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Unformatted text preview: ss the disclosure; ● whether disclosures in audio messages are presented in an adequate volume and
cadence and visual disclosures appear for a sufficient duration; and ● whether the language of the disclosure is understandable to the intended audience. If there are indications that a significant proportion of reasonable consumers are not
noticing or comprehending a necessary disclosure, the disclosure should be improved.
The following discussion uses these traditional factors to evaluate whether disclosures
are likely to be clear and conspicuous in the context of online ads. Hyperlinks labeled as 22. This approach mirrors one articulated by the Commission in 1970, when it said that if disclosures in television
ads could not be understood, then ads containing representations requiring those disclosures should not be
aired. See Commission Enforcement Policy Statement in Regard to Clear and Conspicuous Disclosures in
Television Advertising (Oct. 21, 1970). 7 .com Disclosures: How to Make Effective Disclosures in Digital Advertising Examples in the text link to mock ads in the appendix. Each mock ad presents a scenario to
illustrate one or more particular factors. Advertisers must consider all of the factors, however,
and evaluate an actual disclosure in the context of the ad as a whole. 1. Proximity and Placement
A disclosure is more effective if it is placed near the claim it qualifies or other relevant
information. Proximity increases the likelihood that consumers will see the disclosure and
relate it to the relevant claim or product. For print ads, an advertiser might measure proximity
in terms of whether the disclosure is placed adjacent to the claim, or whether it is separated
from the claim by text or graphics. The same approach can be used for online ads. Websites,
and mobile applications, however, are interactive and have a certain depth — with multiple
pages or screens linked together and pop-up screens, for example — that may affect how
proximity is evaluated. Mobile devices also present additional issues because a disclosure
that would appear on the same screen of a stand...
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- Spring '14