Business Innovators Radio - Chuck Cooper – eCommerece Attorney – On The Three Triggers Escalating Digital Marketing Risk

Episode Date: July 19, 2023

In this episode, Nina Hershberger talks with eCommerce attorney, Chuck Cooper, about the three triggers that are escalating digital marketing risk. Chuck is the CEO and marketing compliance coach of FTC Guardian, a company that helps marketers navigate the complex world of legal compliance in the online world.Chuck has years of experience in e-commerce and digital marketing, as well as mergers and acquisitions. He is also an adjunct professor of law at Wake Forest University. In this episode, Chuck breaks down the three triggers that are causing digital marketing risk to skyrocket.The first trigger is the escalation of ad claims or advertising claims, which has been happening since 2009 but has recently accelerated.The second trigger is a recent Supreme Court ruling that limits the Federal Trade Commission’s jurisdiction and authority to impose fines. This ruling has led to a rush by the FTC to pass new rules that allow them to impose fines on digital marketers.The third trigger is the introduction of artificial intelligence, specifically Chat GPT, which has raised concerns about how marketers might use AI to manipulate consumer beliefs and behavior.This episode is especially important for anyone involved in online marketing, as the risks associated with digital marketing are increasing. Chuck provides valuable insights and advice on how to navigate these risks and stay in compliance with FTC regulations. Whether you’re a business owner, marketer, or copywriter, you’ll gain valuable knowledge from this episode.If you’re interested in learning more about Chuck Cooper and FTC Guardian,1. You can visit www.ecommerceattorney.io.. There you can sign up for a free two-minute email newsletter that provides quick updates on the latest developments in digital marketing compliance.2. You can also schedule a complimentary 30-minute consultation call with Chuck here to discuss your specific needs and explore the possibility of a future attorney-client relationship.3. Finally, Chip has an upcoming webinar going into more detail about these 3 triggers. To be invited to the webinar, send him an email at [e-mail]’t miss this opportunity to learn from a leading expert in digital marketing compliance. Tune in to this episode and stay informed about the latest trends and regulations in the industry.MegaBucks Radio with Nina Hershbergerhttps://businessinnovatorsradio.com/megabucks-radio-with-nina-hershbergerSource: https://businessinnovatorsradio.com/chuck-cooper-ecommerece-attorney-on-the-three-triggers-escalating-digital-marketing-risk

Welcome to Megabox Radio. Conversations with successful entrepreneurs, sharing their tips and strategies for success, real-world ideas that can put Megabox in your bank account. Here's your host, Nina Hirshberger. Well, welcome to today's show. It's been a while since I've had an attorney on the show, actually, only probably about three weeks. So, you know, I love attorneys that love marketing and understanding. understand the world that we work in.

And so today is no different. I get the privilege of welcoming to the show Chip Cooper. Chip is an attorney, he's an accomplished attorney and has years of experience. And he specializes in e-commerce and digital marketing. He's done some mergers and actualizations as well. And he also is an adjunct professor of law at Wake Forest University. But today we're going to talk about things that we as marketers need to be aware of. We're calling this the three triggers that are escalating our digital marketing risk and they're sending it through the roof.

So Chip is a CEO and marketing compliance coach of FTC Guardian. And we'll talk about that again in a few minutes. Anyway, welcome to today's show, Chip. well thank you nina and just prior to going live you remember we sort of reacquainted ourselves from a meeting years ago on a marketer's cruise and time really flies when you're having fun though isn't it it does if i recall we were sitting on one of the decks and you know i mean i knew you were part of a marketing group we were all there about 400 of us and we got to chatting and boy was i impressed You know all of those things that I don't know, and so it's exciting to have you on the show.

Well, thank you. So I'm looking at some questions that I've got, and I want to start out. So let's talk about those three triggers. Explain the three triggers and why our risk is really exponentially going through the rough. Well, the result of the three triggers, of course, is a very, sharply escalating marketing risk for digital marketers, anybody in that space, and they all sort of happening are all sort of happening at the same time.

One of them has really been going on primarily since about 2009, and it deals with, generally speaking, ad claims or advertising claims, and it's been escalating essentially very slowly from 2009, but beginning around 2020 or 21, it started escalating. So that would be trigger number one, and we can go into a little bit of detail about that if you like. And then trigger number two really happened really all of a sudden in 2021, where the FTC was sued and the case went to the U.S. Supreme Court,

and the result was that the U.S. Supreme Court said that the FTC did not have the jurisdiction or legislative authority to impose fines under a very specific section of the FTC Act, which, by the way, they had been imposing serious fines for over 30 years. So the U.S. Supreme Court overrules or basically disqualifies the Federal Trade Commission from using a specific section which they had sort of stretched the interpretation of, and it used it for over 30 years to levy fines with the result that they couldn't levy fines. And then that triggered an incredible rush by the Federal Trade Commission to pass a lot of rules, which, which basically allows them to impose fines on digital marketers. A little bit more about that in a minute if you have questions.

And then the last one was the very recent introduction publicly of artificial intelligence, specifically, chat GPT. And the FTC has a lot of questions and concerns about marketers using chat GPT or other generative AI. So all of these things are sort of converging at one time, and the sum total of them, these three triggers that you referred to, and of course I referred to as well, increase very substantially digital marketing risk. So that's the quick summary of what we're looking at.

Let's give a definition of digital marketers. So tell me who needs to be concerned about what we're going to talk about today. It's really an extremely broad, definition, Nina. I mean, it's essentially anyone marketing online in the digital environment for promotion, advertising, marketing, you know, a very broad term that includes anybody, online marketing, marketing with through their websites, marketing and social media, that sort of thing, very broad. So that's pretty much everybody who has a business is marketing. That's right. It'd probably be everybody that,

It is a listener to your podcast, I would imagine. So trigger number two, the Supreme Court said, no, no, no, no, no, you can't be doing what you did for the last 30 years and finding these people. So then they had to scramble because they got to get more money in. So that's when they made up all of those rules. Did I understand what you said correctly? Yes, and it's very interesting, this so-called rulemaking authority. Because, you know, when you get right down to it, the U.S. Congress is the only branch of government that is authorized and directed to make laws, right?

But the FTC Act granted to the Federal Trade Commission a limited authority to make rules, which do have the effect of law. But the rules have to go through a really, a special, very, very time-consuming process so that the FTC actually provides typically something known as an advantage. notice of proposed rulemaking with, you know, what the rule is all about or proposed rule is all about, and the practice that is the target for the proposed rule, which the FTC has determined to be deceptive in terms of marketing, the FTC has to establish that that so-called deceptive act or practice is prevalent, meaning it's fairly widespread in the industry. So,

So step one is the FTC actually makes this advance notice of a proposed rule and then alerts the public to make comment, solicits input from the public and industry groups. And then second, after reviewing all of that, and it takes a few months, the first of these rules went into effect, well, the process went into effect a couple of years ago. And so then the FTC issues a notice of proposed rulemaking with very specific rules. And then finally, if there is a final rule, it's announced later and it's published in the Federal Register. And of course, the public now has rights to participate in the process by making rebuttal comments, and they can also cross-exam FTC witnesses.

informal hearing. So it's sort of a many, many way to, many legislative way to create a rule that has the effect of law. And the interesting thing here is that the rules now are very specific. And they are to be contrasted with what we're probably much more familiar with, which are guidelines or guides, which are general views of the Federal Trade Commission that might, be under certain circumstances deceptive, right? And then, of course, the FTC looks to see acts or practices that fall within that general guideline. And if the FTC wants to bring an enforcement action, the FTC has to prove.

The FTC has the burden of proof, we say, to prove deception. And that's quite different from rules because rules are not general. They're very specific. They're inflexible. Deception is presumed, meaning that the FTC has no burden of proof. All they have to do is prove that you violated the rule, and deception is presumed. So it's essentially strict liability. And one clear example would be if we're talking about subscriptions,

which is the subject matter under review right now for a rule update, the guideline might say you need to make it relatively. easy for a consumer to cancel the subscription, relatively easy to cancel. On the other hand, the rule will go much more specific and say something like, not only do you need to make it relatively easy to cancel, you have to provide a button that with one click will allow the subscription to be canceled. So that's the difference, and we're right in the middle of a lot of rulemaking right now, involving earnings claims, for example, if you're selling any kind of money-making opportunity.

There's one involving junk fees, which are sort of add-on fees that are unexpected, a whole category of those. The biz-op rule, which really is a rule that's been around for a long time, is now proposed to be expanded to include almost any kind of money-making opportunity, which would radically impact anyone selling any money-making opportunity online. The negative option rule, again, just mentioned that, fake review, and there are others that are in process right now. So that's a quick summary of what FTC rules are all about, how they differ from guidelines,

and the big takeaway for marketers here is they're much more specific. There's no wiggle room whatsoever. if you violate the specific rule, you're liable for fines in the amount of $50,000 per violation. So the fines can really add up. So it's something that's really never happened before in the FTC, never happened, meaning with the amount of rules either new or revised that are in process as we speak. Yeah, you know, you're sitting here as a business owner. Just trying to make a business, employ some people, you know, feed your family, and these things are happening, and you have even no idea.

When you talked about subscription, was it a subscription where money was involved, or was it even, like, say, a subscription to an e-newsletter or something? Well, anything, the key to it is anything that requires a recurring payment. And the classic example is X dollars a month until you cancel. Or it can be X dollars per year if the recurring fee is charged annually, right? So it can be a newsletter. It can be something as simple as that. It can be the same thing as a book of the month club,

anything where a consumer is charged on a recurring basis. And if the consumer does not take an affirmative step, to cancel the subscription, then the recurring fees continue to charge the credit card indefinitely until, again, the consumer actually takes an affirmative action to cancel. So a lot of people get involved in this, and the FTC has now combined that with something called dark patterns, which is very vague. And one of the classic examples is bonnage, which entered into a, massive settlement very recently with the Federal Trade Commission over telephone service, right?

It's a recurring charge, right, for the ongoing service. It's a negative option or a subscription. And what happened was the FTC now combined the concept of dark patterns, which allegedly were that Vantage was making it very. difficult to cancel. In fact, if someone was trying to cancel Vonage his telephone service, they could only do it by telephone. There was no button to click or anything that was relatively easy. Instead, I think your dog disagrees with the telephone. That's the beauty about these kind of things. It

could be real life. That's right. Yeah, this is the real live stuff here. So your dog disagrees with Vonage is making it difficult to cancel telephone service. And, of course, the way was you had to call up. But guess what happened? When you call to cancel, which is the only way you could cancel, the person on the other end of the line for Vonage attempted to talk you out of it. So it was very difficult to cancel. There were other things that made it difficult as well.

and the FTC nailed them for a huge fine by, it was a consent deal, a settlement. But it indicates how serious the FTC is regarding subscriptions, particularly when they view that you've gone overboard and making it difficult to cancel. Well, let's turn the corner and talk about chat GPT, because that certainly is one of the hot topics these days. So what's the concern there? Well, you know, it's chat GPT is relatively new. I think it went online publicly late last year.

The first time I was aware of it was very early this year, 2013. And the FTC has been prepared for this. I was a little surprised. But I did remember when Chat GV. P.T. went live publicly and started reading some comments by the Federal Trade Commission that two, three, or maybe four years ago, the FTC started very actively and very aggressively hiring marketing, or not marketing, but technologists who were very fluent in big data and artificial intelligence. And I started thinking, well, you know they are expecting,

Well, at that time, big data was a big deal, and then they were expecting AI to become public and were wanting to be up to speed. And so they already have a matter, a mounted, a large number of technologists, which, by the way, are actively surveilling. So think about this for a minute. This is a little bit off of the question you ask, but one of the traditional ways that the FTC ends up learning about a potential complaint to make is they have a complaint form at their website, and they have other entities that refer leads to them, leads meaning possible claims for enforcement.

Well, they actually have, and have had for a number of years essentially a marketing funnel that funnels leads. But now it's very clear if you read carefully what the FTC is saying. that they have the capacity to monitor using AI and big data technology to monitor what you're doing online as an advertiser. So really think about it. You know, I hate to use the term Big Brother is watching, but it seems to be that that's the case.

So it's much more difficult now, bottom line, to essentially fly under the radar than it used to be when essentially the FTC could only, you know, visit your website and look at your ad claims or get referrals from the Better Business Bureau, that sort of thing. So they started building up a team of technologists so that they were really ready when GPT came out. And they're basically concerned now

with a couple of policy statements they've made earlier this year about essentially two things. One is that they're interested in how marketers are using the term AI because the FTC says that the term AI is essentially a marketing term because it's hot right now. In fact, the FTC actually uses the term hot to describe AI as a marketing term. If you say that a product or service incorporates AI, you get a product. you get attention.

Of course, that's what marketers are looking for. So generally speaking, the FTC is simply warning marketers not to overuse the term and to not exaggerate. And they give several examples here about advertising about a product or services or service that incorporates AI. In other words, will it really work as advertised? And that typically refers to an efficacy type claim. And the FTC warns you need to be very, very sure they will actually do what it's advertised to do

in any type of unsubstantiated claims would be subject of enforcement actions. Another concern they have with advertising AI-enabled products or services is a claim to the effect that your product, which is AI-enabled, is, quote, better, end quote, than, say, a non-AI product. And the question is, is that really true? Or is it an unsubstantiated claim? Is it really better than a non-AI product? It's got the label AI incorporated, but is it really better? Another one is that any product or service that is AI-enabled does have some risk.

And the FTC will not tolerate a disclaimer they're saying in a statement they've made regarding policy that you're not responsible for results, right? So they want you to be responsible for them and to avoid being responsible through a disclaimer. So those are three things that really concern them about products or services that incorporate AI. And then secondly, the way advertisers and marketers might use AI, specifically chat GPT, which is the rage these days, how marketers might use AI to engineer consumer trust. Now, you know, marketers are in the business of promoting calls to action and getting a result to a call to action. And there may be marketers out there, advertisers who believe that through, by using AI, they can influence the beliefs of consumers or maybe even Frigger emotions or behavior.

So the FTC has said that if you're using advertising or if you're advertising using GPP or any type of generative AI, their overall concern is that you can unduly influence the beliefs, emotions, and even the behavior of consumers, and they refer to this as a quoted term, unearned trust. Because typically, as you know, marketers have to essentially earn a certain level of trust in order to get the result from a call to action that they're looking for. And of course the FTCs. I'm not going to break in because I want to ask a question.

So a really good copywriter who's written sales copy and sales marketing pieces, that's their whole job. And so what you're saying is now the FTC thinks that if I, instead of my writing the copy out of my own brain, I'm going to use AI to write it, then it might be better than my stuff and unduly. Yeah. Yeah, that's what they're saying. But, you know, if you think about it, a professional copywriter who is very good at what he or she does is actually working

and of course there's a limitation here within the rules, right? Working within the rules to get a positive reaction to a call to action in an advertisement. And the ones, the copywriters, the professionals

that I've met with and discussed sort of talking shop have been extremely talented and very good at what they do. But that's what they attempt to do. And so I think what the FTC is saying, if you are doing it in a way that is deceptive, then, but of course that would apply to a copywriter as well.

Exactly. I mean, I remember the thing is you can't ever say anything's going to cure something. That was always the big one in the past. Nothing can cure anything. You might feel better or whatever. And so, I mean, but yeah, a copywriter could never step or is not supposed to step over that boundary of different kinds of things. Yeah, I'm thinking, you know, the FTC in saying that they're concerned about the use of chat GPT in terms of engineering consumer trust and influencing beliefs and behaviors, that's exactly what professional copywriters do. but I guess the FTC is saying if you can do it deceptively or if you can do it using AI

to somehow go deeper into the psyche of a consumer that a professional copyright who is a person wouldn't be able to do. I don't even know if that's possible. But the FTC's concerned about it, okay, unearned trust. And another quote that I've seen recently from the FTC is, steer consumers into a harmful decision. Well, professional copywriters are steering consumers into a positive reaction to a CTA. But the FTC says, you know, steering consumers into a harmful decision.

Well, unprofessional copywriters can be liable for the same thing. So I'm really a little bit struggling here to determine the difference. If it's deceptive, it's deceptive, right? Whether a very talented person is creating the deception or whether working with AI has the same result. I don't really know. So, but to sort of sum up what the FTC is concerned with is there are certain fundamental rights that the FTC has recently described,

and I won't go into all of them. In fact, I couldn't remember them all off the top of my head. Some of them are basically fundamental rights that they have already indicated several years ago. One is the consumer should always be able to know that the consumer is being advertised to, essentially, that an ad is an ad, right? And that came about back in the days of when native advertising was hitting, you know, making a lot of conversions, because they were disguising ads to look like articles in print media or in social media. So that concept, that concern was there years ago with respect to native ads.

But now it might be easier to hide and deceive, and of course that's one of the fundamental rights. Consumers should know that an ad is an ad. And then also they want to be sure and they're concerned about they being the FTC that the consumers knows that he or she is communicating with a person or machine. And that sort of goes back to chat box and that sort of thing. But here is one that I do have made a note of it because it's very significant. And it really jumped out to me as I was reviewing a recent policy statement by the FTC. And that is a duty.

Well, it hasn't been made into a rule yet, but there seriously must be contemplating it. a duty by a marketer or advertiser to monitor and frack actual use and impact of advertising by AI. Think about that. By AI, but not a copywriter. Yeah, well, apparently, yes, that's true. That would be a significant difference to monitor and frack actual use and impact. So that's one that really jumped out to me. So the rest of what I've mentioned here in the last few minutes about chat, GPT, and AI,

and how it might be a concern of the FTC and therefore be a concern for marketers. It's sort of common sense. But this one, in fact, not only common sense, but they seem to correlate with previous concerns by the FTC in a non-examined. AI environment, right? But this one could wreak havoc among digital marketers with the obligation to monitor and frack. And not only the obligation, but they're going to have to pay to do it. If that becomes law, if that becomes part of a rule, then there are going to be all sorts

of software as a service providers out there that provide a service that allows that to happen, but it's going to have to be paid for. and it's going to be another impediment for marketers to actually get their message out and sell something. So that's something to keep track of it. You go back to them, don't use AI to create your advertising stuff. Just use a very qualified copywriter and make sure they don't use AI because now you don't have that rule, right? Well, this is just an initial statement of concern. It's not a rule, right?

It's not even a guideline yet. It's just the beginning of a conceptual list of concerns, of conceptual concerns, so that you might know that this is on the FTC's mind at the present time. So if this becomes a serious problem, it's going to be down the road somewhere. It's not going to be in the next year or so. So let me ask you about,

AI-generated illustrations, like for books and stuff. Tell me what, I mean, is there any kind of issues around that? Is there any copyright issues? Yes. The U.S. Copyright Office was the first, that I'm aware of, the first agency of the United States government that reacted very shortly after, early this year, very shortly after they, after that GPP had been

out, say, for two, three months, three or four months. And they issued a statement that said that, and this is all very traditional copyright principles, there's nothing new here. And that is that the copyright office and the copyright act itself really only recognize copyrightable authorship created by persons, human beings, through essentially sweat of the brow. You know, authorship, real authorship by a real person, either writing text, which is copyrightable authorship, or generating artwork, again, which is a different type of copyrightable authorship. So the policy statement that was issued very shortly after

Shat-GPT started taking everyone's sort of imagination early this year was nothing new. In fact, It became known that a number of authors had submitted for copyright registration works of authorship created by artificial intelligence, either in the written form or in the artistic category, right? And so the FTC said, not only going forward do you need to actually distinguish human-created authorship in an application for copyright registration, distinguish human-created authorship from AI-created authorship. And then they went retroactive with that rule. Any prior registration, prior to this policy statement in the first quarter of this year,

say late last year, needed to be revised and updated to reflect that rule, distinguish authorship by AI from human authorship. So right now, right now that's the general rule. But there are really a lot more issues that are much more subtle than that that are going to be addressed in the near future. So let's say somebody wrote a book, you know, a novel, a fantasy book, a fiction book. and they decided to go to Mid Journey or Daly or someplace like that and get some illustrations done.

And so they've got those illustrations. What you're saying to me is then on the copyright page, they need to indicate that all the illustrations were done by AI or do they register them somewhere? Well, that's a really good question. So let me think about that in reply. First of all, let's go back one step. Let's say that you create an e-book or you create artwork on your own.

Then by virtue of your creation, you own the copyrights and that work without registration at the U.S. Copyright Office. It's referred to generally as the right of automatic copyright. Now, that term automatic copyright is not written in the Copyright Act, but generally speaking, it means that whenever you put pen to paper and go beyond a de minimis level of sentences, you've now crossed the line into authorship that is copyrightable as you create it automatically, right? So the ownership right is created automatically at the time an authorizer. or an artist creates the work.

That's step one, and that results in ownership. Now, then you have the option as an author and owner to file for a copyright registration, which in the United States, by the way, is if you have the registration, it is a prerequisite to bringing a copyright claim for infringement, right? So a lot of authors do that. Many authors, however, do not file for a copyright registration because, remember, they own the copyrights and work. They created by virtue of this unofficial rule of, you know, automatic copyright. So then they merely affix a copyright notice to the work.

Now, if the work is not created by AI, that's just fine. can claim copyright, and they are the owner if they created it. And then if someone infringes and they want to bring an action, they do a fast-track registration for a copyright registration, and they file a law. With the Library of Congress? Is that who they do it with? The Copyright Office, the United States Copyright Office, right? That's the way things have worked for a long time.

Now I'm getting gradually to approaching an answer to your question. Because if the work that is at issue here contains not only, let's say, work that was created by a human author, but also a substantial amount of work created by chat GPT, textual work, for example, or using other forms of AI artistic work, then is it deceptive in some way to put a copyright notice on the work, or, here's the copyright notice, say, portions copyrighted by Chip Cooper, right? I don't know. We haven't gotten quite that far. My, I think, guess is that you're going to see some of that, but we haven't gotten that far yet.

We're still just a few months away from the time early this year. In fact, it was in February that I was starting to play around with ChatGPP and very, shortly thereafter the U.S. Copyright Office came out with this policy statement. So it's been just a few months. But at some point we're going to be addressing those issues. But I'm even thinking about the illustrations, you know, because now there's a lot of people, not only just the copy, but the actual pictures that are on the front cover or inside the book.

Right. Well, yeah, but let me jump in if I may. let's say you're doing a children's book, you're writing the text, but you go to an outsource service provider, such as Fiverr, to create some images. Well, fiber, we believe up until recently, as the images were created by a real human artist. Right. And so in order to claim copyright and put the copyright notice on the book of children's stories with images, you needed to get an assignment of the ownership of copyright from whoever it was at Fiber that created the image.

Right. So that's the way things have been for a long time, right? But what about if the guy from Fiber used AI to create the image? Now we don't really know. We have no control over it. So we have a lot of unanswered questions regarding how do we claim copyright in copyrightable authorship, either parkely or wholly created by AI. So I don't know the answer to some of those, and I think we can only guess,

and we need to wait and see how they shake out over time. Okay, so, man, you know, this is, you know, we're kind of in a scary thing. Talk to me about your being the FTC guardian. What kind of service are you providing for us business owners? Apparently, we're not sitting there reading any of this stuff or knowing any of those stuff. Yeah, it's very interesting. Again, the marketer's cruise comes up, and that is we met on the marketers cruise years ago, and also on one of those cruises prior to the time we met,

I met a guy named Alan Cutts who liked what I was doing. I had created a document generator software program that was creating website documents using rule-based document assembly. And I was involved in working with clients regarding ad claims and some of the things we've been talking about. And so he said, let's start a little company. And he said, I'll do the marketing and run the web. website and you be the guy that, you know, you license in your document generator and also we're going to do a lot of coaching on, you know, live coaching for our members on basically the kind of things we're talking about right now.

And so we formed a company and it's called FTC Guardian. And the website is FTCGuardian.com. If someone were to go there right now, they would see a homepage that's being to be totally redone. So it's not a good time. But anyway, so we met on another marketer's cruise. We've been in business since 2014, and we're really very active now coaching regarding these three triggers that we just have talked about. In fact, we really did not address one of them, which was called ad claimed granularity, which is a strange term. But there were three triggers. We really talked about two of them.

the rulemaking, which is accelerating, and of course, AI and chat GPT, but there's a lot going on with ad claims and how the FTC is interpreting them. So we do twice a month coaching calls for our members, where we go over all of this stuff and basically provide them with what they need to know. Because I'm sure a lot of what you've heard me discussing today, you're not quite probably acquainted with, right? So we provide that service along with the document generator. So it's really a very helpful service, particularly now where you have this huge upswing

and marketing risk due to these three triggers with the way ad claims are being interpreted now by the Federal Trade Commission, the new rules and all of the new and revised rules instead of guidelines anymore. And then you throw into the mixed chat GPT and AI, generative AI, and you've got really an incredible situation that's causing marketing risk to essentially go through the roof, I think, as you said at the beginning of this call. So a good way to keep up with all of that stuff on a very affordable basis. Now, obviously, I'm an attorney.

If you want to become a client or talk to me about how I can work with you, that's fine. but if you just want information about what in the world is really going on, and it's all happening at a very fast pace, then a subscription to FTC Guardian. You get to see me live twice a month. You get to ask questions in the live coaching. We don't terminate the call. If there's any question left, we stay on until all the questions are answered.

And by the way, Alan cuts, my son. called partner in this corporate venture FTC Guardian, Inc. He's a marketing guy. He was on the cruise, right? He's a marketing guy, a digital marketer. And so a lot of the discussion that we have in coaching sessions involves the legal side from me, the kind of information we've been talking about on this call, but it also resonates with Alan because he's a digital marketer. And he has very strong ideas about how it might impact what he does. So it's interesting that you get a fairly balanced presentation. You know, on the one side, I'm, I'm pretty much towing the line legally on what the FTC requires. On the other side, Alan is sort of saying,

now, wait a minute. It's got to be a way for us to market things and still do it within the rules. and what if we do it this way? And so it's sort of like a larger corporation where you've got an in-house legal department, right? And then you've got, of course, the sales and marketing department, and they're always at odds about what to do with marketing products and services. And so there's always tension between the sales and marketing people and the legal people. So you have some of that on these coaching calls that we'll. do. So it's a very cost-effective way to stay up with all of this stuff going on right now

that we're going to be dealing with for at least five years. That's what we've seen before all of this settled out. I would almost say it's like an insurance policy because certainly we don't know what we don't know and we don't want to be at risk. I mean, we want to follow whatever we're supposed to. So can you share how much is the membership for this group? Well, it's 497 for a one-time payment, but there are all sorts of different options, and we have a huge webinar that we're planning probably to release this within the next two or three weeks.

So if anybody would like to send me an email, I'll put you on the mailing list for that webinar, which will give you a lot of information, and we'll be talking a lot about these three triggers as well for about an hour if you can handle it. So Chip Cooper ESQ at Gmail. Again, Chip Cooper ESQ at Gmail.com and just say, hey, I want to be on the webinar, and I'll make sure that he puts you on the list. It'll be, I think, a much deeper dive into some of these issues than what we've had time to do here, and it'll be an opportunity to consider whether it might be something that you should take advantage of. Yeah, because I'm a checklist kind of gal. So I need a checklist, get this done, do this, add this to your website, make sure this doesn't happen, you know,

so that's what I like to do. So, Chip, I'm looking at the clock, and the clock is never my friend. This has been, you know, I mean, it has been long overdue, that's for sure. I know you've got actually an amazing offer for somebody who's listening to this and actually wants to a fast path whether or not they should be part of it. What kind of special offer do you have for the listeners? Well, there are two, actually. One would be go to my website, e-commerce attorney.io, not dot com. Again, e-commerce attorney.io. And in the margins of the web pages, you can sign up for, it's really not a newsletter, but it's sort of like one.

It's what I call a two-minute email. Because a lot of us are too busy to be reading newsletters, right? So this is basically I take all of the recent developments and boil them down into something you can read in two minutes. So it doesn't cost anything. You can sign up by going to the website ecommerce attorney.io, and you'll find it on the margins of the web pages. That's an excellent way to stay up with all of this stuff. The other one is if you want to explore, maybe to talk about a little bit, get to know me a little bit better,

and talk about some issues you have, and maybe discuss the possibility of a future relationship as an attorney-client relationship, then there is a complimentary 30-minute contact call, and I believe you've got the link for that, where you can sign up for it. It's a calendar-operated sign-up for calls, for scheduling the call. So that's another benefit that we have available that you can certainly take advantage of.

Yeah, so I will put that down below in the show notes. So they can sign up for the upcoming webinar. They can go to your two-minute. thing, or if they really want to explore the possibility of an attorney-client relationship, actually then schedule 30 minutes on your calendar, and that will be down in the show notes. But remember, if they look at the webinar, they need to go to my email address, Chip Cooper ESQ at Gmail. Put me on the webinar list, and I'll make sure Alan Cuts gets that and includes it on the list when we send out the mailer. So it sounds good.

Well, Chip, thank you, thank you, thank you. We can't thank you enough for bringing these really important things that we all need to know about. We're busy working our business. And you're our eye and ears, you know, watching us and making sure that we're covered with all of this stuff. So thank you so much for being on today's show. Well, thank you for having me, Nina. And also for the opportunity to get acquainted after we, sort of bump into each other and add a mutual interest chat type thing at the marketer's

cruise. In fact, that's what the marketer's cruise is all about. And so it's good to reconnect. Yep, you're absolutely right. You get to meet 400 possible people who are trying to do things like you're doing. So, all right. Until next time, this is Nina Hirschberger, your host. go out and make it a great day.

Thank you for listening to Megabucks Radio with Nina Hirshberger. To learn more about the resources mentioned on today's show or to listen to past episodes, visit megabucksradio.com.