Cole Haan devised a contest encouraging Pinterest users to create boards called "Wandering Sole." As a creative pun, people were instructed to pin five pictures of Cole Haan products and five places. It was a cute idea, but the Federal Trade Commission (FTC) expressed concern about people getting rewarded—$1,000 for winning the contest—without admitting the connection between their posts and the potential monetary award.
In a letter to Cole Haan, the FTC admonished Cole Haan:
The FTC is concerned about deceptive social media practices. An easy solution, according to a MediaPost article, is for Cole Haan to have people indicate that their posts were part of a contest. An advertising lawyer suggests, "A hastag that included a word like 'sweeps,' or 'contest,' or 'giveaway,' would have satisfied the FTC's concerns."
- What's the rationale for the FTC rule? What situations can you think of where this may be a significant issue? Or, do you think this rule is just silly?
- How, if at all, do you think adding the word "contest" would have affected this promotion?