Testimonial copy winks at typicality

Source: Helios Daily — paid social (draft)

“10,000 five-star reviews — results not typical? We didn't say that.”

Why this is a finding

16 CFR § 255.2 requires consumer endorsements to reflect typical results, or to clearly disclose generally expected performance. Joking about the disclosure is still a disclosure failure.

Suggested fix

State typical results, or do not use the testimonials. Delete the wink.

A draft for the officer. RuleCites does not clear copy.

First seen: Sep 2, 2026, 9:14 AM EDT
Last scan: Sep 2, 2026, 9:14 AM EDT