Warner Brothers investigated Warner Brothers’s use of online influencers to promote video games and found that the company was violating an FTC Order that barred it from misrepresenting sponsored content as the objective, independent opinions of gamers including, by way of example, a YouTube video promoting Shadow of Mordor created and posted by YouTube’s top influencer “PewDiePie,” which continued to lack a clear and conspicuous disclosure.


October 30 sends complaint letter to FTC alerting it to Warner Bros.’s violation of the 2016 Order, and urging it to reopen its investigation into the company’s use of influencer marketing and take appropriate enforcement action.

November 17

The FTC’s action against Warner Brothers results in an FTC Order that bars Warner Brothers from misrepresenting that sponsored content, including gameplay videos, are the objective, independent opinions of video game enthusiasts or influencers. The Order also requires Warner Brothers to clearly and conspicuously disclose the material connection between the company and the influencers, and to ensure that its influencers do the same.


The FTC files an administrative complaint against Warner Brothers Home Entertainment for its use of online “influencers” to promote the video game Middle Earth: Shadow of Mordor without adequately disclosing that Warner Bros. paid the influencers.


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