Tuesday, November 12, 2013

Week 7 Topic Post: Commercial Speech

http://law2.umkc.edu/faculty/projects/ftrials/conlaw/camelad.jpg

Topic Overview

Commercial speech is the term used to distinguish ads proposing commercial transactions from other kinds of ads. Advertising means commercial speech. The Court affirmed the ability of governments to regulate advertising and suggested that a FA interest could be served by advertising a commercial proposal, and the interest could outweigh the government’s interest in regulating advertising. Determining the type of speech conveyed in ads are weighed between purely commercial speech and ads that contained factual material of clear public interest in addition to a proposed commercial transaction. Speech is not stripped of FA protections because it has they are paid commercial ads. While untruthful express could be regulated, the law is more tolerant of error and falsehood in a political content than of speech in the commercial arena. In the Central Hudson case, the court developed a test for bans and ruled that gov regulation is constitutional only if there is a substantial state interest that justifies the regulation, the regulation directly advances that state interest, and the regulation directly advances the state interest through the least speech restrictive means possible. Now there only has to be a reasonable fit between the regulation and state interest making it easier for advertising regulations to pass the test and be ruled constitutional.

A federal law prohibiting information about alcohol content appearing on product labels or in advertising to prevent strength wars failed the Central Hudson test. It failed because there are alternatives that would be less intrusive on the commercial speech’s FA protections. A law against advertising bargain prices on alcoholic beverages because it would increase consumption did not hold up in court ruling it fails to establish a causal relationship between its abridgment of commercial speech and achieving its goal of temperance. Withholding information about price does not work to decrease drinking.

There is a legitimate state interest in regulating tobacco advertising: preventing minors from accessing tobacco products. Regulations and restrictions on tobacco products upheld because the state’s interest was unrelated to the communication of ideas. Clinton the FDA to initiate steps to stop sales and marketing of tobacco to children and had the authority to regulate tobacco products. The industry agreed to stop billboard and transit ads and cartoons. The Public Health Smoking Act of 1969 required a ban on tobacco ads on broadcast TV and radio stations. Tobacco company free speech rights were not infringed because they had other advertising outlets.

While there is a substantial state interest for reducing the social costs associated with gambling, laws banning broadcasters from airing ad for legal casino gambling did not advance this interest and was not as narrowly tailored as could be. Prohibiting ads for private casinos but allowing it for others only steered gamblers to specific outlets rather than others.

Court found law prohibiting lawyer service ads in violation of the FA. The ruling emphasized it stopped short of granting a blanket endorsement to attorney advertising. Reasonable restriction pertaining to false advertising could survive the FA.

The Court upheld the right of corporations to communicate through purely political speech; political speech has more FA protection than commercial. In Nike’s case, speech was ruled commercial and could not be punished under state false advertising and unfair competition laws. Nike engaged in commerce, the intended audience was largely composed of potential Nike customers and the speech consisted of representations of fact of a commercial nature that were intended to maintain and increase sales of Nike products. Nike argued that although false, speech was absolutely protected by the FA because it was political in nature concerning discussions about factory working conditions and not commercial speech involving things like products and prices. The Court dismissed the case stating the plaintiff did not suffer sufficient injury to file a lawsuit. This case is seen as a missed opportunity for clarifying commercial speech.

Advertising is subject to regulation on the state level, but the federal gov has most responsibility mostly because ads cross state lines; falling under the Constitution’s commerce clause, Congress may also control it within FA limits. The Lanham Act prohibits any false/misleading description of goods, services, or commercial activities in any forum including ads and promos. It became the foundation for lawsuits as ads grew into comparative ads.

The FTC was established in 1914 as an independent agency that reports to Congress. It I headed by five commissioners nominated by the president, confirmed by Senate, each serving a seven-year term. One acts as chair and no more than three can be of the same political party. It protects consumers from unfair/deceptive practices by businesses and is the primary federal regulator of advertising. It has the authority to demand that advertisers substantiate accurate claims. The FTC included the Bureau of Consumer Protection, which protects against unfair/deceptive/fraudulent practices. The Division of Advertising Practices is a division of the bureau and is the enforcer of federal truth-in-advertising laws focusing on: deceptive ads of fraud cure-all claims for dietary supplements and weight loss products, deceptive internet marketing practices for health issues, enforcement strategies for new ad techniques and media, ads of food to children like impacts on obesity, industry practices regarding marketing violent media, and alcohol and tobacco marketing practices. Puffery is fine if it is not deceptive and if advertisers have adequate substantiation before a claim is made. A literally true statement can have deceptive implications when considered in the context of the whole ad even if it is not the only possible interpretation.

The FTC is made aware of potentially problematic ads by complaints from consumers, businesses, etc. FTC investigations are generally nonpublic to protect the investigation and companies involved. Measures are taken to protect the public.

Preventive measures: advertiser advice is requested in an opinion letter from the FTC. The advice does not bind the commission in any way but it can be an efficient way to avoid ad problems. Advisory opinions contain more info and are more official. It is placed in public record making the FTC accountable to its advice so opinions tend to be harsh with a heavy obligation to adhere to them. Industry guides outline policies concerning a particular category of product or service. They are intended to prevent future problems wtih testimonials, endorsements, etc. They affect celebrity endorsements and est. practices of broadcasters and new media companies. Endorsers are liable or false claims and “results not typical” disclaimers do not excuse endorsers or companies from responsibility. Material connections like payments must be disclosed, warnings to understand guidelines and guidelines are directed at nontraditional ads like celebrity endorsements. The trade regulation rule targets an entire trade allowing the FTC to deal with an entire group of advertisers at once. Under the commission’s voluntary compliance function, advertisers have the opportunity to comply with complaints that the judges to have merit.

Corrective measures: A cease and desist order demands the stopping of one or more advertising practices. It is contained within a consent order/consent agreement. A consent order is for settlement purposes and does not constitute an admission of guilt by the advertiser. Failure to sign it will likely generate negative publicity and the FTC is likely to impose severe penalties. If they choose not to, the FTC can issue a litigated order to stop an ad claim filed in an administrative court. If it is upheld, the advertiser may appeal to a fed court can result in serious fines. Substantiation gives the FTC authority to demand an advertiser prove its claims—to provide competent and reliable evidence for claims made. The FTC may require corrective advertising—to set the record straight in future ads or other kids on info distribution. Listerine was the first corrective advertising case. A court injunction or a restraining order can be used if ads are false/misleading and cause immediate harm (credit card claims for reducing debt).

The FCC is the primary regulator of advertising cut the FCC can deal with problem ads in broadcast media and the FDA can deal with ads for products within its influence at least indirectly.

Advertisers view Internet advertising as cost effective. Technology allows them to gather data on user activity for marketing purposes (data mining), which is controversial. The instantaneous nature of Internet ads have created fraud and unwanted ads across the Internet. The FTC monitors illegal practices on the Internet and enforces laws against fraud online advertisers in other media. The first deceptive Internet ad case was in 1994; ads advising consumers to take illegal steps to repair credit records. A consent decree required the advertiser to est. a compensation fund, not engage in future misrepresentations, to disclose future credit programs and to cooperate in FTC investigations. The FTC supports providing “do not track” options like cookie-blocking features to avoid targeting ads. In response to unsolicited, unwanted email or spam Congress enacted the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act under which ISPs, states attorney generals and federal agencies can pursue spammers in fed courts with criminal and civil penalties. The law prohibits the use of false header info in commercial email and requires unsolicited messages to include opt-out instructions. There is also protection against spam with unmarked pornographic material. Penalties include millions in fines and imprisonment. The FTC approved provisions in ’08 to strengthen enforcement.
37 states enacted anti-spam regulations to supplement fed law. The Court ruled the right to engage in anonymous speech was protected by the FA so a law prohibiting false routing info in emails infringed on this FA right.

Key Definitions

Puffery- ads that exaggerate the merits of products or services in a way that no reasonable person would take it seriously

Litigated order- FTC order to stop a specific ad claim

Industry guides- FTC measure that outlines the policies concerning a category of product or service

Trade regulation rule- statement by the FTC that outlines ad requirements for a trade

Substantiation- authority of the FTC to demand an advertiser prove claims made in ads

Corrective advertising- FTC requirement forcing an advertiser to include info in future ads that corrects false or misleading claims in previous ads

Important Cases

1.     Central Hudson Gas & Electric Corp. v. Public Service Commission of New York- ad ban test- Court reaffirmed the constitutionality of regulations forbidding untruthful and misleading ads and prohibition on ads that promote illegal products or services. Gov regulation is constitutional only if there is a substantial state interest that justifies the regulation, the regulation directly advances that state interest, and the regulation directly advances the state interest through the least speech restrictive means possible.
2.     Lorillard v. Reilly- ban on tobacco ads and sales within 1,000 ft of school and playgrounds- Court applied Central Hudson test and ruled ban restricted company’s FA rights and was too broad

Relevant Doctrine

Free Flow of Commercial Information

Supreme Court established several principles concerning advertising
-       Freedom of speech applies to both the speaker and recipient of info. There is a right to receive info.
-       FA protection had never been denied to speech merely because it was commercial.
-       Speech doesn’t lose it FA protection because money is spent to project it, as in a paid ad.
-       Speech does no more than propose a commercial transaction is not so removed from any exposition of ideas that it lacks all protection.
-       Consumer interest in the free flow of commercial info may be as high as, if not higher than, the interest in the day’s most urgent political debate. Even an individual ad, though entirely commercial, may be of general public interest.
-       Particularly in a free enterprise economy, it is a matter of public interest that economic decisions be intelligent and well informed
-       As with other categories of speech, some forms of commercial speech may be regulated. Untruthful speech, for example, has never been protected for its own sake. 

The Commercial Speech Doctrine

-       The gov may regulate advertising that it is false, misleading or deceptive.
-       The gov may regulate advertising for unlawful goods and services.

Even truthful, honest advertising for legal goods and services may be regulated if the following conditions are met:
-       The gov claims a substantial state interest to justify the regulation.
-       The gov demonstrates that the regulation directly advances the claimed interest.
-       The gov shows that there is a reasonable fit between the claimed interest and the regulation.

FTC: False and Misleading Advertising

The FTC Policy Statement explains false and misleading advertising from the commission’s viewpoint:
-       First, there must be a representation, omission or practice that is likely to mislead the consumer.
-       Second, we examine the practice from the perspective of a consumer acting reasonably in the circumstances. If the representation or practice affects or is directed primarily to a particular group the omission examines reasonableness from the perspective of that group.
-       Third, the representation , omission or practice must be a material one. The basic question is whether the act or practice is likely to affect the consumer’s conduct or decision with regard to a product or service.

FTC Mechanisms

Preventive Measures:
-       Opinion letters
-       Advisory opinions
-       Industry guides
-       Trade rules
-       Voluntary compliance

Corrective Measures:
-       Cease and desist orders
-       Consent orders
-       Substantiation
-       Litigated orders
-       Corrective advertising
-       Injunctions

Issues/Controversies

Commercial speech was outside the range of the FA until the court articulated the idea that advertising could be considered speech and was entitled to FA protection. Distinguishing ads as a commercial ad or an informational one as paid political speech sparked the need for determining what kinds of commercial speech would have FA protection.  Issues with determining the type of speech conveyed in ads were weighed between purely commercial speech and ads that contained factual material of clear public interest in addition to a proposed commercial transaction. Speech is not stripped of FA protections because it has they are paid commercial ads. The degree of protection for certain ads and the degree of tolerance for error and falsehood are also issues. There are many who question the fed government’s ability to enforce Internet restrictions and criticize the way the CAN-SPAM Act supersedes stricter state laws.

Questions/Concerns
My only concern is keeping up with FCC regulations. They will constantly be changing and applied differently as various mediums become more pervasive, flexible and ever changing. 

References:   
 Trager, R., Russomanno, J. & Ross, S.D. (2012), The law of journalism and mass communication. Thousand Oaks, CA: Sage Publications.
Image:
http://law2.umkc.edu/faculty/projects/ftrials/conlaw/camelad.jpg  
  

No comments:

Post a Comment