ERSP Recommends Global Smart Products Discontinue Certain Claims for Lead-Generation Program; Company Agrees to Do So

The Electronic Retailing Self-Regulation Program (ERSP) has recommended that Global Smart Products modify or discontinue certain claims for the company’s “Female Power Program,” a lead-generation wealth creation business.

ERSP is an investigative unit of the advertising industry’s system of self-regulation and is administered by the Council of Better Business Bureaus. The marketer’s advertising came to the attention of ERSP through ERSP’s ongoing monitoring program.

ERSP reviewed online advertising claims for the lead-generation, wealth-creation product, including:

• “A woman’s guide to becoming a Millionaire”
• “This course will teach you how to make money and how to go from having nothing to having millions of dollars in your bank account”
• “Get inspired and learn from a real life story of a woman who has made millions of dollars from implementing these simple techniques”
• “Revolutionary step-by-step guide to creating wealth!”
• “Within the very first year of using the Female Power program, I have made over $100,000”

The advertising at issue featured the following disclaimer: “Disclaimer: Individual results may vary.”

The disclaimer, ERSP noted, was inadequate to qualify the atypical results promoted by the marketer in testimonials and earnings claims.

ERSP recommended that in future advertising the marketer clearly, conspicuously and in close proximity to the main claim, disclose the amount of money consumers can generally expect to earn, based upon reliable program usage data it has received from consumers.

Further, given the absence of evidence in the record, ERSP recommended the marketer discontinue claims that indicate users of the system can earn money quickly and easily.

Finally, ERSP recognized the marketer’s voluntary removal of claims that formed the basis of this inquiry, such as:

• “This course will teach you how to make money and how to go from having nothing to having millions of dollars in your bank account.”

The company, in its marketer’s statement, said that it would follow ERSP’s recommendations and that it is “… in the process of revising our marketing material to remove all express earning claims and/or claims that might mislead the end user.”