s policies, procedures, or practices for reviewing, 

vetting, verifying, and authorizing prospective Advertising Customers on the Social 

Media and Video Streaming Service, including, but not limited to: 

a) any human review or any algorithmic, machine-learning, or other automated 

systems used by the Company; 

b) any information about prospective Advertising Customers used or analyzed by the 

Company to vet or verify the identity of the prospective Advertising Customer, 

including, but not limited to, any information submitted by a prospective 

Advertising Customer during the Ad Account creation process; 

c) whether and how the Company considers or weighs information about Paid Ads 

previously run by an Advertising Customer on the Social Media and Video 

Streaming Service (e.g., whether any such Paid Ads were disallowed or removed by 

the Company or reported or flagged for violating Company Advertising Policies); 

d) whether and how any such policies, procedures, or practices vary based on the 

characteristics of prospective Advertising Customers, including, but not limited to: 

i. the prospective Advertising Customer’s size or industry vertical;

ii. the prospective Advertising Customer’s advertising spend tier or bracket; 

iii. any Advertising Objective; and

iv. whether Paid Ads from the prospective Advertising Customer are targeted 

to a particular subgroup of users of the Social Media and Video Streaming 

Service (e.g., children; cancer patients or survivors); 

e) the criteria and mechanisms for disallowing, suspending, or permanently blocking 

Advertising Customers from the Social Media and Video Streaming Service, 

including, but not limited to, removing Paid Ads associated with that Advertising 

Customer on the Social Media and Video Streaming Service; and 

f) any efforts undertaken by the Company to prevent Advertising Customers from 

circumventing Company actions to disallow, suspend, or permanently block any 
15

Advertising Customer (e.g., the Advertising Customer creating an Ad Account with a 

misappropriated, fake, or fabricated identity or alias, or having Paid Ads served from 

another party’s Ad Account).

If any such policies, procedures, or practices vary by the Ad Format (including for Boosted 

Ads) or by the Relevant Language of ads from the advertiser, provide responsive 

information for each Ad Format and Relevant Language. Produce written guidance or 

instructions relating to such policies, procedures, or practices provided to internal or

external staff responsible for ad review or sales, or for engineering any related algorithmic, 

machine learning, or other automated systems, including, but not limited to, written 

policies, procedures, guidelines, training materials, manuals, or talking points.

31. Describe in Detail the methods, processes, and criteria used by the Company to evaluate 

and validate the efficacy or quality of any such policies, procedures, or practices described

in response to Specification 30, including, but not limited to: 

a) any information considered or analyzed to identify deficiencies or gaps in such 

review, vetting, or verification processes for prospective Advertising Customers; 

b) any criteria, standards, or benchmarks used by the Company to evaluate the efficacy 

of any such policies, procedures, or practices, including any recommended or 

proposed changes; and

c) any recommended or proposed changes to such policies, procedures, or practices that 

the Company has rejected or otherwise failed to implement.

Produce any Documents showing (i) any such methods, processes, and criteria described in 

response to this Specification, including materials provided to internal or external staff 

responsible for ad review or sales, or for engineering any related algorithmic, machine 

learning, or other automated system; and (ii) all recommended or proposed changes to such 

Company policies, procedures, and processes described in response to Specification 30, 

including those that the Company rejected or otherwise failed to implement. 

32. Describe in Detail the Company’s policies, procedures, and practices for reviewing, 

screening, approving, and removing Paid Ads on the Social Media and Video Streaming 

Service, including, but not limited to:

a) any human review or any algorithmic, machine learning, or other automated system 

used by the Company to determine whether to disallow or remove ads from the Social 

Media and Video Streaming Service;

b) whether and how Paid Ads are reviewed for compliance with Company Advertising 

Policies before being served to users of the Social Media and Video Streaming 

Service, including any efforts undertaken by the Company to review, validate, or 

authenticate Paid Ad content and other data provided by Advertising Customers; 
16

c) the criteria or factors weighed in determining the Paid Ads for human review (e.g., 

user reports or flags about ads; whether Paid Ads are from Advertising Customers

with a history of Advertising Policy violations);

d) any processes for reviewing or evaluating the page or other destination to which Paid 

Ads lead users of the Social Media and Video Streaming Services (e.g., a landing page 

to which an ad directs users who click on it);

e) any efforts undertaken by the Company to detect, prevent, and reduce potentially 

misleading, deceptive, or fraudulent Paid Ads on the Social Media and Video 

Streaming Service, including:

i) potentially misleading, deceptive, or fraudulent Paid Ads in Relevant Ad 

Categories;

ii) online shopping fraud, including Paid Ads for counterfeit or fake products; and 

iii) Impersonator Scams; and

f) how any such policies, procedures, and practices function or are applied differently 

with respect to: 

i) the Ad Category of the Paid Ads, including with respect to Paid Ads in the 

Relevant Ad Categories;

ii) whether Paid Ads are targeted to a particular subgroup of users of the Social 

Media and Video Streaming Service (e.g., children; cancer patients or survivors);

iii) any Advertising Objective (e.g., brand awareness; customer acquisition; lead 

generation); 

iv) whether Paid Ads enable or support the direct selling or buying of goods or 

services (e.g., Shoppable Ads); 

v) amount of ad revenue generated for the Company; and

vi) any characteristics of the Advertising Customer associated with the ads, including 

(e.g., the Advertising Customer’s size or industry vertical; the Advertising 

Customer’s spend tier or bracket).

If any such policies, procedures, and practices vary by Ad Format (including for Boosted 

Ads) or Relevant Language of the ad, provide responsive information for each Ad Format 

and Relevant Language. Produce any written guidance, instructions, or assessments

relating to any such policies, procedures, and practices provided to internal and external 

staff responsible for ad review or sales, or for engineering any related algorithmic, machine 

learning, or other automated systems, including, but not limited to, written policies, 
17

procedures, training materials, manuals, performance evaluations or reviews, or talking 

points.

33. Describe in Detail how such Company algorithmic, machine learning, or other 

automated systems described in response to Specification 32 operate, including, but not 

limited to:

a) the criteria and weighting of factors used by any such systems to determine which ads 

to disallow, approve, or remove (e.g., user reports or flags about ads; whether ads are 

from Advertising Customers with a history of Advertising Policy violations);

b) any information about ads’ content analyzed or considered by any such systems (e.g., 

text, images, co-signals with other ads);

c) any underlying models used to sort or order ads according to compliance with 

Company Advertising Policies; 

d) the processes, methods, or criteria for training, tuning, or evaluating the performance 

of any such systems, including with respect to detecting potentially misleading, 

deceptive, or fraudulent Commercial Ads;

e) any predetermined categories according to which Paid Ads are labeled;

f) any benchmarks or standards against which performance is measured (e.g., achieving 

a desired level of accuracy); and

g) whether and how any such systems operate differently with respect to any particular 

subsets of Paid Ads, including Paid Ads in any Relevant Ad Category or Paid Ads 

targeted to particular subgroups of users of the Social Media and Video Streaming 

Service (e.g., children; cancer patients or survivors).

Produce Documents showing any assessment, evaluation, adjustment, or criticism of any 

such systems, the criteria and weighting of factors used by any such systems, the training 

of the models underlying any such systems, and any benchmarks or other standards by 

which performance is measured.

34. Describe in Detail all efforts undertaken by the Company (including conducting or 

commissioning any audits, assessments, or studies) to evaluate or validate the efficacy or 

accuracy of the Company’s algorithmic, machine learning, or other automated systems 

described in response to Specification 32, including, but not limited to, whether any such 

systems are effective in detecting, preventing, or reducing potentially misleading, 

deceptive, or fraudulent Paid Ads on the Social Media and Video Streaming Service, 

including with respect to:
18

a) potentially misleading, deceptive, or fraudulent Paid Ads in the Relevant Ad 

Categories; 

b) online shopping fraud, including Paid Ads for counterfeit or fake products; and

c) Impersonator Scams.

Produce all presentations or recommendations submitted to or prepared by management 

committees, executive committees, boards of directors, or senior management 

concerning any such efforts undertaken by the Company. Produce Documents showing 

any audits, assessments, or studies, including reports analyzing or summarizing the 

results or findings of such audits, assessments, and studies.

35. Other than reported in response to Specification 34, Identify and Describe in Detail, any 

independent audits, assessments, or reviews commissioned by the Company, whether 

completed or merely proposed, to evaluate or validate the efficacy of the Company’s 

policies, procedures, or practices, including any human review or any algorithmic, 

machine learning, or automated systems, for the following: 

a) reviewing, vetting, verifying, or authorizing prospective advertisers on the Social 

Media and Video Streaming Service, as described in response to Specification 30;

b) the Company’s policies, procedures, or practices for reviewing, screening, 

approving, or removing ads, as described in response to Specification 32; and

c) the Company’s efforts otherwise to detect, prevent, or reduce potentially 

misleading, deceptive, or fraudulent Commercial Ads on the Social Media and 

Video Streaming Service, including, but not limited to:

i) potentially misleading, deceptive, or fraudulent Paid Ads in the Relevant Ad 

Categories; 

ii) online shopping fraud, including ads for counterfeit or fake products; and

iii) Impersonator Scams.

Identify the Person(s) who conducted, or were retained by the Company to conduct, any 

such independent audits, assessments, or reviews. Provide the date any such audits, 

assessments, or reviews were conducted. Produce all such audits, assessments, or 

reviews, whether final or preliminary. 

36. Describe in Detail the Company’s policies, processes, or procedures for challenging or 

appealing any Company decision to: (i) approve, disallow, suspend, or permanently 

block any Advertising Customer; and (ii) approve, disallow, or remove Paid Ads from 

the Social Media and Video Streaming Service for violating Company Advertising 

Policies, including, but not limited to:
19 

a) who is eligible outside the Company to challenge or appeal these decisions (e.g., the 

Advertising Customer; other businesses; users of the Social Media and Video 

Streaming Service);

b) how any such policies, processes or procedures are disclosed; 

c) any mechanisms or processes allowing for internal challenges or appeals of ad 

compliance decisions (from, e.g., the chief revenue officer; personnel responsible 

for ad sales); 

d) the mechanisms or procedures for making any such challenges or appeals; and 

e) the methods, criteria, and processes used or followed by the Company to review and 

resolve such challenges or appeals, including the involvement of the teams, groups, 

or Persons responsible for the original decisions. 

If any such policies, processes, or procedures vary by whether the challenger or appellant 

is an Advertising Customer, another business, or a user of the Social Media and Video 

Streaming Service, provide responsive information for each such challenger or appellant. If 

any such policies, processes, or procedures vary by Ad Format (including for Boosted Ads) 

or Relevant Language of the Paid Ad, provide responsive information for each Ad Format 

and Relevant Language. Produce any written guidance or instructions relating to any such 

policies, processes, or procedures provided to internal or external staff responsible for 

handling or resolving any such challenges or appeals, including, but not limited to, written 

policies, guidelines, procedures, manuals, or talking points. 

Information Regarding Whether Commercial Advertising on Social Media and Video 

Streaming Services Is Recognizable as Advertising 

37. Describe in Detail the Company’s policies, plans, and directives, whether formally 

adopted, informally issued, internal, or made public, for ensuring that Paid Ads on the 

Social Media and Video Streaming Service are recognizable as advertising to users of the 

Social Media and Video Streaming Service, including, but not limited to: 

a) any processes for reviewing, approving, or disallowing Paid Ads based on the ad’s

design or format, including, but not limited to, Paid Ads resembling news stories or 

other independent journalistic content; 

b) any method of disclosure, including, but not limited to, through graphic 

representation (e.g., screenshots and screencasts), used by the Company to 

distinguish Paid Ads from other content published on the Social Media and Video 

Streaming Services (including, but not limited to, any ad labels or other visual or 

audio cues);
20 

c) whether and how such ad disclosure methods are maintained when users of the 

Social Media and Video Sharing Service share or republish Paid Ads; and 

d) whether and how any such ad disclosure methods vary depending on any particular 

subgroup of users of the Social Media and Video Sharing Service viewing a Paid Ad 

(e.g., older consumers, children), the device on which the Paid Ad is viewed (e.g., 

mobile, desktop), or the user interface in which the Paid Ad appears. 

For each ad disclosure method described in response to this Specification, provide the time 

period that it was in effect. If such policies, plans, or directives vary by Ad Format or the 

Relevant Language of the ad, provide responsive information for each Ad Format and 

Relevant Language. Describe in Detail the steps taken by the Company to implement such 

policies, plans, or directives, including, but not limited to, any guidance or instruction 

provided to any ad review, UX design, or ad sales teams. Produce any such written

guidance or instructions, including, but not limited to, written policies, procedures, training 

materials, manuals, or talking points. 

38. For each ad disclosure method described in response to Specification 37, Describe in 

Detail, including through graphic representation (e.g., screenshots and screencasts), any 

change or redesign implemented by the Company from January 1, 2016 until the date 

of full and complete compliance with this Order. Produce all presentations, reports, or 

recommendations prepared by or submitted to management committees, executive 

committees, boards of directors, or senior management concerning any such disclosure 

methods and any changes or redesigns considered or implemented by the Company 

during this time period. 

39. Describe in Detail the Company’s policies, plans, and directives, whether formally 

adopted, informally issued, internal or made public, governing whether and how Nonpaid 

Commercial Advertising published on the Social Media and Video Streaming Service is 

identifiable to users of the Social Media and Video Streaming Service as advertising (e.g., 

influencer marketing or paid placement), including, but not limited to: 

a) any automated features or tools, or other support, offered by the Company to 

influencer marketers or endorsers for identifying Nonpaid Commercial Advertising 

content as advertising, including disclosing material connections between endorsers 

and the sellers of advertised products or services; 

b) the mechanisms and processes, including, but not limited to, through graphic 

representation (e.g., screenshots and screencasts), by which any ad labels or other 

disclosures are implemented or included in Nonpaid Commercial Advertising 

content through use of any such Company features or tools; 

c) how any such implemented or included ad labels or other disclosures are maintained 

when users of the Social Media and Video Streaming Service share or republish 

Nonpaid Commercial Advertising content; 
21 

d) whether and how any such ad labels or other disclosures implemented or included 

vary based on the user interface design in which Nonpaid Commercial Advertising 

content appears, any particular subgroup of users of the Social Media and Video 

Streaming Service viewing Nonpaid Advertising content (e.g., older consumers, 

children), or the device on which users of the Social Media and Video Streaming 

Service view it; and

e) the consequences of noncompliance with any such policies, plans, and directives (e.g., 

removal of violative content; account suspension). 

For each automated feature or tool described in response to this Specification, provide the 

time period that it was in effect. If any such policies, procedures, or practices vary by 

Relevant Language, provide responsive information for each Relevant Language. Describe 

in Detail the steps taken by the Company to implement such policies, procedures, and 

practices, including any guidance or instructions provided to any UX design teams. 

Produce any such written guidance or instructions, including written policies, procedures, 

guidelines, training materials, manuals, or talking points. 

40. Describe in Detail any public statements or disclosures to consumers, advertisers, and 

endorsers concerning the existence or efficacy of any automated feature or tool 

described in response to Specification 39. Produce representative samples of all such 

public statements and disclosures. 

41. Describe in Detail any efforts undertaken by the Company, including through human 

review and any algorithmic, automated, or other automated systems, to detect, prevent, 

or reduce deceptively formatted or designed Commercial Advertising on the Social 

Media and Video Streaming Service (i.e., Commercial Advertising that misleads 

consumers as to its source or commercial nature), including Commercial Advertising 

resembling news stories or other independent journalistic content. 

42. Regardless of time period, Describe in Detail all efforts undertaken by the Company to 

evaluate, validate, or substantiate, including conducting or commissioning any studies, 

experiments, user testing, or other research, the efficacy of: 

a) any ad disclosure methods described in response to Specification 37; and 

b) any automated features or tools described in response to Specification 39. 

Specify any other information on which the Company relies to validate or substantiate

the efficacy of any such ad disclosure methods or automated features or tools. 

Ecommerce-Related Features, Products, or Services

43. Describe in Detail each feature, product, or service offered or sold by the Company that 

enables or supports direct selling or buying of advertised products or services (e.g., 
22

Shoppable Ads, storefronts, order processing and fulfillment, payment systems and 

processing, customer service, digital shopping assistants and other forms of customer 

service, and any features allowing for users of the Social Media and Video Streaming 

Service to test, or experience, advertised products in extended or virtual reality 

environments) (collectively and hereinafter, “Ecommerce-Related Products”). For each 

Ecommerce-Related Product, Describe in Detail:

a) how it operates, including through representative examples and graphic 

representations (e.g., screenshots and screencasts);

b) its intended user or user segment;

c) any eligibility criteria governing which Advertising Customers are allowed to 

purchase or use it; 

d) how it is priced (e.g., by one time or recurring payment, cost-per-click, cost-perimpression, revenue split, or other formula);

e) whether it is offered or sold as part of any Company Digital Advertising Service;

f) whether it involves integration with or use of any other online platforms and the 

Identity of any such online platform and a description of the platform’s relationship 

to the Company;

g) any support or advice, including, but not limited to, human support, offered or 

provided by the Company to Advertising Customers using it; and

h) any efforts undertaken by the Company to evaluate and validate its efficacy or 

quality. 

44. Produce representative samples of each type of promotional material that the Company 

disseminates to prospective customers of any Ecommerce-Related Product described in 

response to Specification 43.

45. Describe in Detail any efforts undertaken by the Company to prevent or detect consumer 

deception or fraud relating to any Ecommerce-Related Product described in response to 

Specification 43, including, but not limited to, any human review or any algorithmic, 

machine learning, or other automated systems used by the Company. Describe the 

Company’s policies, processes, and procedures for addressing complaints, inquiries, or 

concerns submitted to the Company concerning any sales transactions enabled or 

supported by any such Ecommerce-Related Product. Produce all presentations, reports, or 

recommendations submitted to or prepared by management committees, executive 

committees, boards of directors, or senior management concerning any such efforts 

undertaken by the Company.
23 

46. State, on a monthly basis, in total and separately for each Relevant Ad Category, the 

number of: (a) Shoppable Ads viewed on the Social Media and Video Streaming Service, 

in total and as a share of all ads viewed; and (b) product purchases from those ads. 

47. Identify and Describe in Detail each metric tracked or used by the Company to evaluate the 

performance, effectiveness, value to the Company, and reach of any Ecommerce-Related 

Product described in response to Specification 43, including Shoppable Ads. 

48. State on a monthly, quarterly, and annual basis, in total and separately for each 

Ecommerce-Related Product described in response to Specification 43, the Company’s 

revenue attributable to the provision or sale of Ecommerce-Related Products, including 

Shoppable Ads, stated in dollars, stated separately by type of revenue, including gross and 

net revenue, and describe how such revenues were attributed and calculated.

Research and Analyses

49. Produce all research, studies, testing, reports, or analyses (including surveys, copy tests, 

focus groups, experiments, or A/B testing), regardless of whether completed or merely 

proposed, and whether qualitative, empirical, or otherwise, relating to the following: 

a) the use or efficacy of any ad disclosure methods described in response to 

Specification 37 (including, but not limited to, whether consumers comprehend or 

notice any ad labels or other visual or audio cues used by the Company); 

b) the use or efficacy of any automated features or tools described in response to 

Specification 39, including any ad labels or other disclosures implemented or 

included through use of any such feature or tool; 

c) consumers’ ability to recognize Commercial Advertising or to distinguish between 

Paid Ads and nonpaid content on the Social Media and Video Streaming Service; 

d) the effect of ads’ content, messaging, or formatting, or an ad’s intended audience, 

on consumer or user perceptions or behavior, activity, or engagement with ads on 

the Social Media and Steaming Service, or with the Social Media and Video 

Streaming Service generally; 

e) the extent to which ads served or viewed on the Social Media and Video Streaming 

Service violate Company Advertising Policies, or the extent of potentially misleading, 

fraudulent, or deceptive Commercial Ads served or viewed on the Social Media and 

Video Streaming Service, including, but not limited to: 

i) potentially misleading, deceptive, or fraudulent ads in the Relevant Ad 

Categories;

ii) online shopping fraud, including ads for counterfeit or fake products; and
24 

iii) Impersonator Scams;

f) whether or the extent to which any particular subgroups of users of the Social Media 

and Video Streaming Service (e.g., older users; users located in certain areas; 

military service members or veterans) are served, or view or interact with, or 

otherwise are disproportionately affected by: 

i) potentially misleading, deceptive, or fraudulent Commercial Ads on the Social 

Media and Video Streaming Service; and

ii) ads in any of the Relevant Ad Categories; 

g) the efficacy or accessibility of any features or mechanisms described in response to 

Specification 25 for users of the Social Media and Video Streaming Service to report 

or flag ads to the Company, including, but not limited to, whether these users notice 

and employ any such features or mechanisms, or whether and the extent to which any 

particular subgroups of users are more or less likely to avail themselves of such 

features or mechanisms; 

h) the effect of Company Advertising Policies, plans, or directives, and enforcement of 

any such Advertising Policy, plan, or directive on advertising inventory volume and 

performance, on advertising revenue generated, the pricing of ads, or profitability of 

the Social Media and Video Streaming Service; and

i) the efficacy of any Company efforts described in response to Specification 45 in 

preventing any Ecommerce-Related Product offered or sold by the Company from 

being used by advertisers to engage in consumer deception or fraud. 

50. Produce all presentations, reports, or recommendations submitted to or prepared by 

management committees, executive committees, boards of directors, and senior 

management concerning the subjects described in Specification 49. 

Personnel Responsibilities and Related Expenditures 

51. Identify, and Describe in Detail the responsibilities of, each department, group, and 

team, including any external staff, and all oversight provided by senior leadership as 

Identified by position, involved in: 

a) the subjects described in Specifications 21 through 50 above; and

b) the sale of Paid Ads or business operations relating to Paid Ads. 

For any such department, group, and team, Describe in Detail the means used by the 

Company to review or evaluate job performance, including, but not limited to, any 

incentives or penalties or performance measures (based on, e.g., rate of ads reviewed; 

accuracy of human review or any algorithmic, machine learning, or other automated 
25

systems; or ad revenue generated, ad volume, or ad spend per ad campaign). Describe in 

Detail the composition, size, and reporting structure of any such departments, teams, or 

groups, including, but not limited to, through visual representation. Produce Documents

setting forth the performance expectations and basis for compensation of personnel in 

such departments, teams, or groups. 

52. Describe in Detail the role, if any, including decision making and setting of strategic 

goals and planning, of any department, team, group Identified in response to 

Specification 51(b), with respect to the following:

a) the specifications and scope of any Company Advertising Policies, any proposed 

or recommended updates to such policies, and the enforcement of the policies;

b) the Company’s methods, processes, and criteria for reviewing, vetting, verifying, 

and authorizing prospective Advertising Customers;

c) the Company’s policies, procedures, and practices for reviewing, screening, 

approving, and removing Paid Ads;

d) any Company efforts to detect, prevent, and reduce potentially misleading, 

deceptive, or fraudulent Commercial Ads on the Social Media and Video 

Streaming Service, including:

i. potentially misleading, deceptive, or fraudulent Paid Ads in Relevant Ad 

Categories;

ii. online shopping fraud, including ads for counterfeit or fake products; 

iii. Impersonator Scams; and

iv. deceptively formatted or designed Commercial Advertising (i.e., 

misleads consumers as to its source or commercial nature);

e) the operation of Company algorithmic, machine learning, and other automated 

systems described in response to Specification 33, including the criteria and 

weighting of factors used and any benchmarks or standards against which 

performance is measured;

f) the review and resolution of challenges or appeals of Company ad compliance 

decisions, including actions to: (i) disallow, suspend, or permanently block an 

advertiser or (ii) disallow or remove ads from the Social Media and Video 

Streaming Service for violating Company Advertising Policies;

g) the formatting and design of ads, including any disclosure methods used by the 

Company to ensure that ads are recognizable as advertising to users of the Social 
26 

Media and Video Streaming Service or distinguishable from nonpaid content on the 

Social Media and Video Streaming Service; 

h) advertisers or ads’ eligibility for any Ecommerce-Related Product described in 

Specification 43, including, but not limited to, Shoppable Ads, sold or offered by the 

Company; and

i) the Company’s commissioning or conducting any research, testing, or analyses 

(including any independent audits, assessments, or reviews) described in

Specifications 34, 35, and 49. 

Describe in Detail the policies, processes, and procedures governing the relationship 

between any such departments, groups, or teams Identified in response to Specification 

51(a) and (b) regarding the subjects described in this Specification, including, but not 

limited to, with respect to resolving any disagreements or disputes. Describe in Detail the 

flow of information on such subjects, if any, between any such departments, groups, or 

teams, including any guidance, reporting, regular meetings or task forces, or shared access 

to data dashboards. 

53. State, on a monthly, quarterly, and annual basis, separately for each Relevant Language, 

the Company’s: (i) costs and expenditures (e.g., labor, research and development, machine 

learning infrastructure) and (ii) head count, relating to developing, maintaining, and 

enforcing Company Advertising Policies, including through human review or any 

algorithmic, machine learning, or other automated system. 

Reporting on Revenue and Other Metrics for Paid Ads Viewed on Social Media and Video 

Streaming Services

Provide responses to Specifications 54 to 62 for each Social Media and Video Streaming 

Service Identified in response to Specification 5. Provide reported information separately 

for: (a) each Relevant Language and (b) desktop and mobile. Unless specified, do not include

responsive information for Boosted Ads. Before submitting a full response to Commission 

counsel, submit a list of available Relevant Ad Categories and Relevant Advertiser 

Customer Categories and meet and confer with Commission counsel regarding the format of 

Your response. Include in Your response a description of how each responsive metric is 

calculated and a data dictionary with each such metric. 

54. Revenue from Advertising: Report, on a monthly, quarterly, and annual basis, the dollar 

amount of revenue from ads on the Social Media Service, for: (a) all Paid Ads in total; 

(b) Paid Ads in each Relevant Ad Category; and (c) Boosted Ads, stated separately for 

gross and net revenue. 

55. Ads Viewed: Report, on a monthly basis, and separately for Boosted Ads, the number of 

Paid Ads viewed for:
27

a) all Paid Ads in total; and

b) each Relevant Ad Category.

Report responsive information in total and broken down by (i) Ad Format; (ii) Relevant 

Advertising Customer Categories Identified in response to Specification 10; and (iii) by

Advertising Objectives Identified in response to Specification 15.

56. Pre-screening of ads: Report, on a monthly basis, before delivery to users of the Social 

Media and Video Streaming Service, the number of ads, in total and as a share of all ads 

submitted to the Company, and separately for Boosted Ads, for:

a) Paid Ads reviewed manually; and

b) Paid Ads disallowed from the Social Media and Video Streaming Service for violating 

Company Advertising Policies.

Report responsive information in total and broken down by: (a) whether ad sales were 

direct or by auction; and (b) Ad Category.

57. Advertiser Suspensions and Removals: Report, on a monthly basis, the number of 

Advertising Customers that the Company:

a) disallowed from creating an Ad Account, in total and as a share of all Ad Accounts 

created; 

b) suspended from serving ads on the Social Media and Video Streaming Service, in total 

and as a share of active Advertising Customers; and

c) permanently blocked from serving ads on the Social Media and Video Streaming 

Service, in total and as a share of active Advertising Customers. 

Report the Identity (including any unique ID value used by the Company) of any such 

(i) disallowed; (ii) suspended; or (iii) permanently blocked Advertising Customer. Report

responsive information in total and broken down by Relevant Advertiser Customer 

Categories.

58. User Reports or Flags: Report, on a monthly basis, and separately for Boosted Ads, the 

total number of user reports or flags described in response to Specification 25, and the 

reason specified and the Identity of the Advertising Customer (including any unique ID 

value used by the Company), for:

a) all Paid Ads in total; and

b) each Relevant Ad Category.
28

Report responsive information in total and broken down by Ad Format and Advertising 

Objective.

59. Removed Ads: Report, on a monthly basis, and separately for Boosted Ads, the total 

number of Paid Ads removed from the Social Media and Video Streaming Service for 

violating Company Advertising Policies, and the relevant Advertising Policy Violation 

Code and Identity of the advertiser (including any unique ID value used by the Company),

for:

a) all Paid Ads in total; and

b) each Relevant Ad Category.

Report responsive information in total and broken down by Ad Format and Advertising 

Objective. 

60. Demographic Information and Advertiser Metrics: For Paid Ads reported in response 

to Specifications 55(b), 58, and 59, provide Relevant Demographic Data Identified in 

response to Specification 16 for users of the Social Media and Video Streaming Service 

who viewed such ads and the following Advertising Metrics:

a) ad revenue;

b) number of unique users of the Social Media and Video Streaming Service who viewed 

the Paid Ad;

c) number of viewed impressions;

d) viral reach;

e) click-through rate;

f) cost-per-action; 

g) rate of any user interactions other than reported in response to (d); and

h) conversion rate; and

i) average ad campaign duration.

61. Audit Sample: Produce a sample consisting of 300 randomly selected ads among the Paid 

Ads viewed on the Social Media and Video Streaming Service on two days (as determined 

by Commission counsel) during the calendar years 2019, 2020, 2021, 2022, and 2023 for 

each Relevant Ad Category. For each sampled ad provide the following:
29

a) copy of the ad creative shown to users of the Social Media and Video Streaming 

Service (including, but not limited to, the landing page or other destination to which 

the ad leads users and corresponding hyperlink for any such landing page or other 

destination);

b) the start and end date of the ad campaign;

c) the Advertising Objectives (including any target audience selected by the advertiser);

d) audience insights and other information related to ad targeting;

e) the value of each Advertising Metric listed in Specification 60 above;

f) whether the Paid Ad was reported or flagged by users of the Social Media and Video 

Streaming Service for violating Company Advertising Policies and, if so, the number 

of times and the reason(s) specified; 

g) whether the Company subsequently removed the ad for violating Company 

Advertising Policies and, if so, the relevant Advertising Policy Violation Code and 

date of removal; and

h) the Identity of the Advertising Customer (including any unique ID value used by the 

Company) and:

i) each Relevant Advertising Customer Categorization; and

ii) whether any other ads from the Advertising Customer were reported or flagged by 

users.

62. Advertising Records: Describe in Detail the policies, procedures, or processes followed 

by the Company to create, maintain, and preserve records on the subjects described in 

Specifications 54 to 61, including whether and for how long to preserve such records.
30 

Attachment A 

DEFINITIONS & ADDITIONAL INSTRUCTIONS

A. “Ad Format” means, and information shall be provided separately for, each type of Paid 

Ad by media type (e.g., text, photo, video, or extended reality media, including, but not 

limited to, virtual, augmented, and mixed reality ads), by design and function (e.g., 

carousel ad, slideshow ad, collection ad, playable ad, in-stream or in-feed ad, native ad,

or Shoppable Ad), and location (e.g., specific locations on a web page or app) on 

Company Social Media and Video Streaming Services. 

B. “Advertising Customer” means any Person that uses or avails themself of a Company 

Digital Advertising Service.

C. “Advertising Policy” means, and information shall be provided separately for, each 

Company policy, code of conduct, advertising standard or guideline, that the Company 

applies or otherwise uses to determine what types of Paid Ad content are allowed on 

Company Social Media and Video Streaming Services, or otherwise are subject to user 

audience or location restrictions.

D. “Boosted Ad” means any existing or already posted content on Company Social Media 

or Video Streaming Services that the Company amplifies or promotes to a wider 

audience in exchange for consideration from an Advertising Customer. 

E. “Commercial Advertisement” or “Commercial Advertising” or “Commercial Ad”

means any written or verbal statement, illustration, or depiction that promotes the sale of 

a good or service or is designed to increase consumer interest in a brand, good, or service 

(excluding, e.g., social issue, election, or political ads). 

F. “Company,” “You,” or “Your” means [COMPANY NAME], its domestic and foreign 

parents, predecessors, wholly or partially owned subsidiaries, unincorporated divisions, 

joint ventures, operations under assumed names, and affiliates, and all directors, officers, 

members, employees, agents, consultants, and other Persons working for or on behalf of 

the foregoing. The terms “Company,” “You” or “Your” do not include separately 

incorporated subsidiaries and affiliates unless it relates to information from or about such 

entities if you already have access to it, including information maintained in a central 

data repository. 

G. “Describe in Detail” means providing the information requested in narrative form, and 

including an explanation of each material change, if any, during the Applicable Time 

Period relating to the matter described, as well as the effective date of the change(s), and 

the reason(s) for such changes.

H. “Digital Advertising Service” means each Company product or offering that serves, 

displays, or amplifies, or Company service relating to the service, display, or 
31

amplification of, Paid Ads through an application or website on any device (e.g., 

personal computer, iOS device, Android device, etc.).

I. “Document” means the complete original, all drafts, and any non-identical copy, 

whether different from the original because of notations on the copy, different metadata, 

or otherwise, of any item covered by 15 U.S.C. § 57b-1(a)(5), 16 C.F.R. § 2.7(a)(2), or 

Federal Rule of Civil Procedures 34(a)(1)(A).

J. “Identify” or “the Identity of” requires identification of (a) natural Persons by name, 

title, present business affiliation, present business address, telephone number, and email 

address or, if a present business affiliation or present address is not known, the last 

known business and home address; and (b) businesses or other organizations by name, 

address, and the Identities of the Company’s contact Persons at the business or 

organization.

When used in reference to facts, items, or things, “Identify” or “the Identity of” means 

to describe, with particularity, the fact, item, or thing in question, including how the 

Company names or references it.

K. “Impersonator Scams” means a form of Commercial Advertising that pretends to be 

from or impersonates a Person to convince the consumer to send that Person money or to 

promote a good or service (e.g., Social Security Administration scams, Internal Revenue 

Service scams, fake celebrity or expert endorsements, tech support scams, romance 

scams, nanny and caregiver scams, grandkid scams, and family emergency scams).

L. “Paid Ad” means content that the Company delivers to users of a Social Media and 

Video Streaming Services in exchange for payment or other compensation from an 

Advertising Customer, including, but not limited to, Boosted Ads. 

M. “Nonpaid Commercial Advertising” means Commercial Advertising posted or 

published on Company Social Media and Video Streaming Services by users of these 

services of these services for which the Company does not receive compensation (e.g., 

brand account content, paid placements, influencer marketing, or brand partnerships with 

content creators). 

N. “Person” means a natural Person, an organization, or other legal entity, including a 

corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity.

O. “Relevant Language” means, and information shall be provided separately for, 

advertising targeted to: (1) English speakers; and (2) Spanish speakers.

P. “Shoppable Ads” means Paid Ads that allow consumers to purchase the advertised 

product or service directly from the ad.
32 

Q. “Social Media and Video Streaming Service” includes, and information shall be 

provided separately for, any product or service that allows users of the product or service 

to create and share content with other users of the product or service (whether a private 

or group interaction) through an application or website on any device (e.g., personal 

computer, iOS device, Android device, etc.), or stream video, including, but not limited 

to, any social networking service, messaging service, video streaming service, or photo, 

video, or other content sharing application, whether offered for a fee or for free. 

R. “You” and “Your” mean the Person or Entity to whom this CID is issued and include the 

“Company.” 

S. Responses to Specifications 54-62: The Company must produce responses to these 

Specifications in a format, in part, in one or more delimited text files, that the staff will 

provide after the meet and confer discussions. 

T. Meet and Confer: You must contact Laura Sullivan at (202) 326-3327; 

lsullivan@ftc.gov or Rafael Reyneri at (202) 326-3026; rreyneri@ftc.gov as soon as 

possible to schedule a meeting (telephonic or in person) in order to confer regarding 

Your response. 

U. Modification of Specifications: If You believe that the scope of the required search or 

response for any Specification can be narrowed consistent with the Commission’s need 

for Documents or information, You are encouraged to discuss such possible 

modifications, including any modifications of definitions and instructions, with the 

Commission counsel named above. 

V. Electronic Submission of Documents: See the attached “Federal Trade Commission, 

Bureau of Consumer Protection Production Requirements,” which details all 

requirements for submission of information, generally requiring that files be produced in 

native form and specifying the metadata to be produced. As noted in the attachment, 

some items require discussion with Commission counsel prior to production, which can 

be part of the general Meet and Confer described above. If You would like to arrange a 

separate discussion involving Persons specifically familiar with Your ESI systems and 

methods of retrieval, make those arrangements with Commission counsel when 

scheduling the general Meet and Confer discussion. 

W. Applicable Time Period: Unless otherwise directed in the Specifications the Applicable 

Time Period for the requests shall be from January 1, 2019 until the date of full and 

complete compliance with this Order.

X. Production of Copies: Copies of marketing materials and advertisements shall be 

produced in color, and copies of other materials shall be produced in color if necessary to 

interpret them or render them intelligible.
33

Y. Sensitive Personally Identifiable Information and Sensitive Health Information: If 

any material called for by these requests contains Sensitive Personally Identifiable 

information or Sensitive Health Information of any individual, please contact 

Commission counsel before sending those materials to discuss ways to protect such 

information during production. For purposes of these requests, Sensitive Personally 

Identifiable Information includes: an individual’s Social Security number alone; or an 

individual’s name or address or telephone number in combination with one or more of 

the following: date of birth, Social Security number, driver’s license number or other 

state identification number, or a foreign country equivalent, passport number, financial 

account number, credit card number, or debit card number. Sensitive Health Information 

includes medical records and other individually identifiable health information relating to 

the past, present, or future physical or mental health or conditions of an individual, the 

provision of health care to an individual, or the past, present, or future payment for the 

provision of health care to an individual.

Z. Withholding Requested Material / Privilege Claims: For specifications requesting 

production of Documents or answers to written interrogatories, if You withhold from 

production any responsive material based on a claim of privilege, work product protection, 

statutory exemption, or any similar claim, You must assert the claim before full and 

complete compliance with this Order, and You must submit a detailed log, in a searchable 

electronic format, of the items withheld that identifies the basis for withholding the 

material and meets all the requirements set forth in 16 C.F.R. § 2.11(a)–(c). The 

information in the log must be of sufficient detail to enable FTC staff to assess the validity 

of the claim for each Document, including attachments, without disclosing the protected 

information. If only some portion of any responsive material is privileged, You must 

submit all non-privileged portions of the material. Otherwise, produce all responsive 

information and material without redaction. 16 C.F.R. § 2.11(c). The failure to provide 

information sufficient to support a claim of protected status may result in denial of the 

claim. 16 C.F.R. § 2.11(a)(1).

You are advised that penalties may be imposed under applicable provisions of federal law 

for failure to file special reports or for filing false reports.

By direction of the Commission

____________________________

Lina M. Kahn, Chair

DATED: March 16, 2023