Warner Bros. Home Entertainment Inc.; Analysis of Proposed Consent Order to Aid Public Comment, 46078-46080 [2016-16729]
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46078
Federal Register / Vol. 81, No. 136 / Friday, July 15, 2016 / Notices
to provide to the FCC advice, data, and
technical analyses, and will formulate
recommendations relating to the
preparation of U.S. proposals and
positions for ITU World
Radiocommunication Conferences,
specifically the World
Radiocommunication Conference that
has been preliminarily scheduled for the
year 2019 (WRC–19).
This notice advises interested persons
of the first meeting of the WRCAC.
Additional information regarding the
WRC–19 and the WRCAC is available on
the WRCAC’s Web site, https://
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Open captioning will be provided for
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The proposed agenda for the first
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First Meeting of the World
Radiocommunication Conference
Advisory Committee
Federal Communications
Commission, 445 12th Street SW., Room
TW–C305, Washington, DC 20554,
August 2, 2016; 11:00 a.m.
1. Opening Remarks
2. Approval of Agenda
3. Advisory Committee Structure
4. WRC–19 Preparatory Process
Timeline
5. Other Business
sradovich on DSK3GMQ082PROD with NOTICES
FEDERAL RESERVE SYSTEM
Formations of, Acquisitions by, and
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The companies listed in this notice
have applied to the Board for approval,
The notificants listed below have
applied under the Change in Bank
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notices are set forth in paragraph 7 of
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The notices are available for
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Interested persons may express their
views in writing to the Reserve Bank
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A. Federal Reserve Bank of
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1. Jeffrey A. Fisher, Bigfork,
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indirectly retain control of First State
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Board of Governors of the Federal Reserve
System, July 11, 2016.
Michele Taylor Fennell,
Assistant Secretary of the Board.
[FR Doc. 2016–16696 Filed 7–14–16; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL TRADE COMMISSION
[File No. 152 3034]
Warner Bros. Home Entertainment Inc.;
Analysis of Proposed Consent Order
to Aid Public Comment
Federal Trade Commission.
Proposed Consent Agreement.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair or
deceptive acts or practices. The attached
Analysis to Aid Public Comment
describes both the allegations in the
draft complaint and the terms of the
consent order—embodied in the consent
agreement—that would settle these
allegations.
SUMMARY:
Comments must be received on
or before August 10, 2016.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
warnerbrothersconsent online or on
paper, by following the instructions in
the Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘In the Matter of Warner
Bros. Home Entertainment Inc., File No.
152 3034—Consent Agreement’’ on your
comment and file your comment online
at https://ftcpublic.commentworks.com/
ftc/warnerbrothersconsent by following
DATES:
Change in Bank Control Notices;
Acquisitions of Shares of a Bank or
Bank Holding Company
BILLING CODE 6712–01–P
Jkt 238001
[FR Doc. 2016–16748 Filed 7–14–16; 8:45 am]
FEDERAL RESERVE SYSTEM
[FR Doc. 2016–16716 Filed 7–14–16; 8:45 am]
19:03 Jul 14, 2016
Board of Governors of the Federal Reserve
System, July 12, 2016.
Michele Taylor Fennell,
Assistant Secretary of the Board.
BILLING CODE 6210–01–P
Federal Communications Commission.
Denise Coca,
Chief, Telecommunications and Analysis
Division, International Bureau.
VerDate Sep<11>2014
pursuant to the Bank Holding Company
Act of 1956 (12 U.S.C. 1841 et seq.)
(BHC Act), Regulation Y (12 CFR part
225), and all other applicable statutes
and regulations to become a bank
holding company and/or to acquire the
assets or the ownership of, control of, or
the power to vote shares of a bank or
bank holding company and all of the
banks and nonbanking companies
owned by the bank holding company,
including the companies listed below.
The applications listed below, as well
as other related filings required by the
Board, are available for immediate
inspection at the Federal Reserve Bank
indicated. The applications will also be
available for inspection at the offices of
the Board of Governors. Interested
persons may express their views in
writing on the standards enumerated in
the BHC Act (12 U.S.C. 1842(c)). If the
proposal also involves the acquisition of
a nonbanking company, the review also
includes whether the acquisition of the
nonbanking company complies with the
standards in section 4 of the BHC Act
(12 U.S.C. 1843). Unless otherwise
noted, nonbanking activities will be
conducted throughout the United States.
Unless otherwise noted, comments
regarding each of these applications
must be received at the Reserve Bank
indicated or the offices of the Board of
Governors not later than August 12,
2016.
A. Federal Reserve Bank of New York
(Ivan Hurwitz, Vice President) 33
Liberty Street, New York, New York
10045–0001. Comments can also be sent
electronically to
Comments.applications@ny.frb.org:
1. CheckSpring Community
Corporation NY, Bronx, New York; to
become a bank holding company by
acquiring 100 percent of the shares of
Spring Bank, Bronx, New York.
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sradovich on DSK3GMQ082PROD with NOTICES
Federal Register / Vol. 81, No. 136 / Friday, July 15, 2016 / Notices
the instructions on the web-based form.
If you prefer to file your comment on
paper, write ‘‘In the Matter of Warner
Bros. Home Entertainment Inc., File No.
152 3034—Consent Agreement’’ on your
comment and on the envelope, and mail
your comment to the following address:
Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW., Suite CC–5610 (Annex D),
Washington, DC 20580, or deliver your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610
(Annex D), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT:
Linda K. Badger, (415–848–5151), FTC
Western Region, 901 Market Street,
Suite 570, San Francisco, CA 94103.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis to Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for July 11, 2016), on the
World Wide Web at: https://www.ftc.gov/
os/actions.shtm.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before August 10, 2016. Write ‘‘In the
Matter of Warner Bros. Home
Entertainment Inc., File No. 152 3034—
Consent Agreement’’ on your comment.
Your comment—including your name
and your state—will be placed on the
public record of this proceeding,
including, to the extent practicable, on
the public Commission Web site, at
https://www.ftc.gov/os/
publiccomments.shtm. As a matter of
discretion, the Commission tries to
remove individuals’ home contact
information from comments before
placing them on the Commission Web
site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
VerDate Sep<11>2014
19:03 Jul 14, 2016
Jkt 238001
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment does
not include any sensitive health
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which . . . is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
warnerbrothersconsent by following the
instructions on the web-based form. If
this Notice appears at https://www.
regulations.gov/#!home, you also may
file a comment through that Web site.
If you file your comment on paper,
write ‘‘In the Matter of Warner Bros.
Home Entertainment Inc., File No. 152
3034—Consent Agreement’’ on your
comment and on the envelope, and mail
your comment to the following address:
Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW., Suite CC–5610 (Annex D),
Washington, DC 20580, or deliver your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610
(Annex D), Washington, DC 20024. If
possible, submit your paper comment to
the Commission by courier or overnight
service.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
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46079
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before August 10, 2016. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
Analysis of Proposed Consent Order To
Aid Public Comment
The Federal Trade Commission
(‘‘FTC’’ or ‘‘Commission’’) has accepted,
subject to final approval, an agreement
containing consent order from Warner
Bros. Home Entertainment Inc.
(‘‘Warner Bros.’’ or ‘‘respondent’’). The
proposed consent order (‘‘proposed
order’’) has been placed on the public
record for thirty (30) days for receipt of
comments by interested persons.
Comments received during this period
will become part of the public record.
After thirty (30) days, the Commission
will again review the agreement and the
comments received, and will decide
whether it should withdraw from the
agreement and take appropriate action
or make final the agreement’s proposed
order.
This matter involves respondent’s use
of social media influencers to advertise
the video game, Middle Earth: Shadow
of Mordor (‘‘Shadow of Mordor’’).
According to the Commission’s
complaint, Warner Bros., through its ad
agency, Plaid Social Labs, LLC, hired
individuals who had earned reputations
as video game enthusiasts on YouTube
(‘‘YouTube influencers’’) to post
positive videos promoting Shadow of
Mordor on YouTube. The Commission’s
complaint alleges that these YouTube
influencers were given free access to a
pre-release version of Shadow of Mordor
and cash payments often ranging from
hundreds of dollars to tens of thousands
of dollars, if the videos they created
about Shadow of Mordor met certain
requirements defined by Warner Bros.
Among other things, Warner Bros.
required influencer videos to promote a
positive sentiment about the game, and
not to disclose any bugs or glitches that
the game might have. Consequently,
these videos were sponsored
advertisements, and did not necessarily
reflect the independent experiences of
the individual YouTube influencers.
The complaint also alleges that while
Warner Bros. instructed the YouTube
influencers to provide a disclosure that
their videos had been sponsored, it
specified that the disclosure be written,
and placed in the description box
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appearing below the YouTube videos.
Warner Bros. did not require the
YouTube influencers to place a
sponsorship disclosure clearly and
conspicuously in the video itself. Nor
did Warner Bros. require that the
YouTube influencers be instructed to
place the sponsorship disclosure ‘‘above
the fold’’ in the description box, or
visible without consumers having to
scroll down or click on a link, as it had
for other promotional information about
Shadow of Mordor. (See, e.g., Exhibit A–
1) As a result, most YouTube
influencers did not include any
sponsorship disclosures in their videos,
and only placed their sponsorship
disclosures ‘‘below the fold’’ in the
description box below the video.
Therefore, consumers had to click on a
‘‘Show More’’ button in the description
box and potentially scroll down before
they could see the sponsorship
disclosure. As a result, consumers who
watched these YouTube videos were
unlikely to learn that the videos were
paid promotions for Warner Bros.
The Commission’s complaint further
alleges that when YouTube influencers
posted their Shadow of Mordor videos
for viewing on Facebook or Twitter,
consumers were even less likely to see
these sponsorship disclosures because
such posts did not include the ‘‘Show
More’’ button. In addition, the
complaint states that on at least two
occasions, the influencers disclosed
only that they had been given early
access to the game, and did not
adequately disclose that they had also
been paid to post the video.
According to the complaint, in
numerous instances, YouTube
influencers did not disclose or
adequately disclose that Warner Bros.,
through Plaid Social, offered
compensation to the influencers in
exchange for creating and uploading
gameplay videos as part of a Shadow of
Mordor advertising campaign. The
Commission’s complaint alleges that
these videos were false and misleading
because they did not reflect the
independent opinions or experiences of
impartial video game enthusiasts. The
complaint further alleges that the videos
were deceptive because they failed to
disclose or disclose adequately that the
influencers who posted the videos were
compensated in connection with their
endorsements.
The proposed order includes
injunctive relief to address these alleged
violations and requires Warner Bros. to
follow certain monitoring and
compliance procedures related to its use
of influencer campaigns.
Part I of the proposed order prohibits
Warner Bros., in connection with the
VerDate Sep<11>2014
19:03 Jul 14, 2016
Jkt 238001
advertising of any home entertainment
product or service, from
misrepresenting in any influencer
campaign that an influencer or endorser
of such product or service is an
independent user or ordinary consumer
of the product or service.
Part II of the proposed order requires
Warner Bros., in connection with the
advertising of any home entertainment
product or service by means of an
endorsement, in any influencer
campaign, to disclose clearly and
conspicuously a material connection, if
one exists, between the influencer or
endorser and Warner Bros.
Part III of the proposed order sets out
certain monitoring and compliance
obligations to ensure that Warner Bros.,
or any entity it engages to conduct an
influencer campaign, comply with Parts
I and II of the proposed order. These
obligations include: Obtaining signed
acknowledgements from such
influencers that they will disclose their
material connection to Warner Bros.;
monitoring the influencers’
representations and disclosures;
maintaining records of monitoring
efforts; and, under certain
circumstances, terminating and ceasing
payment to influencers who
misrepresent their independence, or fail
to properly disclose any material
connection to Warner Bros. Part III
specifically provides that if Warner
Bros. engages an entity to conduct an
influencer campaign, Warner Bros. must
take steps to ensure that the entity
complies with this Part, and to monitor
its compliance. If the entity fails to
comply with this Part, Warner Bros.
must cease payment to the entity until
it cures any noncompliance.
Furthermore, Warner Bros. is required
to disqualify the entity from conducting
future influencer campaigns upon a
repeat incident, unless it reasonably
concludes that the entity’s failure to
comply was inadvertent.
Part IV of the proposed order contains
recordkeeping requirements for relevant
documents.
Parts V through VII of the proposed
order require the company to: Provide
copies of the order to certain personnel
having responsibilities with respect to
the subject matter of the order; notify
the Commission of changes in corporate
structure that might affect compliance
obligations under the order; and file
compliance reports with the
Commission.
Part VIII of the proposed order
provides that the order will terminate
after twenty (20) years, with certain
exceptions.
The purpose of this analysis is to
facilitate public comment on the
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proposed order, and it is not intended
to constitute an official interpretation of
the complaint or proposed order, or to
modify the proposed order’s terms in
any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2016–16729 Filed 7–14–16; 8:45 am]
BILLING CODE 6750–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Centers for Medicare & Medicaid
Services
[Document Identifiers: CMS–339 and CMS–
460]
Agency Information Collection
Activities: Proposed Collection;
Comment Request
Centers for Medicare &
Medicaid Services, HHS.
ACTION: Notice.
AGENCY:
The Centers for Medicare &
Medicaid Services (CMS) is announcing
an opportunity for the public to
comment on CMS’ intention to collect
information from the public. Under the
Paperwork Reduction Act of 1995 (the
PRA), federal agencies are required to
publish notice in the Federal Register
concerning each proposed collection of
information (including each proposed
extension or reinstatement of an existing
collection of information) and to allow
60 days for public comment on the
proposed action. Interested persons are
invited to send comments regarding our
burden estimates or any other aspect of
this collection of information, including
any of the following subjects: (1) The
necessity and utility of the proposed
information collection for the proper
performance of the agency’s functions;
(2) the accuracy of the estimated
burden; (3) ways to enhance the quality,
utility, and clarity of the information to
be collected; and (4) the use of
automated collection techniques or
other forms of information technology to
minimize the information collection
burden.
DATES: Comments must be received by
September 13, 2016.
ADDRESSES: When commenting, please
reference the document identifier or
OMB control number. To be assured
consideration, comments and
recommendations must be submitted in
any one of the following ways:
1. Electronically. You may send your
comments electronically to https://
www.regulations.gov. Follow the
SUMMARY:
E:\FR\FM\15JYN1.SGM
15JYN1
Agencies
[Federal Register Volume 81, Number 136 (Friday, July 15, 2016)]
[Notices]
[Pages 46078-46080]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-16729]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 152 3034]
Warner Bros. Home Entertainment Inc.; Analysis of Proposed
Consent Order to Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed Consent Agreement.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair or deceptive acts or
practices. The attached Analysis to Aid Public Comment describes both
the allegations in the draft complaint and the terms of the consent
order--embodied in the consent agreement--that would settle these
allegations.
DATES: Comments must be received on or before August 10, 2016.
ADDRESSES: Interested parties may file a comment at https://ftcpublic.commentworks.com/ftc/warnerbrothersconsent online or on
paper, by following the instructions in the Request for Comment part of
the SUPPLEMENTARY INFORMATION section below. Write ``In the Matter of
Warner Bros. Home Entertainment Inc., File No. 152 3034--Consent
Agreement'' on your comment and file your comment online at https://ftcpublic.commentworks.com/ftc/warnerbrothersconsent by following
[[Page 46079]]
the instructions on the web-based form. If you prefer to file your
comment on paper, write ``In the Matter of Warner Bros. Home
Entertainment Inc., File No. 152 3034--Consent Agreement'' on your
comment and on the envelope, and mail your comment to the following
address: Federal Trade Commission, Office of the Secretary, 600
Pennsylvania Avenue NW., Suite CC-5610 (Annex D), Washington, DC 20580,
or deliver your comment to the following address: Federal Trade
Commission, Office of the Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610 (Annex D), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT: Linda K. Badger, (415-848-5151), FTC
Western Region, 901 Market Street, Suite 570, San Francisco, CA 94103.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of thirty (30) days. The
following Analysis to Aid Public Comment describes the terms of the
consent agreement, and the allegations in the complaint. An electronic
copy of the full text of the consent agreement package can be obtained
from the FTC Home Page (for July 11, 2016), on the World Wide Web at:
https://www.ftc.gov/os/actions.shtm.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before August 10, 2016.
Write ``In the Matter of Warner Bros. Home Entertainment Inc., File No.
152 3034--Consent Agreement'' on your comment. Your comment--including
your name and your state--will be placed on the public record of this
proceeding, including, to the extent practicable, on the public
Commission Web site, at https://www.ftc.gov/os/publiccomments.shtm. As a
matter of discretion, the Commission tries to remove individuals' home
contact information from comments before placing them on the Commission
Web site.
Because your comment will be made public, you are solely
responsible for making sure that your comment does not include any
sensitive personal information, like anyone's Social Security number,
date of birth, driver's license number or other state identification
number or foreign country equivalent, passport number, financial
account number, or credit or debit card number. You are also solely
responsible for making sure that your comment does not include any
sensitive health information, like medical records or other
individually identifiable health information. In addition, do not
include any ``[t]rade secret or any commercial or financial information
which . . . is privileged or confidential,'' as discussed in Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
---------------------------------------------------------------------------
\1\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
---------------------------------------------------------------------------
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/warnerbrothersconsent by following the instructions on the web-
based form. If this Notice appears at https://www.regulations.gov/#!home, you also may file a comment through that Web site.
If you file your comment on paper, write ``In the Matter of Warner
Bros. Home Entertainment Inc., File No. 152 3034--Consent Agreement''
on your comment and on the envelope, and mail your comment to the
following address: Federal Trade Commission, Office of the Secretary,
600 Pennsylvania Avenue NW., Suite CC-5610 (Annex D), Washington, DC
20580, or deliver your comment to the following address: Federal Trade
Commission, Office of the Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610 (Annex D), Washington, DC 20024. If
possible, submit your paper comment to the Commission by courier or
overnight service.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before August 10, 2016. You can find more
information, including routine uses permitted by the Privacy Act, in
the Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
Analysis of Proposed Consent Order To Aid Public Comment
The Federal Trade Commission (``FTC'' or ``Commission'') has
accepted, subject to final approval, an agreement containing consent
order from Warner Bros. Home Entertainment Inc. (``Warner Bros.'' or
``respondent''). The proposed consent order (``proposed order'') has
been placed on the public record for thirty (30) days for receipt of
comments by interested persons. Comments received during this period
will become part of the public record. After thirty (30) days, the
Commission will again review the agreement and the comments received,
and will decide whether it should withdraw from the agreement and take
appropriate action or make final the agreement's proposed order.
This matter involves respondent's use of social media influencers
to advertise the video game, Middle Earth: Shadow of Mordor (``Shadow
of Mordor''). According to the Commission's complaint, Warner Bros.,
through its ad agency, Plaid Social Labs, LLC, hired individuals who
had earned reputations as video game enthusiasts on YouTube (``YouTube
influencers'') to post positive videos promoting Shadow of Mordor on
YouTube. The Commission's complaint alleges that these YouTube
influencers were given free access to a pre-release version of Shadow
of Mordor and cash payments often ranging from hundreds of dollars to
tens of thousands of dollars, if the videos they created about Shadow
of Mordor met certain requirements defined by Warner Bros. Among other
things, Warner Bros. required influencer videos to promote a positive
sentiment about the game, and not to disclose any bugs or glitches that
the game might have. Consequently, these videos were sponsored
advertisements, and did not necessarily reflect the independent
experiences of the individual YouTube influencers.
The complaint also alleges that while Warner Bros. instructed the
YouTube influencers to provide a disclosure that their videos had been
sponsored, it specified that the disclosure be written, and placed in
the description box
[[Page 46080]]
appearing below the YouTube videos. Warner Bros. did not require the
YouTube influencers to place a sponsorship disclosure clearly and
conspicuously in the video itself. Nor did Warner Bros. require that
the YouTube influencers be instructed to place the sponsorship
disclosure ``above the fold'' in the description box, or visible
without consumers having to scroll down or click on a link, as it had
for other promotional information about Shadow of Mordor. (See, e.g.,
Exhibit A-1) As a result, most YouTube influencers did not include any
sponsorship disclosures in their videos, and only placed their
sponsorship disclosures ``below the fold'' in the description box below
the video. Therefore, consumers had to click on a ``Show More'' button
in the description box and potentially scroll down before they could
see the sponsorship disclosure. As a result, consumers who watched
these YouTube videos were unlikely to learn that the videos were paid
promotions for Warner Bros.
The Commission's complaint further alleges that when YouTube
influencers posted their Shadow of Mordor videos for viewing on
Facebook or Twitter, consumers were even less likely to see these
sponsorship disclosures because such posts did not include the ``Show
More'' button. In addition, the complaint states that on at least two
occasions, the influencers disclosed only that they had been given
early access to the game, and did not adequately disclose that they had
also been paid to post the video.
According to the complaint, in numerous instances, YouTube
influencers did not disclose or adequately disclose that Warner Bros.,
through Plaid Social, offered compensation to the influencers in
exchange for creating and uploading gameplay videos as part of a Shadow
of Mordor advertising campaign. The Commission's complaint alleges that
these videos were false and misleading because they did not reflect the
independent opinions or experiences of impartial video game
enthusiasts. The complaint further alleges that the videos were
deceptive because they failed to disclose or disclose adequately that
the influencers who posted the videos were compensated in connection
with their endorsements.
The proposed order includes injunctive relief to address these
alleged violations and requires Warner Bros. to follow certain
monitoring and compliance procedures related to its use of influencer
campaigns.
Part I of the proposed order prohibits Warner Bros., in connection
with the advertising of any home entertainment product or service, from
misrepresenting in any influencer campaign that an influencer or
endorser of such product or service is an independent user or ordinary
consumer of the product or service.
Part II of the proposed order requires Warner Bros., in connection
with the advertising of any home entertainment product or service by
means of an endorsement, in any influencer campaign, to disclose
clearly and conspicuously a material connection, if one exists, between
the influencer or endorser and Warner Bros.
Part III of the proposed order sets out certain monitoring and
compliance obligations to ensure that Warner Bros., or any entity it
engages to conduct an influencer campaign, comply with Parts I and II
of the proposed order. These obligations include: Obtaining signed
acknowledgements from such influencers that they will disclose their
material connection to Warner Bros.; monitoring the influencers'
representations and disclosures; maintaining records of monitoring
efforts; and, under certain circumstances, terminating and ceasing
payment to influencers who misrepresent their independence, or fail to
properly disclose any material connection to Warner Bros. Part III
specifically provides that if Warner Bros. engages an entity to conduct
an influencer campaign, Warner Bros. must take steps to ensure that the
entity complies with this Part, and to monitor its compliance. If the
entity fails to comply with this Part, Warner Bros. must cease payment
to the entity until it cures any noncompliance. Furthermore, Warner
Bros. is required to disqualify the entity from conducting future
influencer campaigns upon a repeat incident, unless it reasonably
concludes that the entity's failure to comply was inadvertent.
Part IV of the proposed order contains recordkeeping requirements
for relevant documents.
Parts V through VII of the proposed order require the company to:
Provide copies of the order to certain personnel having
responsibilities with respect to the subject matter of the order;
notify the Commission of changes in corporate structure that might
affect compliance obligations under the order; and file compliance
reports with the Commission.
Part VIII of the proposed order provides that the order will
terminate after twenty (20) years, with certain exceptions.
The purpose of this analysis is to facilitate public comment on the
proposed order, and it is not intended to constitute an official
interpretation of the complaint or proposed order, or to modify the
proposed order's terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2016-16729 Filed 7-14-16; 8:45 am]
BILLING CODE 6750-01-P