Marketing Roadmaps

Ethics

More on FTC guidelines and impact on bloggers

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Recently Word of Mouth on NH public radio interviewed Rich Cleland, Assistant Director of the FTC’s Advertising Practices bureau about the revised guidelines on endorsements and testimonials that are expected to be approved this summer. Liz Gumbinner from Cool Mom Picks and Mom-101 provided the blogger’s perspective.

There really wasn’t anything new or unexpected. I’ve written about this topic as has Liz. What was nice was to actually hear it directly from the FTC rather than filtered through another source like AP or BusinessWeek.

Here’s my takeway from the interview:

  • The key issues are disclosure of relationships and truthful opinion. FTC believes truth in advertising/transparency should apply regardless of the media.
  • FTC isn’t regulating whether bloggers take compensation or not. The occasional review or free product is not the issue. FTC is concerned about blog networks, bloggers that consistently receive products/compensation, and disclosure of relationships.
  • FTC believes compliance will be high.
  • Enforcement will be subject to the same criteria as it is now — the extent of the injury will determine whether it justifies the expense of enforcement. I have long believed this would be the case. Nice to hear it from the source.
  • While bloggers would like the FTC to distinguish between free product and cash compensation, it does not seem inclined to do so. However, as noted above, the occasional free product or review isn’t the issue. The FTC is interested in consistent patterns of behavior, and in blog networks, not in whether an individual blogger got a free mascara or a bag of chips.

What they did NOT discuss on Word of Mouth was affiliate marketing, which the AP story said would be included:

“… the guidelines also would cover the broader and common practice of affiliate marketing, in which bloggers and other sites get a commission when someone clicks on a link that leads to a purchase at a retailer. In such cases, merchants also would be responsible for actions by their sales agents – including a network of bloggers.”

I’ve read the initial draft of the changes to the guidelines, and it does not include an example specific to online affiliate marketing such as Amazon. While I expect changes to draft in the final guidelines, I never made the connection between endorsements & testimonials, and affiliate ads like Amazon. Blog networks that offer free products or compensation to bloggers, absolutely. Campaigns that offer compensation to users for reviews on Amazon or iTunes. Again, clearly subject to the guidelines.

But simple affiliate marketing programs?

After much thought and conversation, I don’t think affiliate marketing should be lumped together with the guidelines on endorsements and testimonials. If the FTC wants to review online affiliate marketing practice, it should do so in a separate effort and allow sufficient time for public comment.

Affiliate marketing is a different type of advertising

A review of a product that is compensated in advance by either cash or free product should be considered a form of advertising. The FTC guidelines should apply.

The affiliate marketing relationship is different.

The blogger reviews or mentions a product on her blog and provides a link to a store that carries the item. For example, Amazon. It’s a referral. The blogger is only compensated if the buyer purchases the product from that link.

The explicit endorsement is of the product, although no one would deny that there is also an implicit endorsement of the store, especially if the blog also shows a search widget for the store in its sidebar.

However, once the buyer is at the store, the influence of the initial mention or review is diluted — by the advertising material on the store, by reviews from other consumers, by alternate product suggestions from the store. The blogger’s original opinion becomes one of many sources of information. If the buyer goes ahead and purchases something from the visit created by the affiliate link, the compensation is really nothing more than a “thank you for telling your friends about us.”

Now,  if the blogger received the product for free,  it should be disclosed under the guidelines. But it should be the free product that trips the endorsement guidelines, not the affiliate referral.

Affiliate marketing is understood by Internet users

Whether you see an ad like this:



or embedded links within a post like these Sleep Is for the Weak, The White Trash Mom Handbook, most Internet users  understand these to be affiliate marketing/advertising  links, with a compensation component. Many are probably Amazon affiliates themselves.

In the very long FTC guidelines document, a key condition of the additional disclosure requirement is if the consumer would not otherwise understand that an endorsement was compensated or that the speaker had a material interest. If the consumer would understand that the speech or action was compensated, the public interest does not require additional disclosure.

Examples — An athlete wearing name brand sports apparel is assumed to have a contract with the manufacturer. A celebrity on the red carpet is assumed to have borrowed her gown from a designer. A public figure endorsing a product in a TV commercial didn’t do it for free.

Affiliate advertising on blogs is similar. We don’t need additional information to know there’s compensation. It looks far too much like straightforward online advertising for there to be any real confusion.

What should bloggers do if they have affiliate marketing relationships?

The new FTC  guidelines are due later this summer. We’ll see then how affiliate marketing is covered (or not) in the document. It wasn’t in the initial draft, so we don’t have an example yet.

In the meantime, if you have affiliate marketing relationships, I suggest disclosing them clearly in your blog policy.

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The Amazon affiliate links used above for illustrative purposes are for books written by friends and use the Amazon affiliate account from my personal blog Snapshot Chronicles. So yes, if you buy a book, a friend gets a sale and I get a teeny weeny commission.

Impact of potential new FTC endorsement guidelines on companies

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Yesterday, I gave you my take on how the potential new FTC guidelines for endorsements and testimonials might impact bloggers. Today we are going to look at the potential impact on companies.

A couple of things to keep in mind:

  • The guidelines outline how the FTC intends to enforce the laws governing endorsements and testimonials in commercial speech. They are meant to be used as an aid to compliance. The new bit is that they are clearly extending the definition of commercial speech into certain social media activities.
  • The FTC is still working on these new guidelines, but has said they’ll be out this summer. The new guidelines  could change a little or a lot from what it outlined in the call for comments I reviewed, based on the comments received, lobbying and so on. I’m betting a little, but I could be wrong. Been known to happen.

How might companies change/have to change their blogger relations programs and practices to comply with the guidelines?

First, let’s review the three examples related to blogs. The citations are the direct quotes from the document; headlines and emphasis mine. Please note,  I’ve changed the emphasis from yesterday’s post. It now reflects the impact on the company. Also, be aware that there is a fourth example specifically related to in-person word-of-mouth marketing, “street teams,” such as the work done by firms like BzzAgent. That’s not my area of expertise, so I’ll leave that one to WOMMA.

Number one: Liability for false statements in a sponsored post.

“Example 5: A skin care products advertiser participates in a blog advertising service. The service matches up advertisers with bloggers who will promote the advertiser’s products on their personal blogs. The advertiser requests that a blogger try a new body lotion and write a review of the product on her blog. Although the advertiser does not make any specific claims about the lotion’s ability to cure skin conditions and the blogger does not ask the advertiser whether there is substantiation for the claim, in her review the blogger writes that the lotion cures eczema and recommends the product to her blog readers who suffer from this condition. The advertiser is subject to liability for false or unsubstantiated statements made through the blogger’s endorsement. The blogger also is subject to liability for representations made in the course of her endorsement. The blogger is also liable if she fails to disclose clearly and conspicuously that she is being paid for her services. [See § 255.5.]

In order to limit its potential liability, the advertiser should ensure that the advertising service provides guidance and training to its bloggers concerning the need to ensure that statements they make are truthful and substantiated. The advertiser should also monitor bloggers who are being paid to promote its products and take steps necessary to halt the continued publication of deceptive representations when they are discovered.”

Number two: Disclosure of receipt of free product

“Example 7: A college student who has earned a reputation as a video game expert maintains a personal weblog or “blog” where he posts entries about his gaming experiences. Readers of his blog frequently seek his opinions about video game hardware and software. As it has done in the past, the manufacturer of a newly released video game system sends the student a free copy of the system and asks him to write about it on his blog. He tests the new gaming system and writes a favorable review. The readers of his blog are unlikely to expect that he has received the video game system free of charge in exchange for his review of the product, and given the value of the video game system, this fact would likely materially affect the credibility they attach to his endorsement. Accordingly, the blogger should clearly and  conspicuously disclose that he received the gaming system free of charge.”

Number three: Anti-astroturfing. Requires disclosure of material interest when making an endorsement.

“Example 8: An online message board designated for discussions of new music download technology is frequented by MP3 player enthusiasts. They exchange information about new products, utilities, and the functionality of numerous playback devices. Unbeknownst to the message board community, an employee of a leading playback device manufacturer has been posting messages on the discussion board promoting the manufacturer’s product. Knowledge of this poster’s employment likely would affect the weight or credibility of her endorsement. Therefore, the poster should clearly and conspicuously disclose her relationship to the manufacturer to  members and readers of the message board.”

Sponsored Posts/Blogs

There are a few flavors of sponsorship. The company might pay the the blogger directly for a post or as an advertising sponsor of the blog, it might pay a blog network like BlogHer for access to its members or it might work with a sponsored post company like Izea.

In the first case, when the company works directly with a blogger, for example by sponsoring a specific post or even the blog as an advertising sponsor, the relationship should be governed by an advertising contract that outlines the responsibilities of the parties, and the nature of the relationship clearly disclosed on the blog. This is just smart business for both sides.

If, however, the company is not working directly with the blogger and instead is working through an intermediary, described in the FTC doc as a blog advertising service, the company needs to perform an additional level of due diligence. It needs to be sure that the advertising service is providing guidance and training to its bloggers, and if free product or services are provided, requiring disclosure of the commercial relationship.

Note that there is no requirement that the blogger be receiving a payment. Or even free product. If a company uses a blog network to reach out, is paying the blog network for the access to its members, that seems to be sufficient for liability for false statements.

What kind of policy should you look for in a blog advertising network or sponsored post firm? A good example is BlogHer. It  has done a nice job navigating this minefield. The blog network you use may not have exactly the same policies, which is fine, but you want it to have at least paid as much attention to its own policy. To understand and be sensitive to the impact on both the blogging community and the advertiser.

Is there an issue if you are working with a consultant or agency to reach out to bloggers on your behalf, but who has not promoted a blog network as a product? In this case, the vendor would be building an outreach list based on your criteria and probably its relationships, but it isn’t advertising a blog network service.  I do not think the same liability exists, but usual disclaimer. Not a lawyer, don’t play one on the WWW.

{added 5/21 7:50 am}

After sleeping on it, I realized the above paragraph wasn’t clear. I don’t want to read too much into the examples, so be aware that this next thought is my interpretation, not a direct example from the FTC document.

It is the payment to the blog network combined with the explicit agreement that the bloggers will write that creates commercial speech, ie advertising. When blogger outreach is handled more like public relations, as it would be by a PR agency or an independent consultant like me, there is no agreement that the bloggers will write. Our job is to present a relevant story to a group of bloggers that we expect will be interested. If they write, it is editorial.

If free product is provided to them, the same disclosure provisions would apply. In both cases, whether there is agreement to write or not, best practice is to provide as much information as the blogger needs/requests, but no direction as to post tone, content or timing.

{end insertion}

Free product considerations

Many blogger relations programs include something for free. A product. A trip. Products to giveaway on the blog. While the FTC example doesn’t require you, the company, to do anything, I recommend that you act as though it does, and advise bloggers of the need to disclose.

Should you stop offering review product or developing blogger events? Absolutely not. Even with these new guidelines, honest customer experiences of your products and services are a great way to reach other customers. We all just need to understand that it is a new form of advertising and act accordingly.

A word about contracts. The temptation will be strong, particularly in your legal department, to pass as much liability onto the blogger as you can. My advice is to be reasonable. If the value of the goods received, either for loan or free, is high, you probably need a contract that spells out the responsibilities of the parties. But, if you try to pass on all the responsibility to the bloggers, be prepared for them to walk away. And if you’re just sending the blogger a few DVDs or product samples to try and perhaps give away on her blog, be realistic. A contract?

A form of astroturfing specifically prohibited

The astroturfing example warmed  my cold cynical heart. Far too many companies and agencies have engaged in the  practice of leaving positive comments on blog posts and forums without disclosing their interest in the product or service being discussed. This is an abhorrent, unethical practice. If the example above makes it into the final guidelines, this will be considered deceptive advertising subject to FTC enforcement. AMEN.

Better practice by far is to participate but disclose your interest. In most cases, you’ll be better off communicating with the site or forum owner first, privately, before jumping into a forum, community or ongoing blog discussion, but some will already have threads for vendor discussion. Once you’ve established a relationship with the community, you may even become a resource for it. Isn’t that what we really want? Robust relationships with our customers and influencers.

What’s the bottom line?

The potential new FTC guidelines change the playing field for social media outreach, but only slightly, and really, well within what we should be doing as  ethical practice anyway.

The FTC’s job is to protect consumers from deceptive advertising. One of the ways it does this is to make sure that commercial speech — paid advertising in all its forms — is clearly marked as such. While it may make our jobs as marketers and bloggers a bit more complex, as consumers, we should be glad that we have this watchdog on our side.

The FTC is NOT gunning for mom bloggers

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Articles in the mainstream press, like this one today in BusinessWeek, give the impression that somehow the Federal Trade Commission is targeting mom bloggers for “enforcement.” Poppycock.

The FTC is doing a review of its guidelines on endorsements and testimonials. That’s part of its job — to protect the consumer from deceptive advertising practices. In 2007, it published notice of its intent to review these guidelines and solicited comments. Last year, it published this document, soliciting additional comments, which were accepted until earlier this year.

In the process, new media got added to the mix because word of mouth marketing, whether done by guerrilla marketing agencies or bloggers, is a new form of endorsement.

The question then becomes is it a commercial endorsement or not. If commercial — if it qualifies as advertising — then the guidelines may apply.

Why is this an issue for mom bloggers?

Not because the FTC is targeting them. It is not. However, consumer products companies are, big time. Bloggers are being asked to endorse products in a variety of ways, from sponsored posts to free product to big events and trips. So, what is the real impact of the possible changes to the guidelines?

A long time ago, when I wasn’t much older than my son is now, I thought I wanted to be a lawyer. Which may explain why I still get off on reading 86 page policy documents from the FTC. The good news is, I do, so you don’t have to. Today, I reviewed the FTC call for comments on the guidelines, the most recent public document we have.  Here’s the scoop.

The bulk of the 86 page document focuses on deceptive use of testimonials in advertising, largely for weight loss, baldness and other pharmaceutical (and quasi pharmaceutical) products.  Disclosure of the relationship among the parties and substantiation of claims are the main themes.

There are only three examples related to blogs. The citations are the direct quotes from the document; headlines and emphasis mine.

Number one: Liability for false statements in a sponsored post.

“Example 5: A skin care products advertiser participates in a blog advertising service. The service matches up advertisers with bloggers who will promote the advertiser’s products on their personal blogs. The advertiser requests that a blogger try a new body lotion and write a review of the product on her blog. Although the advertiser does not make any specific claims about the lotion’s ability to cure skin conditions and the blogger does not ask the advertiser whether there is substantiation for the claim, in her review the blogger writes that the lotion cures eczema and recommends the product to her blog readers who suffer from this condition. The advertiser is subject to liability for false or unsubstantiated statements made through the blogger’s endorsement. The blogger also is subject to liability for representations made in the course of her endorsement. The blogger is also liable if she fails to disclose clearly and conspicuously that she is being paid for her services. [See § 255.5.]

In order to limit its potential liability, the advertiser should ensure that the advertising service provides guidance and training to its bloggers concerning the need to ensure that statements they make are truthful and substantiated. The advertiser should also monitor bloggers who are being paid to promote its products and take steps necessary to halt the continued publication of deceptive representations when they are discovered.”

Number two: Disclosure of receipt of free product

“Example 7: A college student who has earned a reputation as a video game expert maintains a personal weblog or “blog” where he posts entries about his gaming experiences. Readers of his blog frequently seek his opinions about video game hardware and software. As it has done in the past, the manufacturer of a newly released video game system sends the student a free copy of the system and asks him to write about it on his blog. He tests the new gaming system and writes a favorable review. The readers of his blog are unlikely to expect that he has received the video game system free of charge in exchange for his review of the product, and given the value of the video game system, this fact would likely materially affect the credibility they attach to his endorsement. Accordingly, the blogger should clearly and  conspicuously disclose that he received the gaming system free of charge.”

Number three: Anti-astroturfing. Requires disclosure of material interest when making an endorsement.

“Example 8: An online message board designated for discussions of new music download technology is frequented by MP3 player enthusiasts. They exchange information about new products, utilities, and the functionality of numerous playback devices. Unbeknownst to the message board community, an employee of a leading playback device manufacturer has been posting messages on the discussion board promoting the manufacturer’s product. Knowledge of this poster’s employment likely would affect the weight or credibility of her endorsement. Therefore, the poster should clearly and conspicuously disclose her relationship to the manufacturer to  members and readers of the message board.”

So what’s the big deal? Doesn’t this all make sense?

It will come as no surprise to readers of this blog, but apparently to some: businesses do not always act in the best interests of consumers. Sometimes they even lie. That’s why we’re in a recession.

The FTC protects us from deceptive practices in advertising, and extending the policies to social media that qualifies as commercial speech makes sense. If you are a blogger, that may include some of your writing. But please don’t over-react. The FTC is not interested in honest reviews of products by bloggers.

It is interested in protecting the consumer. Us.

What should bloggers do?

Well the document I read today merely outlines the direction the FTC was taking. The final guidelines could be slightly or even very different. Nevertheless, I’ll stand by my original post on this topic (Bloggers liable for statements about products? Maybe says FTC ) and say that the key issues will be compensation and disclosure. To what extent is the blogger a proxy for the advertiser?

In that context, here’s my advice. Keep in mind:  I am not a lawyer and I do not play one on the Internet.

1. Whether you write paid posts, go on paid trips or take free products for review, or not, review your blog disclosure policies. Are you clear about your interests and affiliations?

I have three blogs, and each has a slightly different policy. Marketing Roadmaps accepts no advertising whatsoever. Snapshot Chronicles, my personal blog, runs BlogHer ads and is an Amazon affiliate. Snapshot Chronicles Roadtrip, my new family travel blog, accepts review product and advertising with the policies clearly spelled out.

For reference, here’s the general policy for the Snapshot Chronicles.com domain and for the Getgood.com domain that hosts the Marketing Roadmaps blog. Every blog I build for a client has a similar policy. Every one.

If you feel better having a lawyer review your policy, go for it. Especially if you are making money from your blogging or you are in partnership with other bloggers. It’s your business. Protect it.

2. If you accept compensation for a blog post, disclose the payment. If the post was written as part of a blog network, even if you are not compensated directly but the network is, disclose. When in doubt, disclose.

3. If you accept free product, whether or not there is an explicit agreement for a review, if you do the review, disclose. Also, as Erin Queen of Spain pointed out on Twitter today, don’t forget your tax liability for free products. Personally I think it far more likely that the IRS will come knocking than the FTC. Cover yourself.

4. Be careful about claims you make about the products. In the skincare lotion example, there’s a big difference between saying “This cream cures eczema” (Wrong) and “This cream really helped my eczema.” (Specific, probably acceptable). In advertising, commercial speech, general claims must be substantiated.

5. It would be nice, wouldn’t it, if the FTC would say something like free product over $x dollars is subject to the guidelines, but under, it is not. Abandon that hope. It won’t happen. Absolute numbers are a policy mistake, and one that I do not see the FTC making in this case.

Use your common sense. If you take a book or DVD or baby sling to review, something you might purchase anyway, the FTC probably isn’t going to spend any time worrying about deception in your review. Sorry.

A new car? A free trip? A suite of brand-new appliances? Uh. Yes. These are levels of compensation that may get some scrutiny. Should that prevent you from participating in a blogger program? Absolutely not. Assuming everything about the program is kosher, that would be stupid. The FTC is focused on deceptive practices, not honest reviews.

Stay on the side of the angels. You’ll be fine.

This post has focused on the blogger side of the blogger relations equation. In the next few days, I’ll share some thoughts on how the proposed changes might impact what companies and agencies do.

In the doghouse?

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In December, a video began making the rounds on YouTube. Called The Doghouse, it was sponsored by JC Penney’s jewelry department and humorously described what happens to men who give inappropriate gifts to their female partners on significant holidays.

Not to belabor the point, but unless she explicitly asked for a vacuum cleaner, not such a good idea.

The JC Penney branding was subtle. Almost too subtle, said my friend Julia Tanen.

That didn’t worry me so much, as I suspected JCP would use a multi-prong approach to promote the campaign. The day I first learned of the campaign in December in fact, JCP started following me on Twitter, and just before the holidays, one of their PR firms reached out to me about participating in a contest promotion for the Doghouse campaign and site. More about that in a minute.

Women will identify with this promotion. We are always getting gifts from our spouses that aren’t “quite right.” Perhaps not as bad as an appliance, but there’s a reason why women like to get jewelry. In my personal experience, it has relatively little to do with avarice and quite a lot to do with not having to stand in line to return stuff that is the wrong size or style.

However, I’m not crazy about the website.  It seems a bit confused and not up to the standard set by the video.  It’s pretty clear how people get into the doghouse, and the message about how to get out is clear – buy diamonds.  But how do people who are submitted by their friends get released?  Is it real, or just some sort of random thing? I’d like a bit more explanation.

That said, I applaud the company for trying something different and creating a funny video that speaks to the real problem — the difficulty men often have in buying gifts for their partners — and not just to their product. This is thinking at the intersection of mutual interest, not simply product promotion.

Now, back to the outreach from one of Penney’s agencies. They reached out to me with an offer for a gift card that I could award in a reader contest. Now, I don’t do contests here on Marketing Roadmaps. In fact, there is no advertising here and I rarely review products. However, I do have a personal blog where  I do both, and the PR rep was fine if I ran the contest over at Snapshot Chronicles. I also told her I intended to do a brief analysis on the campaign here.

Which brings me back to one of the themes I raised in my New Year’s post – credibility and ethics. I have a clear policy for both my blogs. Marketing Roadmaps is about marketing and critical analysis and accepts no advertising. Snapshot Chronicles is a personal blog and runs ads from BlogHer, Google and Amazon.

What I’ve said here on Marketing Roadmaps about this campaign was not influenced by the blogger outreach. I formed an opinion about the Doghouse campaign when I first saw it and my opinion hasn’t changed. It was a good effort, a funny video and a so-so website. So, I couldn’t see any reason to not accept the offer of the gift card for a contest for my Snapshot Chronicles readers. Times are tough and every little bit helps.

But I wonder — would the critics who lambasted Chris Brogan about the Kmart campaign criticize me in the same way? Granted, I get no personal benefit, other than the continued relationship with the PR rep who reached out to me, but still, I will be writing a post over at Snapshot Chronicles that encourages people to promote the JCP campaign. Even though I was critical of it here.

I think it’s fine. Or I wouldn’t do it.

What do you think?

PS – Go to Snapshot Chronicles for info on how to enter the contest for the $100 JC Penney gift card.

Revisiting the 3Rs of Blogger Relations, Part 1: Respect

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Quite some time ago, my friend David Wescott wrote a post outlining the 3R’s of blogger relations: Respect, Relationship and Relevance, a framework quite similar to my own approach both at the time and still.

Not at all surprising, since a shared conviction about how to engage with bloggers was how we met in the first place.

Since I am more or less relaunching Marketing Roadmaps at this new URL, I thought it would be a good time to revisit these core concepts.

Let’s start with Respect.

What made David’s post so good was the introduction of the word Respect. Most of the thinkers in the space (myself included) had been talking about Relationship and Relevance as well as the ideas he categorized as Respect. But his post was the first time, to my knowledge, that anyone applied the actual word.

And it is such a perfect word to describe the attitude with which you,  the pitcher, should approach the blogger, the pitchee. Yes I know that is not a word. Sue me.

With respect. For his time. For the passions that fuel her blog. For the person. For the blog.

Here are some of the things that demonstrate lack of respect for the blogger that have crossed my desk in the last few months, either directly or forwarded from friends.

  • Messy emails, with multiple fonts, addressed to Dear Blogger, Name not available or some such. Probably forwarded more than once,
  • No actual signature, just a boiler plate email signature. Even worse  –  an email sent from one account but signed by another person. Really has that personal touch, you know.
  • Pitches to review books that want the blogger to flog the book or interview the author but don’t offer a review copy. Why on earth would anyone do that?
  • Repeated follow-ups, often through multiple channels. One is acceptable. After that you are stalking. Back off.
  • Refusing to provide review product after sending a pitch. Hullo — you got a hit. Assuming you targeted properly (yeah I know, big assumption), you should PLAN on sending review product. Offering a jpeg? Not good enough.
  • Pretense. Here’s a recent example. Sara from Suburban Oblivion relates a pitch she received from a product geared to preteen girls. She was somewhat interested and requested review product. The company refused, and not in the most elegant fashion. Bad enough, really, but when Sara blogged the story, someone related to the company left an unattributed positive comment on the blog. Read the denoument on Suburban Oblivion. Remember — pretend is a great game for children, and even has its place in our adult lives, but it is not an appropriate blogger relations tactic.
  • Invitations to events the blogger couldn’t possible attend.  Even worse, press releases about PAST events to which you did not invite the blogger at all.

If you are going to reach out to bloggers, you must develop a very healthy respect for the the fact that most bloggers have no intrinsic reason to be interested in what you have to say. They may indeed be your customers and interested in your product, but it is not their job to promote your product. That’s your job. If you want their help, you have got to put it in a context that is important to them. That’s the concept of Relevance, which we’ll review later this week

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In a special hell all its own is the absolutely awful pitch that made the rounds last week following the family tragedy of actress Jennifer Hudson. I won’t link to it here, but here are some commentaries from Twitter pals Katja Presnal, David Parmet and Kevin Dugan.

I wish this was the first time in my life I had seen such a piss poor PR reaction to a tragedy, but it isn’t. People are blinded by the perceived relevance of their product and lose all perspective about the personal nature of tragedies. It’s stupid, tasteless, disrespectful and shows a total lack of common sense. And happens all the time.  It’s also easy to avoid. When the temptation strikes to capitalize on tragedy, and it well may, just say no. There is absolutely no way your product is SO RELEVANT that it merits the disgraceful behavior of capitalizing on another person’s tragedy. Full stop.

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Finally, all practicing PR people should read BL Ochman’s post PR Industry Leaders Put Their Feet in Their Mouths at Critical Issues Forum and ask themselves, is this me? Am I doing better or perpetuating the problem? What can I do better?

One of the things we can most definitely do better is to improve the relevancy of our pitches, and not just to bloggers. To journalists too. More on that later this week.

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UPDATE, 11/3: This post hadn’t been up a day before a friend, a Massachusetts mom blogger whose home page clearly states her name and state, tweeted about the pitch below. Unfortunately, I couldn’t ask for a better example of the importance of respect for the blogger, especially since the event is for a good cause which is also tarnished by the bad pitch.