The disclosure "imitation" needs to
accompany the triggering term "pearl" so that consumers are not misled about the
type of pearls being sold. The disclosure would not be as effective if it was separated
from the word pearl or placed on a different page. The FTC’s Guides for the Jewelry,
Precious Metals, and Pewter Industries, 16 C.F.R. § 23.19, recognize this and advise
that the disclosure "imitation" immediately precede the word pearl. In this
situation, there is no reason to evaluate proximity differently in Internet ads than with
other types of ads. |
|
FTC FASHION JEWELRY
|