What Made News?
In a recent letter, the Federal Trade Commission (FTC) alleged
that a promotional contest on Pinterest violated Section 5 of the
FTC Act. Although the FTC did not take any direct enforcement
action against Cole Haan, the letter forced Cole Haan to
discontinue the contest and is one of the first instances in which
the FTC has offered an opinion about what it takes to keep social
media contests and promotions on the right side of federal
advertising laws.
What was Cole Haan's Promotion?
In its "Wandering Sole" promotion, Cole Haan
instructed participants to create boards on the social media
platform Pinterest titled "Wandering Sole." Participants
were required to post five images of Cole Haan shoes to their
boards along with five images of the participants'
"favorite places to wander." Participants were also
required to "tag" each pin with the hashtag
"#WanderingSole." The participant with the most creative
entry was eligible to win a $1,000
