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Unformatted text preview: ard desktop computer might, instead, require
significant vertical and horizontal scrolling on a mobile screen. In evaluating placement,
advertisers should also take into consideration empirical research about where consumers do
and do not look on a screen. a. Evaluating Proximity
A disclosure is more likely to be effective if consumers view the disclosure and the claim
that raises the need for disclosure (often referred to as a “triggering claim”) together on the
same screen. Example 1 Even if a disclosure is not tied to a particular word or phrase, it is
more likely that consumers will notice it if it is placed next to the information, product, or service
to which it relates.
Often, disclosures consist of a word or phrase that may be easily incorporated into
the text, along with the claim. Doing so increases the likelihood that consumers will see the
disclosure and relate it to the relevant claim.
In some circumstances, it may be difficult to ensure that a disclosure appears on the
“same screen” as a claim or product information. Some disclosures are long and thus difficult
to place next to the claims they qualify. In addition, computers, tablets, smartphones, and
other connected devices have varying screen sizes that display ads and websites differently.
In these situations, an advertiser might place a disclosure where consumers might have
to scroll to reach it. Requiring consumers to scroll in order to view a disclosure may be 8 Federal Trade Commission problematic, however, because consumers who don’t scroll enough (and in the right direction)
may miss important qualifying information and be misled.
When advertisers are putting disclosures in a place where consumers might have to
scroll in order to view them, they should use text or visual cues to encourage consumers to
scroll and avoid formats that discourage scrolling.
Text prompts can indicate that more information is available. An explicit instruction like
“see below for important information on restocking fees” will alert consumers to scroll and look...
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This document was uploaded on 03/29/2014.
- Spring '14