A Future without Case Studies? 5 Conclusions about the New FTC Rules
Suddenly, the marketing world is in a panic over the new FTC rules regarding endorsements (testimonials).
It’s December, and the new guidelines went into effect yesterday.
Some are asking, should we pull down every customer testimonial, success story and case study?!
Don’t panic.
While it sounds bad, the impact on case studies may be minimal compared to stand-alone testimonials. Even then, there are ways testimonials can comply.
After reading the official guidelines and various interpretations, here are some of my conclusions:
(Note: This is my take on the guidelines – and I’m not an attorney.)
Conlusion #1: Stand-alone testimonials need to be clarified
Testimonials expressing satisfaction or opinion - without mentioning results – usually seem to be OK.
It’s those with specific results that are a particular problem. Consumers can’t really know what’s behind them or if results are typical.
Yet, statements such as "results not typical" are no longer valid under the guidelines.
Here’s a sample problem statement from the FTC doc:
“I lost 50 pounds in 6 months with WeightAway."
Who knows whether this is typical or what went into these results?
Under the new guidelines, testimonials with results can’t omit the "how." Endorsements must have context.
Here’s the FTC’s revised example:
“Every day, I drank 2 WeightAway shakes, ate only raw vegetables, and exercised vigorously for six hours at the gym. By the end of six months, I had gone from 250 pounds to 140 pounds.”
It’s not as crisp and succinct, for sure. But it explains much more accurately what went into the weight-loss results.
IF this is typical of someone who drank the shakes, ate well and exercised that much, then it’s fine.
If not typical, then use of such a testimonial requires you to mention what the typical result would be with this combination.
Conclusion #2: Case studies likely BENEFIT from the new rules
As noted above, a glowing testimonial of a sentence or two ususally doesn’t show the full context.
I have to give Michel Fortin credit for being the first to point out that case studies just may be the answer in many cases.
Customer case studies are intended to go beyond just the results – to show what’s behind the numbers.
By showing the path to success, you eliminate the ambiguity or the implication that magically plugging something in produces success. There’s usually more to it.
To that end, if you write or manage customer stories, make sure that you accurately portray the steps that led to success – which may be more than just your solution.
That may mean fleshing out success stories a bit so they are not just overviews but more detailed accounts.
Also, instead of pulling out specific results quotes from case studies and using them elsewhere, you may need to get customer approval on a second version of each quote that can be used as a stand-alone.
Conclusion #3: Check back with customers regularly
I listened to a recent webinar that Jim Edwards conducted with Richard Cleland, assistant director in Advertising Practices at the FTC.
Cleland clarified a lot of questions.
He also pointed out the importance of updating your endorsements regularly.
Technically, if you’ve left your testimonials and customer stories up for a year or so, you should check back with customers on whether they still feel the same way.
Doing so may even result in updates that make your testimonials or case studies stronger.
Conclusion #4: Introduce affidavits or modify release forms
Cleland also suggested that customers sign an affidavit that their statements are in fact true at that time.
Many legal release forms have wording to this effect. If you use email approvals, you might want to create a very short affidavit doc or email approval string that has wording to address this.
Conclusion #5: The guidelines aren’t totally clear
Even with example scenarios in the doc, the guidelines are still a bit fuzzy when you try to apply them.
At times, it seems a few words can make the difference between compliance or non-compliance.
Just keep in mind the intention of the newly clarified guidelines. They’re intended to protect us from misleading and fraudulent claims.
If we simply learn how to work with them, they’re a good thing for us all.
The FTC has said that, if by chance you are out of compliance, you will receive a warning and a chance to fix the issue.
Over time, these should become clearer, as we learn what real-world examples the FTC finds out of compliance.
Next steps:
Evaluate your inventory of testimonials, success stories and case studies per the guidelines.
Update or get new approvals of old endorsements.
Decide whether you need to revise or add affidavit language into any approval documents.
- Additional resources:
FTC guidelines
Michel Fortin’s blog post
Joel Comm’s blog post
Jim Edwards’ webinar with the FTC
How are you changing your case studies and practices to fit these new guidelines?
Case Studies in Action – Alibaba’s Hybrid Success Story Campaign
The last page of October’s Fast Company magazine took me down a rabbit hole – and I enjoyed the ride.
I’m always on the lookout for creative uses of customer case studies and success stories, and Alibaba.com delivered with a campaign that combines traditional print advertising with the online world, while also mixing real customers with actors – but not at the same time.
It’s an interesting effect.
Alibaba.com helps business owners find suppliers, manufacturers and other resources online to help them make and sell products.
A lot of companies use "fake customers" in their ads (think detergent ads). And some use real customers (Geico, Visa, etc.).
But Alibaba uses both. Here’s how:
1. The print ad features two guys, supposedly customers, holding their product, a robot. Below the photo, it encourages me to get the full story at success.alibaba.com.
2. The website shows Flash-animated sets of three business owners, each with a story. Choose one and you get a funny video featuring those customers talking about their businesses.
Here, the company’s using what I believe are actors to make the point about what Alibaba does and how.
3. But if I click on the Success Stories tab on that page, I get what are definitely several real customer success stories. Clicking on one story initially launches a summary of that customer story in a frame, and then I can take the link for "the full story."
4. For the full story, it pops up a PDF called "Success Stories Booklet." I love this idea.
The booklet has about a dozen one-page stories about actual business owners, with their locations and types of businesses.
What I like about this is, at each step, this campaign lets the audience completely control how much information they want. You can get deeper and deeper into the campaign, and all the while, you are getting the same message about proven success with Alibaba.com.
If I had something to sell on Alibaba.com, I’d be sold on trying them out.
What about you? Do you think the offline/online campaign works? And does the mix of actors/real customers provide the proper level of authenticity to be convincing?
Customer Successes in Advertising: AT&T’s “Small Business Moments”
While reading Fast Company magazine, I came across an AT&T ad featuring a customer success story. The ad’s headline read "Chad Harris’ Small Business Moment."
It went on to highlight, in a paragraph, how the business owner seized an opportunity with his smartphone and AT&T Small Business Solutions. He checked inventory, got pricing and submitted a bid – all from a remote jobsite – and won the job. The full-page ad also features what looks like a stone monument of Harris with his smartphone in one hand and a shovel in the other.
It’s attractive and engaging – and a great example of using customer success stories in advertising. The ad encourages readers to read about more of these moments online.
In advertising, you can capture customer success stories in short snippets like this or in longer advertorials. But no matter which length you choose, it has to tell a story. AT&T succeeds in telling this story in 5 sentences.
I’m always on the lookout for great examples of using customer stories in sales, marketing and PR. Anytime you run across one, let me know!
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