Digital Influencer Marketing Worldwide Legal Developments and Switzerland Digital Influencer Marketing is a new subtle form for reaching
target audiences online. Due to its' increasing emergence as a marketing practice, governmental agencies and selfregulatory bodies worldwide have reacted with the issuance of guidelines how such practices should be conducted in a transparent manner. Also, a few court decisions have been rendered with remarkable remedies ordered. Therefore, it appears sensible to take broad look at what's happening on our globe. In the following, we will provide (i) an overview on noteworthy legal developments with regard to digital influencer marketing in select jurisdictions worldwide, (ii) an overview on the legal status of digital influencer marketing in Switzerland and (iii) a general impact assessment for businesses in Switzerland.
Newsletter No. 119 October 2017
By Dirk Spacek Dr. iur., LL.M., Attorney at Law +41 58 658 56 52 email@example.com
New Transparency Rules for Digital Influencer Marketing Practices
With the increasing emergence of digital influencer marketing, governmental agencies and self-regulatory bodies worldwide have reacted with guidelines on transparency rules which should be observed. Also, a few court decisions have been rendered which could have a distinct impact on such marketing practices in Switzerland. The following provides an overview on select legal developments worldwide, an overview on the legal status of digital influencer marketing in Switzerland and a general impact assessment for businesses in Switzerland.
The media industries' past is marked by revolutionary technical advances (such as the development of radio-, television-, telecommunications-, internet- and, recently, social media-networks). With these new technical tools, advertising has adapted new, and far subtler forms for reaching its target audiences. NOAM CHOMSKY once said (in a sarcastic way): The advertising industry's prime task is to ensure that uninformed consumers make irrational choices, thus undermining market theories that are based on just the opposite. TIM WU who recently published his new book The Attention Merchants describes the advertising industry's goal as the epic scramble to get inside our heads. In his view, in an internet-based time when access to information is virtually unlimited, our short-term attention has become the most important commodity for traders, rather than information itself. Recent legal developments on so called digital influencer marketing indicate that some of it should be critically reviewed.
2. Digital Influencer Marketing
Digital influencer marketing is a new buzzword in today's advertising industry. The term is vacuous and doesn't have a distinct meaning. After all, every advertising effort aims at influencing somebody. As commonly used today, the term probably means a more subtle, frequently
online-based form of advertising with the help of intermediary opinion leaders able to reach broad audiences (so called influencers). Influencers can be celebrities (like famous actors or football-players), but also other individuals with a strong communicative engagement in the online-world (also pejoratively referred to as micro-celebrities with a substantial amount of followers). They usually act through blogs, online-fora or social media networks, mostly in the form of product reviews. Summarized simply, influencer marketing is a more indirect way of reaching the public through intermediaries providing individual, authentic reviews, seemingly authentic. Pursuant to a recent survey, companies are increasingly investing in influencer marketing.
As main benefits to it were cited:
Opportunity to establish an emotional connection between their brand and the consumers (rather than a fleeting impression through wallpapers or displays);
Generate authentic, easily-discoverable product reviews (e.g., an individual presents his seemingly authentic view on his own product experience);
Generate advertising cost-effectively (cost-efficiency is usually achieved through flexible payment models as frequently, influencers are only paid based on the number of engagements their content draws);
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Reaching younger generations who don't trust traditional advertising (Millennials);
Drive engagement around a marketer's brand (e.g., drive traffic to website or directly trigger online and in-store product sales); and
Grow a marketer's e-mail database with qualified consumers1.
3. Legal implications
Influencer marketing has a legal flipside: Everyone is free to influence other people. And, of course, people are free to behave like sheep and accept being influenced. However, where influencing amounts to mislead people in their informed decision-making, such behavior is forbidden under the law of most jurisdictions.
Worldwide issuance of guidelines on digital influencer marketing
Due to the recent emergence of digital influencer marketing, governmental agencies and self-regulatory bodies worldwide have reacted with the issuance of guidelines on digital influencer marketing, cease-and-desist-letters and a few first court decisions have been rendered. Considering that the internet is accessible to a worldwide audience, whoever posts something online can be confronted with multiple jurisdictional requirements. Therefore, it is sensible to take a broad look at what's happening on our globe.
4. Legal Developments Worldwide
United States of America
The Federal Trade Commission (FTC) is the federal agency for consumer protection and competition jurisdiction in broad sectors of the United States economy. In an effort to provide guidance, the FTC has updated its' so called endorsement gui-
1 The State of Influencer Marketing 2017, A look into how brands and agencies view the future of influencer marketing, published by LINQIA, currently available under http://www.linqia.com/ insights/state-of-influencer-marketing-2017/.
des and Frequently Asked Questions (FAQ). The FTC requires that marketers and social media reviewers disclose connections and provides different hashtags for effective disclosures on social media platforms. Among the most relevant recommendations, the following are noteworthy2:
Any compensation provided from a marketer to an influencer (including free or discounted products, travel or accommodation) must be disclosed. Details of compensation are not required, but the compensation fact should be disclosed by using a paid hashtag.
Tagging a brand in a post (e.g., posting a photo and assigning the keyword of the brand to a dress) is considered an endorsement and requires a disclosure if the endorser has a relationship with the brand.
Disclosures on Instagram, Snapchat and other social media platforms should be present in the picture or within the first three lines of the description, as for videos, the FTC recommends that such disclosure is superimposed over the video in a manner noticeable and easy to discern (and not only visible if visitors click more).
Specific wording should be used for social media disclosures, such as #ad or #sponsored. Likewise #my company or #employer's is recommended, whereas #employee, #Thanks, #collab, #sp, #spon without further information is not considered sufficiently clear and #ambassador might even be considered ambiguous/confusing.
In addition to the above, the FTC has settled a first-ever complaint against individual social media influencers who co-owned an online gambling platform (called CSGO Lotto) on which two influencers deceptively endorsed the platform
2 See https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking Please note that this foreign law summary is not provided by a US-qualified attorney and assumes no claim for completeness or legal accuracy.
without disclosing their ownership interest in the company and paid other influencers to promote the same3.
The International Consumer Protection and Enforcement Network (ICPEN), in work led by the UK's Competition and Markets Authority (CMA) has published several new guidelines on online reviews and endorsements applicable to review administrators, traders and marketers and digital influencers4. In its guidance for digital influencers, ICPEN provides that if an online review or endorsement is not based on a genuine user experience or displays elements of bias without appropriate disclosure, then it can negatively impact on consumers and competition. Pursuant to ICPEN, businesses and individuals in a position of online influence should tell their readers/viewers about any incentive (financial or otherwise) that may have influenced or led them to post particular content. The guideline directs influencers to only reflect genuine views and to clearly and prominently disclose their commercial relationship without specifying the form of disclosure in detail. A disclosure may be appropriate irrespective of whether the digital influencer has been paid or is otherwise obliged or incentivized to write or talk about a product or service. CMA has been warning celebrities that it will take further actions if they continue to promote brands on social media without disclosing to be paid5.
3 See https://www.ftc.gov/news-events/pressreleases/2017/09/csgo-lotto-owners-settle-ftcsfirst-ever-complaint-against for more specific information. Please note that this foreign law summary is not provided by a US-qualified attorney and assumes no claim for completeness or legal accuracy.
4 See https://www.gov.uk/government/news/ online-reviews-guidelines-mark-end-of-cmasicpen-presidency for more specific information. Please note that his foreign law summary is not provided by a UK-qualified attorney and assumes no claim for completeness or legal accuracy.
5 See DAVID BOND, Social media celebrities warned on sponsorship disclosure, in: Financial Times, August 31, 2016, currently available under https://www.ft.com/ content/26d91166-6d3d-11e6-9ac1-1055824ca907.
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In June 7, 2017, the French association for regulation of the advertising profession (ARPP; in French autorit de regulation professionelle de la publicit) published a new guidance on digital influencer marketing. This guidance has been integrated into ARPP's general recommendation for publicist communication digital V4 (in French: recommandation communication publicitaire digitale V4)6. ARPP's recommendations define influencers as any individual who expresses a point of view or provides advice in a specific field in writing or through audio-visual channels, according to his or her own style of processing in a way which is identified by his audience. The ARPP provides two general recommendations for digital influencers: (i) If an influencer enters into a commercial collaboration with an advertiser for the purpose of publishing content, such collaboration should be explicitly identified in a way that is immediately apparent to the public. Identification can be done by any applicable means (e.g., within statements themselves or in a text accompanying the content or mentioned during a video). Furthermore, (ii) if the statements of the influencer are qualified of an advertising nature, all other ARPP ethical rules must be observed as well7.
Germany provides for two recent precedents on digital media influencing. German self-regulatory bodies of the advertisement industry have reacted to it and implemented some of the court's findings. In the following, the reasoning of the two German court decisions shall be summarized.
6 See http://www.arpp.org/actualite/communicationinfluenceurs-marques/ for a summary of the new guidance and http://www.arpp.org/nous-consulter/ regles/regles-de-deontologie/communication-publicitaire-digitale/ for down-loading ARPP's general recommendation for publicist communication digital V4.
7 For further information, see http://www.arpp.org/ actualite/communication-influenceurs-marques/.
On June 8, 2017, the Celle Higher Regional court issued a judgement on a request for injunctive relief of the German Association for Social Competition (in German: Verband Sozialer Wettbewerb) raised against the German drugstore chain Rossmann8. A 20-year-old Instagram influencer with 1.3 million followers had advertised the drugstore chain in one of her posts. At the bottomline of the post, the influencer placed six hashtags, the second of them designated as #ad. While the first instance court (the land court of Hannover) denied the claims based on the view that the commercial purposes of the influencer's post were perceivable from the circumstances and thus, no, labelling was required, the second instance (the Celle Higher Regional court) held that this constitutes an infringement of the German Act against unfair competition. The influencer's post was qualified as a commercial action without transparently disclosing the commercial intent to consumers. The hashtag #ad at the end of the post in the second line was considered insufficient as average consumers would not read them and only the ones who read the entire post until the end would have a chance to review. In addition, the Cell Higher Regional court emphasized the post contained many Emojis (smileys and similar signs) which are rather common use in private messages rather than in commercial advertisement. The decision shows that not only influencers are addressees of influencer marketing rules. The companies themselves (who instruct or incentivize influencers to market their products) are equally liable under German unfair competition law.
The German state media authorities (in German: Landesmedienanstalten) have meanwhile updated their FAQ on adverti-
8 Decision of the Celle Higher Regional Court of June 8, 2017 13 U 53/17, currently publicly accessible over: www.rechtsprechung.niedersachsen.de/jportal/portal/page/bsndprod.psml?doc. id=KORE576642017&st=null&showdoccase=1.
sing issues in social media. It now reads: When marking a post as PROMOTION (in German: Werbung) or ADVERTISING (in German: Anzeige), you will be on the safe said that much is certain ... At the current time, we cannot recommend marking posts as #ad, #sponsored by, or #powered by9. Unlike in the USA, it appears that the hashtag recommendations issued by the FTC10 would probably not suffice to establish online-marketing-compliance in Germany.
The Flying Uwe-Case:
On June 8, 2017, the media counsil of the media institution of Hamburg/SchleswigHolstein (MSH) has sanctioned a digital influencer active on YouTube with a fine of 10'500 Euro for non-compliance with advertising disclosure duties11.
The German YouTube-Poster Flying Uwe regularly presented videos on fitness-products on two separate YouTubechannels, without labeling them as advertisements. In November 2016, MSH requested him to label his videos and the accompanying descriptions which recommendation he only partially followed. Flying Uwe had an ownership interest in the fitness products of one company presented, an omitted the labeling to dissimulate his interest. It is pertinent to mention that the legal foundation of
9 See www.die-medienanstalten.de/the-
men/werbeaufsicht/#c3034. See also www.
chat-facebook-co/ for further information.
10 See earlier in Section 4., "United States of America".
11 Decision of the media counsil of the media institution of Hamburg/Schleswig-Holstein, June 8, 2017, currently available under https://www. ma-hsh.de/infothek/pressemitteilung/medienratder-ma-hsh-beschliesst-geldbusse-in-hoehevon-10-500-euro-gegen-youtuber-flying-uwe-wegen-fehlender-werbekennzeichnung.html with a down-loadable PDF of the official press statement.
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MSH's decision and the fines imposed was a public broadcasting treaty (in German: Rundfunkstaatsvertrag12). This treaty stipulates a strict advertisement labeling for TV-offerings and TV-similar content offerings13. MSH has therefore applied public broadcasting rules to internet-based audiovisual content provided on YouTube. Based on publicly available information, MSH has sent further cease-and-desist letters to various other YouTube-users.
5. Legal Status in Switzerland
The German precedents are likely to have a measurable impact on Switzerland as German is an official language in both countries. Thus, online-users from both countries may be misled by online-content posted in either of both countries. Furthermore, the Swiss and the German legal systems are similarly shaped as they share joint historic roots. Nevertheless, there are distinct differences for Switzerland to point out.
Swiss Federal Act against Unfair Competition
The Swiss Federal Act against Unfair Competition (FAUC)14 aims at ensuring transparent and unbiased competition in the market in the interest of all market participants (Art. 1 FACUC). Pursuant to Art. 2 FAUC, anyone who acts in a misleading manner in the market or in another way against good faith principles, which is suitable to influence the relationship between competitors or offerors and consumers, acts unlawful (so called
12 See the German states` treaty for broadcasting and telemedia of August 31, 1991, currently available online under http://www.ard.de/download/538848/Staatsvertrag_fuer_Rundfunk_und_Telemedien_in_der_Fassung_des_19__Aenderungsstaatsvertrags_vom_3__bis_7__12__2015.pdf.
13 See Footnote 12 with references to 58 para. 3 in combination with 7 para. 5 of the German states` treaty for broadcasting and telemedia of August 31, 1991 as referenced to under Footnote 13. Please note that his foreign law summary is not provided by a German-qualified attorney and assumes no claim for completeness or legal accuracy.
14 GermanVersion of this statute available under www. admin.ch/opc/de/classified-compilation/19860391/.
general clause, in German: Generalklausel). Over the years, Swiss courts and scholars have produced case law and opinions on misleading market practices in an attempt to concretize the general clause of Art. 2 FAUC. In addition, Art. 3 para. 1 lit. a. u. FAUC provides for a comprehensive list of more specific unlawful market practices.
The FAUC does not provide any explicit provision on digital influencer marketing. There is no publicly accessible case law to it available at the moment. Nevertheless, non-transparent marketing practices have already been qualified as unlawful under the general clause of Art. 2 FAUC. Swiss scholars have expressed the view that disguised advertising, in particular non-compliance with the principle to separate editorial content from advertising should be considered unlawful under Art. 2 FAUC (separation duty). Pursuant to their view, this applies irrespectively of whether an advertiser has received compensation or not; the latter is only considered indicative but not a constitutive requirement15. It is therefore prudent to assume that this qualification could apply to non-transparent digital influencer marketing as well. This appears supported by two Swiss self-regulatory organizations, namely the Swiss Commission on Fair Competition (SCFC, in German: Lauterkeitskommission)16 and the Swiss Press Counsil (SPC; in German: Presserat)17.
15 See e.g. PETER JUNG, in Peter Jung/Philippe Spitz (editors), Federal Act Against Unfair Competition, hand-commentary, Berne 2010, Art. 2 marginal note 41; see also ROLF H. WEBER/STEPHANIE VOLZ, Online Marketing and Competition Law, Zurich 2011, 52, marginal note 205, 244; LUKAS BHLMANN/ MICHAEL REINLE, Separation duties for native advertising and influencer marketing stricter requirements of the press counsel and the case "Flying Uwe", July 29, 2017, currently available under https:// www.mll-news.com/trennungsgebot-beim-nativeadvertising-und-influencer-marketing-strengerevorgaben -des-presserats-und-der-fall-flying-uwe/.
16 See http://www.faire-werbung.ch/ for further information on the Swiss fair competition commission.
17 See http://www.presserat.ch/ for further information on the Swiss press counsel.
SCFC-Principles of fairness in commercial communication
The SCFC provides for a publicly available guideline named principles of fairness in commercial communication. It provides for principles as to how fair advertising should be conducted in practice18. The guideline has not been updated since April 2008, but it contains principles, which are likely to apply to digital influencer marketing as well. Among other provisions, the principles 3.1 to 3.12 stipulate that commercial communication (i.e. advertising) recognizable and that it should be labelled as such. The guidelines of the SCFC are not binding and the SCFC has no authority to issue sanctions. However, its decisions are highly respected by their member addressees and its principles are frequently observed by state courts when interpreting legal statutes (as e.g. the FAUC). So far, the SCFC has not issued specific guidance on digital influencer marketing.
SPC Decision on the case www.watson.ch
In June 2017, the SPC has taken position on digital marketing practices based on a university student's complaint against a post on the online-newspaper www.watson.ch (Watson)19. Watson is a Swiss online-newspaper active since January 22, 2014 which to a great extent finances itself through digital advertising. In the relevant post rebuked by the student, Watson presented a proprietary designed Quiz. A reader was supposed to identify which outdoor-sport was most suitable to him/her. After filling out the question catalogue, online advertisements of health insurance companies appeared with the label presented by which were clearly linked to the outcome/results of
18 See http://www.faire-werbung.ch/wordpress/ wp-content/uploads/2013/09/Grundsaetze.pdf.
19 See the official statement of the SPC of June 23, 2017, Nr. 15/2017 (X. c. "watson.ch"), currently available under http://www.presserat.ch/_15_2017.htm.
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the Quiz (so called contextual advertising). Health insurance companies had paid Watson for the opportunity to insert their ads in such contextual manner. The ads were, however, clearly labelled as advertisement with the official insurance company's logo20. In its considerations, the SPC affirmed that pursuant to section 2 of its rules of organization, the SPC is competent for the editorial part or professional ethics matters for all public, periodical and/or topicality-related media21. The SPC examined whether Section 10 of the declaration of rights and duties of journalists (DRDJ) was infringed. Section 10 forbids that marketers stipulate conditions on or otherwise influence editorial media content. The SPC came to the conclusion that the contextual advertising on Watson's website was critical and recommended to limit marketer's right to having a say to the ads itself22. Finally, the SPC examined whether the separation duty between editorial and advertising content in Section 10.1 DRDJ was infringed and the SPC was not able to discern a doubtless infringement (the ads were labelled and perceivable as third party content). However, it emphasized the duty of Watson to explicitly label advertisements and suggested to use terms like ad, advertisement, publicity spot or publicity report. In addition, the SPC considered the label used on Watson's website presented by to be insufficiently clear. It recommends using the more transparent labeling paid by. Most importantly, the SPC emphasized that transparency was key and that it will examine whether additional guidelines should be issue to address new digital advertising practi-
ces23. As for the SCFC, even though decisions of the SPC are not legally binding, the decision can be considered indicative for digital marketing influencers in Switzerland.
Swiss public broadcasting statutes
Swiss public broadcasting statutes provide for a strict separation duty between editorial and advertising content (Art. 9 para. 1 of the Swiss Federal Act on Broadcasting (FAB)24). Non-transparent advertising practices are explicitly forbidden under Art. 10 para. 3 of the FAB and further specified under Art. 11 para. 2 of the related FAB-regulation25 as nontransparent advertising practices are any presentations of goods, services or ideas with an advertising character in editorial content, in particular against the receipt of compensation. The observance of these rules is supervised by the Swiss Federal Office of Communication (OFCOM). OFCOM is entitled to issue direct financial sanctions in the event of non-compliance. However, Swiss public broadcasting statutes are not considered applicable to non-linear (i.e., on demand )online-content. Pursuant to Art. 1 FAB, broadcasting programs are defined as content sequences offered in a continuous, timely scheduled manner addressed to the public. Therefore, current Youtube-offerings and most other social-media-channels operating in a non-linear manner are unlikely to be qualified as a broadcasting program in Switzerland and direct
governmental interventions from OFCOM are not expected to occur at the moment26.
6. Impact for Businesses in Switzerland
Worldwide developments on digital influencer marketing are on their way. Thus, whoever goes online and posts content in a way discernably addressed to a worldwide audience can be confronted with multiple jurisdictional requirements. As the previous summaries have shown, non-transparent digital influencer marketing practices can trigger sanctions under various jurisdictions (ranging from being severely criticized or warned by self-regulatory organizations, sued by individuals before court or even fined directly by public administrative bodies). Therefore, the following action requirements are generally recommended.
1. It is recommended to
a. separate branded content from editorial content and label advertisements as such;
b. transparently disclose existing relationships with marketers (incl. compensation or incentives received);
c. observe guidance issued by public or self-regulatory bodies (in particular suggested labeling such as Promotion, Advertising, paid by in a prominently perceivable manner, be it in the form of normal writing or combined with social media-typical forms of communication like hashtags).
20 See the official statement of the SPC of June 23, 2017, Nr. 15/2017 (X. c. "watson.ch"), currently available under http://www.presserat.ch/_15_2017.htm.
21 See the official statement of the SPC of June 23, 2017, Nr. 15/2017 (X. c. "watson.ch"), currently available under http://www.presserat.ch/_15_2017.htm.
22 See the official statement of the SPC of June 23, 2017, Nr. 15/2017 (X. c. "watson.ch"), currently available under http://www.presserat.ch/_15_2017.htm.
23 See the official statement of the SPC of June 23, 2017, Nr. 15/2017 (X. c. "watson.ch"), currently available under www.presserat.ch/_15_2017.htm.
24 See an English version of the statu-
te available under www.admin.ch/opc/en/
25 See an English version of the ordinance
available under www.admin.ch/opc/en/clas-
26 See also LUKAS BHLMANN/MICHAEL REINLE, separation duty for native advertising and influencer marketing strict requirements of the SPC and the case "Flying Uwe", which express a similar view under www.mll-news.com/ trennungsgebot-beim-native-advertising-und-influencer-marketing-strengerevorgaben-des-presserats-und-der-fall-flying-uwe/.
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2. It is recommended to reflect which territorial audience is envisaged to be addressed with content offerings. Depending on the outcome, different approaches to establish compliance are imaginable:
a. A multinational compliance approach by complying with requirements of multiple jurisdictions affected (which requires consultation of multiple attorneys wellversed in this area of the law in their local jurisdiction);
b. A strictest compliance approach (applying the currently strictest legal regime found worldwide in an attempt to be compliant with all the less strict jurisdictions as well); or
c. A territorially selective compliance approach (by excluding addressees from certain territories). To which extent territorially selective compliance is realizable must be examined under all technical resources available (e.g., with geo-blocking of foreign IP-addresses, select offerings provided under different top-level domains such as .ch, .fr, .it, etc. based on users' different foreign IP-addresses or by using specific languages which only addressees from select territories are likely to understand etc.). This approach is especially recommended when online-offerings are likely to be qualified as broadcasting programs under certain public broadcasting statutes (e.g., onlinevideo-platforms and similarly shaped offerings).
3. It is important to bear in mind that digital influencer marketing rules are not only applicable to influencers. The rules may in principle apply to all three parties involved: (i) The influencer (as a primary infringer), (ii) the marketer (as secondary or even a primary co-infringer, if he willingly instructs or incentivizes the influencer to behave non-transparently) and (iii) online content-/social media-platforms (as potential contributory infringers if infringements are conducted over their website). Marketers and online content-/social media-platforms should therefore consider the following additional action requirements:
a. Marketers should stipulate digital influencer-compliance as a requirement in their agreements with influencers (namely that influencer will comply with digital influencer marketing rules under the law(s) applicable to their target audience, i.e., to the extent required, transparently and prominently disclose the relationship with marketer, incl. the fact that compensation was received, and undertake all necessary steps that editorial content is separated from branded content etc.). Needless to say that boilerplate language in the confidentiality section of agreements (like confidential information, including the existence of this agreement, may not be disclosed to any third party) should not be upheld. Rather, an exception for the observance of digital influencer marketing rules should be inserted.
b. Online-content/social media-platforms (like, e.g., Facebook, Youtube, or Instagram) may start considering new approaches to avoid non-transparent digital influencer marketing conducted over their platforms. Based on publicly available information, Instagram
is currently testing the introduction of a branded content tool to make it easier for users to disclose and recognize posts as paid advertising, while Facebook appears to have introduced such tools slightly earlier27. Further technical developments are to be expected in this regard.
The Walder Wyss Newsletter provides comments on new developments and significant issues of Swiss law. These comments are not intended to provide legal advice. Before taking action or relying on the comments and the information given, addressees of this Newsletter should seek specific advice on the matters which concern them. Walder Wyss Ltd., Zurich, 2017
27 See e.g., DAVID COHEN, Instagram Just Added a Tag to Make Sponsored Content More Transparent, June 14, 2017, currently available under www.adweek.com/ digital/instagram-paid-partnership-with/ and David Cohen, Facebook Added "Paid" to Branded Content, and More Pages Can Now Start Publishing It, March 30, 2017, currently available under www.adweek. com/digital/facebook-paid-branded-content-pages/.
Walder Wyss Ltd. Attorneys at Law
Phone + 41 58 658 58 58 Fax + 41 58 658 59 59 firstname.lastname@example.org