DSSRC Administrative Closure #232

The Direct Selling Self-Regulatory Council (DSSRC) initiated an inquiry regarding six earnings claims and one product performance claim communicated on social media posts disseminated by salesforce members of a direct selling company (“the Company”). Six of the identified claims were disseminated on Facebook and the remaining claim was communicated on a YouTube video.

More specifically, DSSRC expressed concern that salesforce members’ claims referencing “unlimited earnings,” “residual income” and “making money while you sleep communicated the message that consumers and potential salesforce members can earn significant income through the Company’s business opportunity while expending little time or effort. The one product claim identified by DSSRC suggested that product users can “take less medication” as a result of the product’s efficacy.

The Company agreed that the claims at issue were inappropriate, explained that such representations were prohibited by the Company’s Policy & Procedures and immediately removed all of the Facebook posts at issue. With respect to the YouTube post, the salesforce member responsible for posting the video designated the video as private. DSSRC informed the Company that while private videos may no longer be available on the internet to a general audience of consumers, because private videos may nevertheless include claims that are unrepresentative and not appropriately qualified, these videos should not be disseminated to even a limited audience in the context in which they were originally communicated. The Company salesforce member subsequently disabled the video in its entirety within 48 hours.

DSSRC appreciated the Company’s god faith efforts and noted that the actions taken by the Company were necessary and appropriate.

Based upon the prompt removal of the posts at issue and the Company’s efforts to address DSSRC’s concerns, this matter was administratively closed.

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