Sundance Vacations and Travel Advantage Network sell vacation packages. This is a case study of their marketing practices, side by side with FTC Truth in Advertising standards.

1. Write a Review, Get Money Back!
- Connecting the Dots
A quick overview of some FTC Advertising
Endorsement guidelines and how they were
recently specifically extended to online reviews.
Then a step-by-step case study of Sundance
Vacations endorsement practices.

2. What is Astroturfing?
Wikipedia’s definition of astroturfing:
“Astroturing refers to political, advertising or public relations campaigns
that are designed to mask the sponsors of the message to give the
appearance of coming from disinterested, grassroots participants.
Astroturfing is designed to give the statements the credibility of an
independent entity by withholding information about the source’s financial
connection.”
http://en.wikipedia.org/wiki/Astroturfing

3. What Does the FTC Think of Astroturfing?
Copy and Paste from FTC Site:
Suppose you meet someone who tells you about a great new product.
It performs exactly as advertised and offers fantastic new features.
Would that endorsement factor into your decision to buy the product? Probably.
Now suppose you learn that the person works for the company
that sells the product – or has been paid by the company to tout
the product. Would you want to know that when you’re
evaluating the endorser’s glowing recommendation?
You bet. That common-sense premise is at the heart of the
revised Endorsement Guides issued by the Federal
Trade Commission (FTC), the nation’s consumer
protection agency.
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking

4. What Does the FTC Think of Astroturfing?
In 2009 the FTC revised their “Guides Concerning the Use of Endorsements
and Testimonials in Advertising.” It was the first time they’d updated this guide in 29
years and it specifically addressed social media.
From the FTC:
"The revised Guides also add new examples to illustrate the
long standing principle that “material connections”
(sometimes payments or free products) between
advertisers and endorsers – connections that consumers
would not expect – must be disclosed."
http://www.ftc.gov/opa/2009/10/endortest.shtm

5. What Does the FTC Think of Astroturfing?
Question :Why did the FTC revise its Endorsement Guides to include social media?
FTC Answer: The FTC revised the Guides because truth in advertising is important in all
media – including blogs and social networking sites. The FTC regularly reviews its guides
and rules to see if they need to be updated. Because the Endorsement Guides were
written in1980, they didn’t address social media.
The legal principles haven’t changed. The FTC revised the
examples to show how these standards apply in today’s
marketing world.
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking

6. What Does the FTC Think of Astroturfing?
Question: My Facebook page identifies the company I work for.
Should I include an additional disclosure when I talk about how great our
products are?
FTC Answer: It’s a good idea. People reading that discussion on your Facebook page
might not know who you work for and what products the company
makes. And many businesses are so diversified that
readers might not realize the products
you’re talking about are sold by your company.
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking

7. What Does the FTC Think of Astroturfing?
"If there’s a connection between the endorser and the marketer of
the product that would affect how people evaluate the endorsement,
it should be disclosed.” – FTC
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-
guideswhat-people-are-asking

8. Sundance’s Review Incentive
A Sundance advertisement:
Write a review online, be entered
Into weekly raffle, winner refunded
their $99 processing fee.
Specifically directs people to Google,
Yahoo, Facebook, Yelp or your
own personal blog.
The attached directions specifically
instruct clients to like their facebook
page.

9. Sundance Vacations Facebook Page
• No mention of the
promotion, no disclosure of
the promotion
• You will not find negative
comments. Negative
comments are deleted.
http://www.facebook.comSundanceVacations?

10. 2/13/13
Just another day over at the Sundance
Vacations Facebook Page…
VP Biz Dev for Sundance
Public Co-Owner
Becky from Shamokin.
Can’t find much else out.
That’s what google is
for…
Remember her.

11. What Happens When I
Google Becky?

12. 2/15/13 – Sundance Facebook Page
From Shamokin
Becky, Marketing
office manager,
Shamokin Office.
Becky Mentions
“Our.”
Just remember
her for now.

13. 2/15/13 – Sundance Facebook Page
I wonder if she
won back her
$99 processing
fee.
I’m telling you.
Remember her!

14. 1/30/13 – What’s a VPoint
Back on January 30th, Tina, Co-Owner of Sundance had commented about giving
an employee 2,000 Vpoints for their “community involvement.”
That got me thinking, what’s a Vpoint? That got me to googling, and I found…

15. The VPoints Facebook Page http://www.facebook.com/V
Points?
See, I told you to
remember her.
Hey look!
It’s Candy.

16. So What is a VPoint?
VPoints is an employee incentive program where employees are given “vpoints” which
they can redeem for material rewards. How do you get VPoints at Sundance? We don’t
know, but we do know, from Tina’s post on their Facebook page (co-owner), that one way
to get them is online “community involvement.”
The VPoints Facebook page is inundated with Sundance, Tri-State (a Sundance
Company) and Mid-Atlantic Capital (another Sundance company) employees. Many
times, the very same ones posting reviews on the Sundance Facebook page.
Hmmm…
That got me to more googling….

17. VPoint – Slimdog – Sundance.
VPoints
“Chris” Sundance Vacations
Slim-Dog-C LLC
VPoints corporate headquarters are listed as Baltimore. There’s a link at the bottom of
their site saying “copyright slim-dog-c llc.”
So I google “slim-dog-c llc” and it’s located at the same address in Baltimore as VPoints,
and owned by a Chris.
http://companies.findthecompany.com/l/9470713/Slim-Dog-C-Llc-in-Baltimore-MD
The same Chris (at least according to the last name) that was on Sundance Vacations IT
Team as detailed in this 2009 blog post:
http://blog.sundancevacations.com/sundance-vacations-corporate-headquarters/sundance-vacations-experiences-a-may-day/

18. Now It Makes Sense…
That’s why the Vpoints page is inundated by only Sundance affiliated employees.

19. Remember Her?
Here she is giving
another raving
review, but this time
for the rewards she
received from
VPoints, Sundance’s
employee incentive
program.
You have to be an employee to participate in an employee incentive program. There was no
disclosure on any of her positive reviews about Sundance vacations and Sundance
properties on Sundance Vacations’ Facebook page.
In fact, had I not stumbled upon the VPoints page, I would have never known she was in
any way connected to Sundance, the company she was giving positive reviews for.
Psssst….recognize the two names that liked her post? Two Sundance employees.

20. Connect the Dots
From the presented evidence -
1. Sundance does not disclose on their Facebook Page that they award refunded
$99 processing fees for reviews on their Facebook Page
2. Sundance employees routinely comment on their Facebook Page about how
great Sundance is and how great their Sundance Vacations are – sometimes
disclosing they’re an employee, sometimes not.
3. According to Sundance’s own statements, VPoints are rewarded to their
employees for online “community involvement.” A quick comparison of the
Sundance and VPoints pages will clearly show the employees giving positive
reviews on the Sundance Vacations Facebook page, are often the very same
employees commenting about the rewards they received with their VPoints.

21. What Does the FTC Think of Astroturfing?
Copy and Paste from FTC Site:
Suppose you meet someone who tells you about a great new product.
It performs exactly as advertised and offers fantastic new features.
Would that endorsement factor into your decision to buy the product? Probably.
Now suppose you learn that the person works for the company
that sells the product – or has been paid by the company to tout
the product. Would you want to know that when you’re
evaluating the endorser’s glowing recommendation?
You bet. That common-sense premise is at the heart of the
revised Endorsement Guides issued by the Federal
Trade Commission (FTC), the nation’s consumer
protection agency.
http://business.ftc.gov/documents/bus71-ftcs-revised-endorsement-guideswhat-people-are-asking

22. One More Thing to Mention…
I have too much time on my hands, and spent too much
of it connecting these dots.
Your average consumer does not.
In fact, many consumers checking the Sundance
Vacations page are doing so on their mobile device,
while they’re sitting at a table being told by a sales
person how great a $15,000 vacation package is, that
they can ONLY buy that night.
How much time do you think they have to connect the
dots?

23. Thank You for Time
“In a time of universal deceit, telling the truth is a revolutionary act.”