FTC Rules Against Cole Haan Pinterest Contest, Says Full Disclosure Was Ignored

Wandering Sole Contest and FTC Disclosure

The U.S. Federal Trade Commission has ruled that a Cole Haan contests asking customers to pin product photos on Pinterest violated the Federal Trade Act.

The company’s “Wandering Sole” contest offered one lucky Pinterest user a $1000 shopping spree, but only if they shared the company’s products with their followers.

In a letter to the Cole Haan legal team, FTC associate director Mary K. Engle, writes:

“The contest rules instructed contestants to create Pinterest boards titled ‘Wandering Sole.’ The contest rules further required that a board include five shoe images from Cole Haan’s Wandering Sole Pinterest Board as well as five images of the contestants “favorite places to wander.” Finally, contestants were instructed to use ‘#WanderingSole’ in each pin description. Cole Haan promised to award a $1,000 shopping spree to the contestant with the most creative entry.”

According to Engle, the issue came down to a lack of disclosure:

“We believe that participants pins featuring Cole Haan products, and the fact that the pins were incentivized by the opportunity to win a $1,000 shopping spree would not reasonably be expected by consumers who saw the pins. Moreover, we were concerned that Cole Haan did not instruct contestants to label their pins and Pinterest boards to make it clear that they had pinned Cole Haan products as part of the contest.”

The FTC says a simple hashtag listed as #WanderingSole was not enough to mark each pin with full disclosure.



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