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Full Disclosure

As one of my blogging idols Robert X. Cringely pointed out today

“The U.S. Federal Trade Commission this week announced rules for bloggers who take money and various other forms of booty in exchange for reviewing products.”

My first thought was that I’m safe. I don’t review products, and that I certainly don’t receive money or other forms of booty in exchange for said reviews.

Then I remembered a line from the second paragraph of the V’ahavta blessing:

“…If, then, you obey the commandments that I enjoin upon you this day, loving God and serving Him with all your heart and soul, I will grant the rain for your land in season, the early rain and the late. You shall gather in your new grain and wine and oil — I will also provide grass in the fields for your cattle — and thus you shall eat your fill…

Holy Cow! Maybe I am in trouble.

In fact, the Guidelines state that I’m in violation of FTC policy (and subject to hefty fines unless

“…(1) the blog provides content that is editorially independent of any sponsor or marketer of a product or service, and (2) there is no material connection with the marketer of a product or service that is discussed in the blog that would call into question the editorial independence of the blog…”

OK, major problem here. Is it even possible to be “editorially independent of” or have “no material connection with” God? I mean, if I was an atheist I guess I could see that being a possibility but sheesh! (no offense intended to any atheists reading this. And hey, email me if you are reading this because I am curious if this blog is working for you or if you are just really really confused.)

I decide to look at this through the FTC’s glasses: I clearly review a product – Torah and Judaism. And not only do I review the product, but I actually endorse it! On top of that, I consume said product as well, by observing the commandments. To cap it all off, that one line from the book of Devarim/Deuteronomy contains an explicit contractual agreement that I’ll get kickbacks for doing so.

By this point I’m seriously panicking. What kind of fines am I going to have to pay? How the heck do you file an FTC disclosure for “rain in season”? My accountant is going to kill me!

I looked over the 81 pages FTC prose and find a section that discusses what makes up false or misleading statements. One line that jumped out at me is:

“When there exists a connection between the endorser and the seller of the advertised product that might materially affect the weight or credibility of the endorsement (i.e., the connection is not reasonably expected by the audience), such connection must be fully disclosed.”

Another statement also caught my eye:

“Endorsements must reflect the honest opinions, findings, beliefs, or experience of the endorser.”

So here’s the deal, oh loyal readers (all 4 of you. 2 of which are probably my family), by way of this blog post, I am clearly disclosing to you that:

  1. As the audience, you should “reasonably expect” there to be a connection between the writer of a blog entitled “The Edible Torah” and God
  2. I am confirming that there is, in fact, a connection between myself (the endorser) and God (the seller of the advertised product: ie: Judaism, Torah, etc.)
    By the way, I’m NOT saying this is God’s only line of products. God clearly understood the concept of “market diversification”.
    Heck, I think there’s a connection between EVERYONE and God, but that’s my belief system and I’m not pushing it on you if you don’t want it (there I go, talking to the atheists again).
  3. Yes indeed, the connection between myself and God does in fact “materially affect the weight or credibility of” my endorsement. It is my firm belief that if there was no connection to God, my endorsement would be far less credible. Mostly because I wouldn’t exist. But again, that’s my belief system.

Finally, and most importantly, my endorsement of Judaism, Torah, God et. al. does “reflect the honest opinions, findings, beliefs, or experience of the endorser.”

And regardless of which brand of God’s products you prefer, I hope the same is true for you.

L’Shalom
Leon

One Response to “Full Disclosure”

  1. Geoffry Roberts says:

    Leon,

    Found your blog by reading the comments on Cringely’s. I loved your take on the FTC ruling. Thanks for the smile.

    Up your readership from four to five. I’m sure I’ll be checking in from time to time.

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