As teens spend an increasing amount of time online, many marketers are trying to reach them by blurring the line between advertising and entertainment.
Now a coalition of consumer watchdog groups is calling foul, filing a complaint with the Federal Trade Commission that contends PepsiCo’s Frito-Lay unit misleads adolescents with its online advertising campaigns for Doritos.
The group, which includes the Center for Digital Democracy, Consumer Action, Consumer Watchdog and The Praxis Project, filed papers Wednesday asking the FTC to investigate what they described as Frito-Lay’s “deceptive and unfair digital marketing practices.” Frito-Lay’s digital marketing campaigns for Doritos, created by the ad firm Goodby, Silverstein & Partners, encourage kids and teens to interact with brands online under the guise of video games and entertainment, according to the groups.
“Frito-Lay disguises its marketing campaigns as entertaining video games, concerts and other immersive forms of entertainment, thus making it more difficult for teens to recognize them as marketing and to be skeptical about the messages they present,” wrote Angela Campbell, an attorney at Georgetown University Law Center’s Institute for Public Representation, in the filing.
The complaint also claims that Frito-Lay collects users’ personal information “without meaningful notice and consent” and “uses viral marketing in ways that violate the FTC endorsement guidelines.”
The watchdog groups point to Hotel 626 and Asylum 626, two horror-themed online games created by Doritos that they say “capitalized on teenagers’ neurobiological vulnerability to thrills and intense sensations.” The latter game apparently requires users to buy a bag of Doritos and use an infrared marker on the bag to complete the game.
In another digital campaign called Late Night Music, Doritos teamed up with popular musical acts including Blink 182 and Rihanna to stream performances online. To control camera angles on a world premiere music video from Rihanna, for example, users had to flash the symbol from a bag of Doritos onto a webcam.
Frito-Lay says it’s aware of the FTC filing and believes "it contains numerous inaccuracies and mischaracterizations,” according to an e-mail from company spokesperson Aurora Gonzalez. "PepsiCo and its Frito-Lay division are committed to responsible and ethical marketing practices. Our marketing programs, which are often innovative, comply with applicable law and regulations.”
FTC spokesperson Betsy Lordan said the agency had received the complaint and would "review it carefully."
The FTC created an interagency working group including the Federal Drug Administration, the Centers for Disease Control, and the Department of Agriculture to draw up voluntary guidelines that companies can follow when marketing food to children. The group released an initial set of those guidelines in May, asking for public comment.
On Oct. 12, FTC Bureau of Consumer Protection director David Vladeck testified to Congress that the working group was making “significant revisions” to its initial proposed principles, and would focus mainly on marketing that targets children rather than adolescents between the ages of 12 and 17.