On February 2, 2006, WLF filed with the Federal Trade Commission a response to a petition seeking an investigation of word-of-mouth, or “buzz,” marketing programs. The petition had been filed by Commercial Alert, an activist group co-founded by Ralph Nader. Commercial Alert claimed in its petition that programs inviting consumers (without compensation) to tell their peers about new products are deceptive if the consumers do not also disclose that they are participating in a marketing program. WLF argued in its response that such communications are not deceptive and that there is no basis for requiring the disclosures sought by Commercial Alert.
