Case #166-2024: Administrative Closure – My Lala Leggings

BBB NATIONAL PROGRAMS

Direct Selling Self-Regulatory Council
Case #166-2024: Administrative Closure – My Lala Leggings

Company Description

My LaLa Leggings ("Company") is a direct selling company that sells leggings as well as other apparel and accessories. The Company was founded in 2014, and is headquartered in Palmdale, California.

Basis of Inquiry

The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This matter was commenced by DSSRC pursuant to DSSRC’s ongoing independent monitoring of advertising and marketing claims in the direct selling industry.

This inquiry concerned seven social media posts containing earnings claims. DSSRC was concerned that the posts conveyed unsupported claims regarding the significant income a typical salesforce member could earn from the Company's business opportunity, including claims that the typical salesforce member could earn full-time income and/or obtain financial freedom through the Company’s business opportunity. The posts at issue were disseminated on Facebook.

The representative claims identified by DSSRC in this inquiry were as follows:

Three Facebook posts stating “financial freedom”
“Whether you’re looking to bring home extra income or grow a full-time business, My Lala offers you the ability to reach your goals!”
“We are expanding this business by helping 1,000 families this year create financial freedom! Earn $50-$100/ hour!”
“Would you like to get some extra income to help with bills, save for a vacation, or something else??”

Company Position

The Company did not attempt to substantiate the earnings claims at issue in this inquiry. Following its receipt of the DSSRC inquiry, the Company promptly began contacting the individuals responsible for disseminating the social media posts to request that the claims be removed. The Company informed DSSRC that none of the individuals responsible for the posts at issue were current salesforce members with the Company. Nonetheless, the Company demonstrated that it attempted to notify these individuals on Facebook and through the email addresses on file with the Company when they were active salesforce members. The Company also contacted Facebook regarding these posts and requested that they be removed. Finally, the Company informed DSSRC that it will comment publicly on these posts on Facebook and state that such claims are unauthorized by the Company.

Administrative Closing Summary

DSSRC acknowledged the good faith actions taken by the Company to effectuate the discontinuance of all of the earning-related social media posts at issue and determined the Company’s actions to be necessary and appropriate.

DSSRC recognizes that removing social media posts that were communicated by inactive salesforce members can be a challenging endeavor for direct selling companies. As DSSRC has noted in previous self-regulatory inquiries, when a direct selling company is made aware of improper claims that were made by an individual who was an active salesforce member when such claim was made but has since become an inactive salesforce member of the company, DSSRC acknowledges that the direct selling company may not be able to require such salesforce members to remove a social media post. In that instance, DSSRC nonetheless recommended that the direct selling company make a bona fide, good faith effort to have the improper claim removed.

In previous self-regulatory inquiries, DSSRC has also recommended that the Company take additional steps to remove such claims from the marketplace including utilizing any mechanism that social media platforms may have for removal of trademark or copyright violations. In addition, DSSRC noted that companies in past DSSRC inquiries have also posted a comment on the applicable social media platform indicating that the subject post is not authorized by the company and that it has requested that the individual responsible for the post have it removed.

Here, DSSRC determined that the Company made a bona fide, good faith effort to have the claims at issue in this inquiry removed by attempting to contact the individuals that disseminated the claims on Facebook and at their last known email address, reporting the claims directly to Facebook and requesting that they be removed, and committing to comment on the posts publicly to state that they are not authorized by the Company. Based upon the Company’s good faith efforts to address the claims identified in this inquiry, DSSRC administratively closed the inquiry.

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