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Although hyperlinks generally should not be used to disclose information integral to the
claim — such as the existence and nature of additional fees consumers might not expect — a
hyperlink can be used to disclose the details if they are too complex to describe next to the basic
price information. Here the hyperlink leads to the disclosure, “Monitoring plan price: $15.95
per month with one camera, $9.95 per month/per camera with two cameras, $7.95 per month/
per camera with three or more cameras. Save 10% with a 12-month commitment, 20% with a
24-month commitment. Additional 5% discount for seniors and families of active duty military
This information about the monitoring plan’s prices is likely is too complex to appear
adjacent to the price per camera claim, and thus can be placed behind a properly labeled
hyperlink. The statement “Service plan required” and the hyperlink are next to the price per
camera; and together, the statement and the hyperlink’s label communicate to consumers the
specific nature and importance of the information to which the hyperlink leads. Moreover, all cost information, including any such fees, should be presented clearly and
conspicuously to consumers prior to purchase.
A-7 .com Disclosures: How to Make Effective Disclosures in Digital Advertising Example 6
Because the advertiser’s assertion that “Satisfaction is guaranteed” implies that
dissatisfied consumers can get a full refund of the purchase price, the advertiser should clearly
and conspicuously disclose any restocking fees.
The hyperlink “Restocking fee applies to all returns.” leads to the disclosure, “If you return
the Frost-a-tron within 30 days there is a restocking fee of $19.95. After 30 days and before 90
days, the restocking fee is $29.95. After 90 days, the restocking fee is $49.95. Shipping and
handling fees are non-refundable. No COD on returns.” The details in this return policy are likely
too complex to disclose next to the guarantee. The label of the hyperlink adequately conveys the
nature and relevance of the information to which it leads. A-8 Federal Trade Commission Example 7
This ad must disclose that the diamond weights are not exact and that a 3/4 carat
diamond may weigh between .72 and .78 car...
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- Spring '14