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FTC Decides to Close Its Investigation on Hyundai and Their Blogger Outreach Campaign


During Super Bowl XLV, Hyundai hired a PR firm to handle a blogger outreach campaign to build buzz around their Super Bowl commercial. The bloggers were asked to write about the commercial, featuring the Hyundai Elantra, and were given a gift certificate in exchange.

But there was a problem with the campaign. There was no disclosure that the bloggers received something in exchange for the promotion, as the FTC requires.

Needless to say, the FTC launched an investigation to find out if the bloggers had indeed been told to disclose to their readers that they had received a gift certificate, in exchange for posting about the Hyundai commercial. The end result? The FTC recently announced they have closed the investigation and gave their reasons why in this letter.

Here are two of the main reasons why the investigation was closed:

  • “First, it appears that Hyundai did not know in advanceabout use of these incentives, that a relatively small number of bloggers received the gift certificates, and that some of them did, in fact, disclose this information.”
  • “Second, the actions with which we are most concerned here were taken not by Hyundai  employees, but by an individual who was working for a media firm hired to conduct the blogging campaign.”

Although no action was taken, Lesley Fair of the FTC’s division of advertising practices, wrote in a blog post that the closing letter from the FTC is worth a read if your company uses social media in its marketing.

He also gave these guidelines for companies needing more guidance when it comes to complying with the FTC policies:

  • Mandate a disclosure policy that complies with the law
  • Make sure people who work for you or with you know what the rules are
  • Monitor what they’re doing on your behalf

The FTC may have closed the investigation and Hyundai escaped something that could have been real messy for the company, but this definitely teaches all of us a lesson – the FTC is paying attention to disclosure policies, so make sure you have one and it’s stated clearly.

Do you feel bloggers are doing a good job disclosing what they are receiving in return for working with a company? And, for those you who regularly work with companies and PR firms on outreach campaigns, do they clearly state a disclosure policy is required?

Five Tired Tactics for Blogger Outreach


If you’ve seen Christmas Vacation, you know the scene. Clark Griswald has been anxiously awaiting his bonus. Then it arrives, but instead of cash he gets enrolled in the Jelly of the Month Club. So yeah. He loses it.

It is just as appealing for bloggers to get paid with stuff.

Yet many companies and firms doing outreach to bloggers avoid cash like it’s infected. It doesn’t even make sense from a bottom line standpoint. How many man-hours did you (or your firm) waste reaching out to hundreds of bloggers to get just a few nibbles? Did you pay your firm thousands, none of which actually reached a blogger?

Firms, are you including a component of paying a blogger when you propose an outreach campaign? I will no longer handle any blogger outreach campaigns unless there is pay for the bloggers. Let’s just say I haven’t been doing much blogger outreach.

I recently submitted a query on Help a Reporter Out seeking firms and companies that have paid bloggers cash in any fashion (advertising, spokesblogging, sponsored posts or writing posts for the company, consulting, whatever), offering to highlight these case studies on my blog. Usually, when I submit a query there I get bombarded with replies. I received three replies, and one wasn’t directly paying bloggers (it was a forthcoming pay per click advertising type of program).

Here is the secret to wildly effective blogger outreach: pay the bloggers actual money. This isn’t a new concept. I hear it repeated at every blog conference I attend (in fact, it was the subject of my panel at the recent Blog World Expo), I see bloggers posting about it, I see active conversations about it on Facebook and Twitter.

Still, I see the same pitches repeatedly in my in-box offering nothing, little, a possible chance to get stuff, or stuff in exchange for advertising and promotion.

I keep witnessing the same tired tactics for blogger outreach:


I want to first say a couple of things. One, reviews are editorial and I don’t believe a company should pay a blogger cash or anything beyond providing the product to test in order to get a review. It ceases to be a true, unbiased review at that point. It can be sponsored content and disclosed as such, but it shouldn’t be called a review.

Also, I am not suggesting companies stop seeking reviews from bloggers. But the lion’s share of pitches I receive are seeking reviews. It should just be one piece of the pie. It has been so overdone, despite the fact that many bloggers do not do reviews and many lack the time it takes to properly do many, if any, reviews.

Sure, seek out reviews as one part of the blogger outreach. It shouldn’t be the default. I wonder how the PR+advertising investment (time, energy and money) into seeking reviews compares from traditional media to new media. I’m betting there is a huge disparity.


Blog contests have become so over-saturated in the space. Unless the prize is high dollar or highly appealing, these contests can just become part of the noise. Beyond that, it takes an awful lot of time to run, maintain, promote, follow up and do all the demanding tasks that a contest requires. Also, a contest is a promotion. Perhaps if you will seek out contests as part of blogger outreach, offer an outstanding prize and pay the blogger for the work and promotion.

What’s even worse is pitches asking bloggers to promote a company’s own contest, not even offering a contest hosted by the blogger. Unless a blogger runs a site about contests, I can’t imagine a reason for them to do it.

Payment in Gift Cards and Products

I’m sorry, but what is the deal with this? It seems pervasive lately. Why pay in gift cards or products instead of cash? I know that many times, providing the gift cards or products is cheaper. Even if that is the case, consider offering bloggers the option of cash (even less cash) or the gift card or product. No one wants to get paid with the Jelly of the Month Club.

Ambassador Programs

I am generally fine with the concept of ambassador programs and spokesblogging. What is less appealing is that these programs often offer very little for the blogger, but ask for promotion on social networks, blog posts and badges (ads) on their sites. Sometimes, the best that is offered in return is a link from the company’s site (sometimes a new microsite that gets no traffic). It is great to create ambassador programs, but pay your ambassadors.

Payment in Contest Entry

This has to be the most boggling of all of the tactics I’ve seen. The blogger writes a post in exchange for the possible, perhaps, maybe chance to get something (not cash, of course, but a prize of product or gift card). I’m not even sure what else needs to be said about that tactic.

Here’s the thing. Companies and firms probably don’t know when their pitches are tired. Most bloggers don’t reply to the bad pitches to tell you what’s wrong. Instead, companies hear from the few bloggers who do reply and get the illusion the outreach was successful.

This really isn’t rocket science. If you want success getting promotion in new media, the money needs to trickle down to the bloggers you want doing the promotion.

Kelby Carr has been social networking online since 1984, building web sites since 1994, blogging since 2002 and tweeting since 2007. She runs an annual blogging and social media conference, Type-A Parent Conference (formerly named Type-A Mom Conference). She also runs an online hub for digital moms and dads, Type-A Parent, is reinventing journalism at Investigative Mommy Blogger and blogs about social media at KelbyCarr.com.

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