The nonprofit Commercial Alert today (Tuesday) sent a letter (pdf) to the Federal Trade Commission (FTC), requesting that it investigate whether buzz marketers are violating federal law that prohibits deceptive advertising. The letter asks the FTC to review what it terms "evidence" that companies are "perpetrating large-scale deception upon consumers by deploying buzz marketers who fail to disclose that they have been enlisted to promote products. This failure to disclose is fundamentally fraudulent and misleading."

Commercial Alert specifically urges that the FTC investigate Procter & Gamble's Tremor, which has enlisted some 250,000 teenagers in its buzz marketing sales force.

"The Commission should carefully examine the targeting of minors by buzz marketing, because children and teenagers tend to be more impressionable and easy to deceive. The Commission should do this, at a minimum, by issuing subpoenas to executives at Procter & Gamble's Tremor and other buzz marketers that target children and teenagers, to determine whether their endorsers are disclosing that they are paid marketers," the letter states.

In a rebuttal to a recent AdAge story about this topic, Andy Sernovitz, CEO of the Word of Mouth Association, wrote, "Word of mouth is not about paying people to pretend they like something. Has that practice, known in the business as stealth marketing, happened in the past? Yes. Should it be done in the future? WOMMA emphatically says no."