Cole Haan's recent Wandering Sole promotional contest with Pinterest got it a slap on the wrist from the Federal Trade Commission.
Though Cole Haan only got a letter and not an enforcement action, the FTC's letter sent a clear message to any advertiser that wishes to ask consumers to post good things about them on social media as part of a contest.
Cole Haan's contest asked consumers to post five pictures of their favorite Cole Haan shoes and their favorite places to wander and tag them with #Wandering Sole. The most creative entrants would be awarded $1,000.
To the average Pinterest viewer, it may not have been clear that the Cole Haan Wandering Sole posts were there only because of a contest. That, in the FTC's eyes, amounted to an endorsement and should have been be properly labeled. Using the contest hashtag #WanderingSole wasn't sufficient, the FTC said in a recent letter to Cole Haan.
"Entry into a contest to receive a significant prize in exchange for endorsing a product through social media constitutes a material connection that would not reasonably be expected by viewers of the endorsement," wrote Mary Engle, the FTC's associate director for advertising practices.
The FTC did not take any enforcement action because it had not previously publicly addressed whether this sort of entry into a contest on social media could be considered a form of material connection.
Since the contest, Cole Haan adopted a social media policy that addressed the FTC's concerns.