Module 2
Claims You Can Prove
If you say it, you must be able to back it up.
Marketing claims are powerful — and dangerous when they are exaggerated or unsupported. The FTC requires advertisers to have competent and reliable evidence before making objective claims about earnings, health, performance, or typical results.
Key rules
- Objective claims need competent and reliable scientific or business evidence before publication.
- Earnings claims must show what the typical participant or customer actually earns.
- Health and weight-loss claims usually need human clinical evidence.
- Testimonials and before/after photos must reflect typical results, or the typical result must be disclosed.
- Urgency and pricing claims must be real; fake scarcity is deceptive.
Do this, not that
Earnings claims
Say 'Typical earnings are $X per month; some earn nothing' and keep records.
Show only the top earner's results with 'You can make $10K/week.'
Why: Exceptional results are misleading unless typical results are clearly disclosed.
Health claims
Limit claims to what the science supports and include required disclaimers.
Say a supplement cures, treats, or prevents a disease without FDA approval.
Why: Disease claims for supplements are illegal without proper drug approval and evidence.
Testimonials
Use genuine reviews and disclose if results are not typical.
Use a testimonial that promises a specific result most users do not get.
Why: A glowing review can mislead if buyers expect the same outcome by default.
Before/after photos
Label them clearly, disclose timing, and note results are not typical if that is true.
Use photoshopped, borrowed, or unrepresentative images without context.
Why: Visual proof is persuasive; faked or atypical images deceive consumers.
Urgency
Only run real, time-limited offers with a genuine end date.
Fake countdowns that reset, 'only 2 left' when stock is plentiful, or perpetual flash sales.
Why: False scarcity pressures consumers into decisions based on lies.
Pricing
Show the full price a buyer will pay, including mandatory fees, before checkout.
Advertise '$0' or '$1' when the buyer must buy a subscription or pay hidden fees.
Why: Consumers must know the real cost before committing.
Fix it: before and after
Risky
Join my course — I made $50K in my first month!
Fixed
I made $50K in my first month. Typical student earnings in the first year are $2,000–$5,000. Some earn nothing. Past performance does not guarantee future results.
Why it works: Adds typical results and a clear disclaimer so the outlier is not mistaken for the norm.
Risky
This tea melts belly fat in 7 days!
Fixed
This tea is part of a balanced diet and exercise plan. Weight loss results vary and are not guaranteed.
Why it works: Removes the unsupported disease/weight-loss claim and adds a realistic qualifier.
Risky
Only 2 spots left at 90% off! (The timer resets every day.)
Fixed
Sale ends Friday at 11:59 p.m. ET. Prices return to regular rates after that.
Why it works: Replaces fake scarcity with a real deadline and avoids misleading stock claims.
What it costs to get wrong
The FTC has obtained orders and civil penalties in the hundreds of millions of dollars for deceptive earnings and health claims. Individual influencers have also been fined tens of thousands of dollars per violation.
Module quiz
Pass with 80% or higher. You can retake as many times as you need.
Question 0 of 8
1. Before making an objective marketing claim, you must have:
2. If you show a testimonial with an exceptional result, you must:
3. A supplement can legally claim it cures a disease if the testimonials are positive.
4. Which earnings claim is most compliant?
5. A 'only 3 left' badge is okay when:
6. Before/after photos must:
7. Which pricing practice is deceptive?
8. A 'results not typical' disclaimer can fix any testimonial.