October 22, 2009

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The FTC's Firestorm over Blogging The Federal Trade Commission (FTC) revisited its Guides Concerning the Use of Endorsements and Testimonials in Advertising , the rules on truth in advertising, for the first time since 1980 and applied it to bloggers. A firestorm of criticism erupted. But I don’t get it on several levels. For years people pretending to be consumers have been posting blog comments, reviews, criticisms, endorsements, features, benefits, images, schematics and other content pretending to independent advocates of brands and causes. Whole firms of these fakeroo posters peddle this service to brands desperate from buzz and new customers. A few years ago Wal*Mart’s PR agency Edelman got busted for this kind of abuse. Bloggers, me included, are always looking for freebies and swag. I’m still jealous that when Jeff Jarvis said he was in “Dell hell” he got a laptop. When I posted my “Dell hell” story I got a snotty call from a Dell flack. Over the years, I got a few books to review, a few t-shirts and a mountain of white papers and reports that the authors’ often charge for. I haven’t shilled for anybody and I’ve tried to be equally critical of everyone; sometimes ranting and sometimes praising. My goal is to disclose everything, take nothing and hold on dearly to my digital bully pulpit. It’s only sensible that bloggers should be transparent and ethical in revealing who is schmearing whom. Payola poisoned broadcasting and print media and has probably played an unfair role in the growth of blogging and other forms of social media. The FTC mandates that disclosure must be “clear and conspicuous” whatever that means.Commercial and endorsement relationships must be disclosed. Wild ass claims are out of bounds as is masquerading as someone or something you are not. The rules kick in on December 1st and penalties include $11,000 in fines per violation. This seems right to me. Bloggers, like journalists, should strive for integrity and transparency by disclosing their allegiances, alignments and paid endorsements. Bloggers also should be subject to libel and slander laws and should adhere to the same code of conduct as journalists and corporate officers. So why did the editors of Ad Age work themselves into a lather calling the FTC blog rules “excessive, ridiculous, hypocritical and likely unconstitutional?’? Because the rules are vague, difficult to understand or enforce, policed by bureaucrats subject to political influences and Obama’s direction and they come down harder on new media than old media. Who knew that Ad Age was such a digital defender? They’re not. They are just anti-regulation across the board for advertising. Today the New York Times weighed-in arguing that the regulations are not onerous and will probably protect the public. I agree. In this case, the shot across the bow is warranted. In cyberspace all kinds’ of shenanigans have gone on for more than 10 years. It is time to rattle the regulatory saber and close down the crooks, charlatans and cheaters. Even if it takes some ham-fisted FTC action, we can find the equilibrium, as needed, through the courts.
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5 Facebook Brand Success Factors Facebook is becoming a marketer's fad and fantasy. Its growth in members, daily use and search frequency make it the place to target discrete customer groups or desirable segments and earn "early adopter" social media bragging rights. But Facebook isn't a cakewalk. In fact, very few brands can or will report measurable results in awareness, preference or sales as result of Facebook campaigns. Most of us are in a test-and-learn mode experimenting with the nuances of the Facebook platform and trying to fit this channel into an integrated brand messaging or marketing strategy. The first critical understanding is that Facebook is an empty pipeline not an on-going party. And while zillions are joining and using Facebook, they aren't interacting with you or your brand ... yet. Marketers have an affirmative burden to create connections and traffic to energize brand interactions. Just like print, radio or TV, on Facebook you have to find, engage and develop a unique audience for your brand. There is no plug-and-play community. It's not a silver bullet. Setting up a page or buying an ad flight merely gives you access to the masses. How you get them connected, opted-in and feeling good about your brand is your problem. To help leverage this channel for optimum impact, here are 5 key considerations to improve your Facebook campaign culled from a wide range of sources. Develop a Posture and Voice. Social media is about interacting with customers and prospects. If each brand has a distinct personality, that personality needs to be present on Facebook. Before you do anything you have to figure out how your brand personality will be be presented and what kind of posture and voice you will take in this channel. To figure this out ask yourself -- If your brand went to cocktail party how would it act? Is your brand an extrovert madly working the room or an introverted wall flower coyly batting her baby blues at selected hotties? What would it say? How would it dress? What opening lines would it use or not use? Who would it schmooze with? Who would it avoid? The answers to these anthropomorphic questions should be your best creative guide. Pick a Page Type. Brands can have "group" pages or "fan" pages. Each has distinct properties and technical capabilities. Facebook set it up so neither is ideal. So putting your brand on Facebook means making an initial critical choice of page type. Groups have friends which means your access is limited and messages are delivered to friend's "home" pages. Businesses have "fans" which means anyone can see your page but messages are delivered to the Updates page, which people check less frequently. Each type of page connects to other applications, notably traffic-building apps like "Causes" or "Events," with specific limitations. The current thinking is that Fan pages offer more flexibility and options for marketers, but that could change as Facebook refines or changes its infrastructure and gets savvier about marketing through more daily interactions with brands and agencies. This is a fluid situation worthy of careful investigation and consideration. Create Strategic & Media Context. A Facebook page doesn't exist alone or in a vacuum. To be effective it has to be part of your brand's online ecosystem; the web of distributed messaging that is strategically placed online to intercept and interact with your most likely prospects and customers. Before you create a presence you have to determine what will the page link to and what is the overlap of information, messaging and outreach between or among your web assets. Figure out what job your branded website will play. Where will e-mail, text, mobile or banner campaigns direct or deliver the responders? What will content you place on YouTube or Flickr? How will it relate or not relate to the Facebook audience? Will you use Wikipedia, MySpace, Friendster, Baidu or LinkedIn to reinforce or extend the message to specific segments or target subsets or will it be used as a straight frequency extender or as an exclusive platform for a specific message or offer? Also how will you drive traffic and get your message to the intended audience? Will you use Facebook ads or other ad vehicles to build your following? Once that is determined, you can assign unique objectives and content to Facebook as part of a larger marketing effort. This should be geared directly to brand goals and targeted by psycho-demographics. Craft Content. Social media is about entertainment, information and interaction. What do you want...

Danny Flamberg

I am a veteran marketing consultant working with leading and emerging brands

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