Sitejabber; Analysis of Proposed Consent Order To Aid Public Comment
The consent agreement in this matter settles alleged violations of Federal law prohibiting unfair or deceptive acts or practices. The attached Analysis of Proposed Consent Order to Aid Public Comment describes both the allegations in the complaint and the terms of the consent order--embodied in the consent agreement--that would settle these allegations.
What this rule actually says
The FTC sued Sitejabber (a review platform) for allowing fake reviews and testimonials to stay up while claiming they were verified. The consent order says: if you collect customer reviews, testimonials, or ratings—especially AI-generated ones—you can't mislead people about how authentic or verified they are. Don't claim reviews are real when they're fake, don't hide that AI wrote something, and don't let obviously false claims sit there untouched.
Who it applies to
- If you collect user feedback or testimonials about your AI product (medical scribes, hiring tools, chatbots, etc.) and display them publicly or to prospects—this applies.
- If you use AI to generate, filter, or moderate reviews—this applies. The FTC specifically cares about deception around AI involvement.
- If you operate in the US—this is FTC enforcement, so US jurisdiction. If you're selling to US customers and showing them reviews, you're covered.
- If you claim reviews are "verified," "real," "authentic," or similar—you need to actually verify them. Vague claims count as deceptive.
- Out of scope: Internal feedback, private beta testing data, or one-off customer testimonials you don't publicly display probably don't trigger this. But if you share them on your website, in marketing, or to prospects, they do.
What founders need to do
- Audit your review/testimonial collection (1-2 days): List every place you display customer feedback—website, case studies, marketing materials, social proof widgets. Note if any are AI-generated or unverified.
- Add transparency labels (3-5 days): If a review or testimonial exists, disclose clearly: (a) who wrote it (customer, AI, employee), (b) whether you verified their identity or purchase, (c) any incentives they received. Don't bury this in fine print.
- Set up a moderation process (1 week): Create a simple system to catch obviously fake reviews before posting. Even spot-checking is better than nothing. Document your process.
- Remove misleading claims (1-2 days): Delete any testimonials that are clearly fabricated or any language claiming "verified" if you haven't verified them. Stop using vague authenticity language.
- Monitor ongoing (ongoing, ~2 hours/month): When new reviews come in, apply the same standards. Don't let obviously false claims sit unchallenged.
Bottom line
If you display customer reviews or testimonials anywhere, be honest about whether they're real, who wrote them, and whether you checked—or face FTC enforcement action like Sitejabber did.