A Pinterest contest conducted by Cole Haan, Inc. recently
resulted in an FTC warning. Shoe company Cole Haan held a contest
via Pinterest that required contestants to create a board entitled
"Wandering Sole." Contestants then had to pin at least
five images from Cole Haan's Wandering Sole Pinterest Board, as
well as five other images of the contestants' "favorite
places to wander," tagging each pin with the hashtag
#WanderingSole.1 Cole Haan promised to award a $1,000
shopping spree to the contestant with the most creative entry.
According to the FTC, the pins of the Cole Haan products were
endorsements, and the $1,000 shopping spree was a material
connection between the contestants and Cole Haan. In 2009, the FTC
revised its Guides Concerning the Use of Endorsement and
Testimonials in Advertising (the "Endorsement
Guides")2, pursuant to Section 5 of the FTC Act, to
require disclosure of any "material connection" between
an advertiser and a consumer's (or
