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  Disclosure: Manifest Technology Site

FTC Disclosure Statement (12/2009, updated 1/2010)

If you're the kind of person who would be shocked to discover that celebrities are paid for their endorsements in late-night infomercials, or would be horrified to discover that Google Ads are advertisements and Amazon product links have to do with selling products, then the Federal Trade Commission is stepping up to protect you -- from evil bloggers!

Yes, the FTC has issued Guides Concerning the Use of Endorsements and Testimonials in Advertising, imposing new rules and "guides" as of December 1, 2009:

Guides Concerning the Use of Endorsements and Testimonials in Advertising
    Effective Date December 1, 2009, 81 pp.

Press release: FTC Publishes Final Guides Governing Endorsements, Testimonials
    Changes Affect Testimonial Advertisements, Bloggers, Celebrity Endorsements, 10/05/2009

While most of the 81-page document is concerned with claims made by advertisers and celebrity endorsers, it also worries about Mommy bloggers: "... an individual who regularly receives free samples of products for families with young children and discusses those products on his or her blog would likely have to disclose that he or she received for free the items being recommended."

However, the guidance in this document is provided in the form of examples of situations that could trigger disclosure, omitting both clear, specific requirements and any discussion of the form of such disclosure. Sigh.

(Interestingly, the FTC is not concerned about such reviews in what it calls "traditional media" -- so newspapers, magazines, and television and radio stations can continue to enjoy press junkets without government supervision. Mommy bloggers are much more dangerous!)

So, while I've been clear about describing my background and industry relationships on my website (and associated blog), I'll take an extra step here. In general, while I'd prefer that you not consider me as on the take, you should assume that companies have provided samples of many of the products that I discuss on my site.

In particular:

- I have long-term relationships with people and companies in the digital media and technology industries, from my development positions at Sarnoff and Intel, my books and articles, my consulting, and my expert witness work. I also have worked with these companies in organizing presentations at professional meetings and conferences. As discussed on my site, I have been compensated for consulting work for some of the companies that I cover, and for expert witness work related to disputes between such companies.

- I attend industry conferences and events, where attendees may acquire tchotchkes or swag including but not limited to pens, pins, those balls that flash when you bounce them, and t-shirts.

- I attend press events, at conferences and other company press tours, which may provide free food, more swag, and product samples, as well as bags to carry it all. Occasionally, companies may provide travel or housing assistance for such events.

- As is standard in the industry, some information from companies can be provided as previews under non-disclosure agreements, typically until a product announcement date (or is revealed by leaks). I also may work with beta versions of products, or participate in formal beta programs under similar agreements.

- I also obtain product samples in preparation for assigned articles, and solicit samples for my talks and other coverage. These may include software, hardware devices, online services, books, and other materials.

- While some companies arrange to provide review copies of products for a limited loan period, many companies are not interested in having product samples returned, including most software and smaller products that cannot be usefully reused. I also may explicitly request long-term demo units of some products to demo at my various talks and other events.

- I do not profit monetarily from any sample products, such as reselling them online. I tend to keep products around for demos and historical comparisons. Products then are explicitly gifted or donated. I also may solicit additional product samples for handouts at meetings or donations.

- The only direct income from my site comes from Google Ads and Amazon links, as used on many other sites all over the web.

- The Google Ads appear in standard locations on sides and bottom of the pages of my site. You can identify the Google Ads because they are isolated in separate sections on the pages, marked "Ads by Google." The ads are placed by Google using some secret process based on the content of the pages. As usual on the web, Google pays me a fee based on what happens when people click through the ads.

- I also typically use Amazon affiliate links when discussing a product, since it allows readers to click though to see additional product descriptions, user reviews, and current street pricing. You can identify the Amazon links because they are typically identified by the Amazon logo, and the verbiage "Find the <product name> on" As usual with Amazon affiliate links, Amazon pays me a fee when readers click though and buy from the Amazon site.

Update: Another big surprise -- I have investments in stocks and/or bonds in individual companies and/or funds that typically include various technology companies, some of which I expect to continue to cover.

Bottom line: I look at lots of products. You should expect that many are provided by companies for this purpose. I also receive various food, tchotchkes, and other materials at various industry and press events. I don't profit from these. I have other long-term relationships and occasional business relationships with some companies, which have been explicitly disclosed on this site (when not confidential). And in case you haven't noticed, I use Google Ads and Amazon affiliate links on the site to help defray my costs.

Yeesh! Do you feel safer now?