{
  "title": "The risk of Dark Reach",
  "description": "A running record of public enforcement actions and lawsuits in the United States involving creator, influencer, affiliate, and social media content, maintained by Watchword Labs, LLC. It shows what exposure of this kind can turn into. Each entry is labeled by scope: 'Creator content' where a creator, affiliate, or brand partner made the post on a brand's behalf; 'Brand's own posts' where the company's own account or storefront was cited. Entries are matters of public record. A filed lawsuit or complaint is an allegation, not a finding. Nothing here is legal advice.",
  "publisher": "Watchword Labs, LLC",
  "url": "https://usewatchword.com/risk.html",
  "data_url": "https://usewatchword.com/risk.json",
  "coverage_start": "2023-01-01",
  "last_updated": "2026-09-14",
  "update_cadence": "weekly",
  "entries": [
    {
      "id": "2026-09-04-lawsuit-sephora",
      "date": "2026-09-04",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Sephora USA, Inc.",
      "category": "Beauty",
      "platforms": [
        "TikTok"
      ],
      "summary": "A parent and a minor filed a proposed class action (Vettel v. Sephora USA, Inc., No. 3:26-cv-09653, N.D. Cal.) alleging that Sephora marketed more than 1,600 skincare products with active ingredients to children and teens without age-appropriate warnings, and that it built demand through paid influencers, a TikTok marketing partnership, and free products and gifts to young creators that were not disclosed. These are allegations; no finding has been made.",
      "source_url": "https://ppc.land/sephora-sued-over-1-600-skincare-products-marketed-to-tweens-and-teens/",
      "source_title": "PPC Land, Sephora sued over 1,600 skincare products marketed to tweens and teens, September 5, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2026-09-lawsuit-polymarket-class",
      "date": "2026-09",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Blockratize, Inc. dba Polymarket",
      "category": "Other consumer",
      "platforms": [
        "Social media"
      ],
      "summary": "A District of Columbia resident filed a proposed class action in federal court in Washington, D.C., alleging that Polymarket recruited content creators to film betting videos on copies of its website that the company built and ran on its own servers, so that the videos showed wins that would have been losses on the real platform. These are allegations; no finding has been made.",
      "source_url": "https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/class-action-follows-nacas-polymarket-influencer-lawsuit",
      "source_title": "Kelley Drye, Class Action Follows NACA's Polymarket Influencer Lawsuit, September 8, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2026-08-14-fda-r3-medical",
      "date": "2026-08-14",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "R3 Medical Companies (Bello Bio, LLC and Regen Suppliers, LLC)",
      "category": "Other consumer",
      "platforms": [
        "YouTube",
        "TikTok",
        "Instagram",
        "Facebook"
      ],
      "summary": "FDA issued a warning letter stating that umbilical cord and exosome products sold under the ReBella name were unapproved new drugs and unlicensed biological products, citing the company's websites and its YouTube, TikTok, Instagram, and Facebook accounts, including a March 2026 YouTube video in which an employee described the products as anti-inflammatory and listed conditions they were used for.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/r3-medical-companies-726330-08142026",
      "source_title": "FDA warning letter, R3 Medical Companies, August 14, 2026",
      "scope": "Brand's own posts"
    },
    {
      "id": "2026-06-26-lawsuit-polymarket-naca",
      "date": "2026-06-26",
      "actor": "Private plaintiff",
      "action_type": "Lawsuit filed",
      "company": "Blockratize, Inc. dba Polymarket",
      "category": "Other consumer",
      "platforms": [
        "X",
        "Social media"
      ],
      "summary": "The National Association of Consumer Advocates sued Polymarket, its CEO, and its chief marketing officer in D.C. Superior Court (No. 2026-CAB-004388) under the District's Consumer Protection Procedures Act, alleging that influencers were paid to promote the platform without disclosure, that creators filmed bets on a simulated version of the platform, and that a paid clipping program spread the videos with instructions not to make them look like ads. These are allegations; no finding has been made.",
      "source_url": "https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/all-bets-are-off-as-polymarket-faces-lawsuit-over-influencer-campaigns",
      "source_title": "Kelley Drye, All Bets are Off as Polymarket Faces Lawsuit Over Influencer Campaigns, June 28, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2026-06-17-fda-alwinshop",
      "date": "2026-06-17",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Telos Trading Limited dba Alwinshop",
      "category": "OTC health",
      "platforms": [
        "TikTok Shop"
      ],
      "summary": "FDA issued a warning letter stating that a Prostatitis Remission Cream sold through the company's TikTok Shop storefront was an unapproved new drug and misbranded. The letter cites the TikTok Shop listing as the place the product was offered and copies TikTok's Global Head of Trust and Safety.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/telos-trading-limited-dba-alwinshop-729062-06172026",
      "source_title": "FDA warning letter, Telos Trading Limited dba Alwinshop, June 17, 2026",
      "scope": "Brand's own posts"
    },
    {
      "id": "2026-06-16-lawsuit-gymshark",
      "date": "2026-06-16",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Gymshark USA, Inc.",
      "category": "Apparel",
      "platforms": [
        "Instagram",
        "YouTube",
        "TikTok"
      ],
      "summary": "A consumer filed a proposed class action (Lupea v. Gymshark USA, Inc., No. 1:26-cv-05073, S.D.N.Y.) alleging that Gymshark had influencers on Instagram, YouTube, and TikTok promote its apparel without disclosing that they were paid, and that exclusivity arrangements with those influencers were not disclosed to consumers. These are allegations; no finding has been made.",
      "source_url": "https://www.classaction.org/news/gymshark-class-action-lawsuit-claims-influencer-posts-not-properly-disclosed-as-ads",
      "source_title": "ClassAction.org, Gymshark class action lawsuit claims influencer posts not properly disclosed as ads, June 22, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2026-06-02-ftc-amare",
      "date": "2026-06-02",
      "actor": "FTC",
      "action_type": "Complaint filed",
      "company": "Amare Global Holdings Inc.",
      "category": "Supplements",
      "platforms": [
        "Instagram",
        "TikTok",
        "YouTube",
        "Facebook"
      ],
      "summary": "The FTC sued multilevel marketer Amare Global, alleging that the company and its brand partners advertised Kids Happy Juice and related supplements on Instagram, TikTok, YouTube, and Facebook with unsubstantiated claims to treat depression, anxiety, and ADHD, and made deceptive earnings claims to brand partners. These are allegations in a complaint.",
      "source_url": "https://www.ftc.gov/news-events/news/press-releases/2026/06/ftc-sues-stop-amare-global-holdings-misrepresenting-health-benefits-its-dietary-supplements-children",
      "source_title": "FTC press release, June 2, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2026-05-15-lawsuit-petpivot-settled",
      "date": "2026-05-15",
      "actor": "Private plaintiff",
      "action_type": "Settlement",
      "company": "PetPivot Inc.",
      "category": "Other consumer",
      "platforms": [
        "TikTok",
        "TikTok Shop"
      ],
      "summary": "The makers of the Meowant litter box and PetPivot settled Meowant's lawsuit, which had alleged that PetPivot engaged two TikTok creators to post review videos containing false statements about Meowant products, with links to PetPivot's TikTok Shop storefront. Settlement terms were not reported.",
      "source_url": "https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/cat-fight-ends-up-in-court",
      "source_title": "Kelley Drye, Cat Fight Ends Up in Court, January 25, 2026 (updated with settlement)",
      "scope": "Creator content"
    },
    {
      "id": "2026-05-14-fda-polleymed",
      "date": "2026-05-14",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "PolleyMed, LLC",
      "category": "OTC health",
      "platforms": [
        "Facebook",
        "Instagram"
      ],
      "summary": "FDA issued a warning letter stating that the SaniiSwab nasal product was an unapproved new drug, citing Facebook and Instagram posts about preventing illness and stopping the spread of germs during flu season, and a website statement that the product was 'FDA OTC approved,' which FDA said was false.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/polleymed-llc-726018-05142026",
      "source_title": "FDA warning letter, PolleyMed, LLC, May 14, 2026",
      "scope": "Brand's own posts"
    },
    {
      "id": "2026-04-29-fda-optihealth",
      "date": "2026-04-29",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "OptiHealth Products, Inc.",
      "category": "Supplements",
      "platforms": [
        "Facebook"
      ],
      "summary": "FDA issued a warning letter stating that Super Antioxidant (OPCXtra) products marketed as dietary supplements were unapproved drugs because of disease claims, citing the company's website and the Facebook page that directed consumers to it.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/optihealth-products-inc-704899-04292026",
      "source_title": "FDA warning letter, OptiHealth Products, Inc., April 29, 2026",
      "scope": "Brand's own posts"
    },
    {
      "id": "2026-01-16-lawsuit-petpivot",
      "date": "2026-01-16",
      "actor": "Private plaintiff",
      "action_type": "Competitor lawsuit filed",
      "company": "PetPivot Inc.",
      "category": "Other consumer",
      "platforms": [
        "TikTok",
        "TikTok Shop"
      ],
      "summary": "The makers of the Meowant self-cleaning litter box sued PetPivot and several TikTok creators in the Eastern District of Texas, alleging the creators posted videos with false statements about Meowant's product and pricing, linked to PetPivot's TikTok Shop storefront, and were paid through TikTok's affiliate system. These are allegations; the case later settled.",
      "source_url": "https://kjk.com/2026/02/02/tiktok-shops-first-major-review-war-new-legal-considerations-for-brands-and-influencers/",
      "source_title": "KJK, TikTok Shop's First Major Review War?, February 2, 2026",
      "scope": "Creator content"
    },
    {
      "id": "2025-12-19-fda-agebox",
      "date": "2025-12-19",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Agebox Inc.",
      "category": "Supplements",
      "platforms": [
        "Facebook"
      ],
      "summary": "FDA issued a warning letter stating that iKids-Growth products marketed as dietary supplements were unapproved drugs, citing September 2024 Facebook posts claiming the products enhance IGF-1 levels and increase children's height. FDA lab analysis also found an undeclared unapproved ingredient.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/agebox-inc-718252-12192025",
      "source_title": "FDA warning letter, Agebox Inc., December 19, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-09-17-lawsuit-revolve-arbitration",
      "date": "2025-09-17",
      "actor": "Private plaintiff",
      "action_type": "Court ruling",
      "company": "Revolve Group, Inc.",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "In Negreanu v. Revolve Group, Inc. (2:25-cv-03186, C.D. Cal.), the court compelled the plaintiff's undisclosed-influencer-advertising claims to individual arbitration and struck the class allegations. The case did not reach the merits.",
      "source_url": "https://www.thefashionlaw.com/revolve-nabs-win-as-court-sends-undisclosed-influencer-ad-case-to-arbitration/",
      "source_title": "The Fashion Law, Court Sends Revolve Influencer Ad Lawsuit to Arbitration, September 23, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2025-09-16-fda-stellalife",
      "date": "2025-09-16",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Stellalife, Inc.",
      "category": "OTC health",
      "platforms": [
        "Facebook",
        "Instagram",
        "YouTube"
      ],
      "summary": "FDA issued a warning letter stating that homeopathic oral care gels and rinses were unapproved new drugs, citing claims on the company's Facebook, Instagram, and YouTube accounts, including a Facebook post about recovering faster from dental surgery.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/stellalife-inc-712804-09162025",
      "source_title": "FDA warning letter, Stellalife, Inc., September 16, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-09-lawsuit-alo-settled",
      "date": "2025-09",
      "actor": "Private plaintiff",
      "action_type": "Settlement",
      "company": "Color Image Apparel, Inc. dba Alo Yoga",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "The Alo Yoga influencer-disclosure class action (Sulici v. Color Image Apparel, N.D. Ill.) was resolved through a settlement before the court reached the merits. Terms were not reported.",
      "source_url": "https://www.thefashionlaw.com/gymshark-pulled-into-growing-influencer-marketing-litigation-wave/",
      "source_title": "The Fashion Law, Gymshark Pulled into Growing Influencer Marketing Litigation Wave, June 2026",
      "scope": "Creator content"
    },
    {
      "id": "2025-08-06-fda-supergoop",
      "date": "2025-08-06",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Supergoop!",
      "category": "Beauty",
      "platforms": [
        "Instagram",
        "Facebook"
      ],
      "summary": "FDA issued a warning letter stating that Supergoop! PLAY SPF 50 Body Mousse was an unapproved and misbranded OTC sunscreen drug because the mousse dosage form is not covered by an authorized sunscreen order, citing the company website and its Instagram and Facebook pages.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/supergoop-711018-08062025",
      "source_title": "FDA warning letter, Supergoop!, August 6, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-08-01-lawsuit-lulifama",
      "date": "2025-08-01",
      "actor": "Private plaintiff",
      "action_type": "Appeals court ruling",
      "company": "LuliFama.com LLC",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "The U.S. Court of Appeals for the Eleventh Circuit (Pop v. LuliFama.com LLC, No. 24-11048) affirmed dismissal of a proposed class action against Luli Fama swimwear and several Instagram influencers alleging undisclosed paid endorsements, holding that the complaint did not plead the alleged fraud with the particularity Rule 9(b) requires.",
      "source_url": "https://law.justia.com/cases/federal/appellate-courts/ca11/24-11048/24-11048-2025-08-01.html",
      "source_title": "Pop v. LuliFama.com LLC, 11th Cir., August 1, 2025 (Justia)",
      "scope": "Creator content"
    },
    {
      "id": "2025-07-lawsuit-celsius-ruling",
      "date": "2025-07",
      "actor": "Private plaintiff",
      "action_type": "Court ruling",
      "company": "Celsius Holdings Inc.",
      "category": "Food and beverage",
      "platforms": [
        "Instagram",
        "TikTok"
      ],
      "summary": "In the Celsius influencer-disclosure class action, the court dismissed the claims against two influencer defendants without leave to amend and dismissed the remaining claims with leave to amend. The plaintiff filed an amended complaint on July 8, 2025, again alleging undisclosed sponsorships.",
      "source_url": "https://www.thefashionlaw.com/gymshark-pulled-into-growing-influencer-marketing-litigation-wave/",
      "source_title": "The Fashion Law, Gymshark Pulled into Growing Influencer Marketing Litigation Wave, June 2026",
      "scope": "Creator content"
    },
    {
      "id": "2025-06-25-fda-hydroxie",
      "date": "2025-06-25",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Hydroxie, LLC",
      "category": "Food and beverage",
      "platforms": [
        "Instagram"
      ],
      "summary": "FDA issued a warning letter stating that 7-hydroxymitragynine tablets, strips, shots, and drink mixes were unapproved drugs and adulterated foods, citing Instagram posts from May 2025 promoting 'calm, clarity, & relief.'",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/hydroxie-llc-709661-06252025",
      "source_title": "FDA warning letter, Hydroxie, LLC, June 25, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-05-29-fda-sprout",
      "date": "2025-05-29",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Sprout Pharmaceuticals, Inc.",
      "category": "Other consumer",
      "platforms": [
        "Instagram"
      ],
      "summary": "FDA's Office of Prescription Drug Promotion issued a warning letter over an Instagram post on the personal account of Sprout's CEO (@cindypinkceo) promoting the prescription drug Addyi without any risk information and without the full approved indication. The post was on a personal account, not a company account.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/sprout-pharmaceuticals-inc-709942-05292025",
      "source_title": "FDA warning letter, Sprout Pharmaceuticals, Inc., May 29, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-05-21-ag-ct-triggered",
      "date": "2025-05-21",
      "actor": "State AG",
      "action_type": "Lawsuit filed",
      "company": "Triggered Brand",
      "category": "Other consumer",
      "platforms": [
        "Social media"
      ],
      "summary": "The Connecticut Attorney General sued Florida-based Triggered Brand under the state's unfair trade practices act, alleging it sold unauthorized GLP-1 weight-loss products without prescriptions, and stating that the company's social media marketing and website targeted consumers looking for weight-loss injections. These are allegations in a complaint.",
      "source_url": "https://portal.ct.gov/ag/press-releases/2025-press-releases/attorney-general-tong-sues-glp-1-weight-loss-drug-distributor-triggered-brand",
      "source_title": "Connecticut Attorney General press release, May 21, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-05-07-lawsuit-beach-bunny",
      "date": "2025-05-07",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Beach Bunny Swimwear, Inc.",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "A California consumer filed a proposed class action (Pop v. Beach Bunny Swimwear, Inc., C.D. Cal.) against Beach Bunny Swimwear and several influencers, alleging the influencers promoted the brand's swimwear on social media without clearly disclosing their paid partnerships. These are allegations; no finding has been made.",
      "source_url": "https://www.morganlewis.com/pubs/2025/06/influencer-marketing-class-actions-on-the-rise-common-themes-and-key-takeaways",
      "source_title": "Morgan Lewis, Influencer Marketing Class Actions on the Rise, June 16, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2025-04-14-lawsuit-revolve",
      "date": "2025-04-14",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Revolve Group, Inc.",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "A California consumer filed a proposed class action (Negreanu v. Revolve Group, Inc., 2:25-cv-03186, C.D. Cal.) against Revolve and certain influencers, alleging Revolve had influencers promote its clothing without disclosing that they were paid, which the complaint says let Revolve charge higher prices. These are allegations; the claims were later sent to arbitration.",
      "source_url": "https://www.beneschlaw.com/insight/classaction-influencer-marketing-class-actions-are-trending/",
      "source_title": "Benesch, Influencer Marketing Class Actions Are Trending, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2025-04-11-lawsuit-alo",
      "date": "2025-04-11",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Color Image Apparel, Inc. dba Alo Yoga",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "Consumers filed a proposed class action (Sulici v. Color Image Apparel dba Alo Yoga, N.D. Ill.) against Alo Yoga and 14 influencers, alleging the influencers promoted Alo activewear on Instagram without adequately disclosing that they were paid, presenting themselves as yoga practitioners rather than paid endorsers. These are allegations; the case later settled.",
      "source_url": "https://www.morganlewis.com/pubs/2025/06/influencer-marketing-class-actions-on-the-rise-common-themes-and-key-takeaways",
      "source_title": "Morgan Lewis, Influencer Marketing Class Actions on the Rise, June 16, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2025-04-07-fda-holistapet",
      "date": "2025-04-07",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Holista LLC dba HolistaPet",
      "category": "Other consumer",
      "platforms": [
        "Instagram",
        "Pinterest"
      ],
      "summary": "FDA issued a warning letter stating that CBD products for animals were unapproved new animal drugs and adulterated animal foods, citing disease claims on the company website, a May 2024 Instagram post, and Pinterest pins.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/holista-llc-dba-holistapet-699082-04072025",
      "source_title": "FDA warning letter, Holista LLC dba HolistaPet, April 7, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-04-07-fda-baileys",
      "date": "2025-04-07",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Bailey's Wellness, LLC dba Bailey's CBD",
      "category": "Other consumer",
      "platforms": [
        "Facebook",
        "Instagram"
      ],
      "summary": "FDA issued a warning letter stating that CBD products for animals and humans were unapproved drugs, citing claims on the company website and August 2024 Facebook and Instagram posts about easing hip dysplasia discomfort in dogs.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/baileys-wellness-llc-dba-baileys-cbd-701066-04072025",
      "source_title": "FDA warning letter, Bailey's Wellness, LLC dba Bailey's CBD, April 7, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-02-25-fda-tktx",
      "date": "2025-02-25",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "TKTX USA",
      "category": "OTC health",
      "platforms": [
        "Facebook",
        "Instagram"
      ],
      "summary": "FDA issued a warning letter stating that TKTX topical numbing creams were unapproved new drugs, citing the company's Facebook and Instagram accounts that directed consumers to its website to buy the products.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/tktx-usa-698435-02252025",
      "source_title": "FDA warning letter, TKTX USA, February 25, 2025",
      "scope": "Brand's own posts"
    },
    {
      "id": "2025-02-10-lawsuit-shein",
      "date": "2025-02-10",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Shein (Roadget Business Pte. Ltd.)",
      "category": "Apparel",
      "platforms": [
        "Instagram",
        "TikTok"
      ],
      "summary": "Consumers filed a proposed class action (Bengoechea v. Shein, N.D. Ill.) against Shein and seven influencers, alleging the influencers promoted Shein products while omitting or burying paid-partnership disclosures, short of the FTC's clear-and-conspicuous standard. These are allegations; no finding has been made.",
      "source_url": "https://www.morganlewis.com/pubs/2025/06/influencer-marketing-class-actions-on-the-rise-common-themes-and-key-takeaways",
      "source_title": "Morgan Lewis, Influencer Marketing Class Actions on the Rise, June 16, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2025-01-22-lawsuit-celsius",
      "date": "2025-01-22",
      "actor": "Private plaintiff",
      "action_type": "Class action filed",
      "company": "Celsius Holdings Inc.",
      "category": "Food and beverage",
      "platforms": [
        "Instagram",
        "TikTok"
      ],
      "summary": "A California consumer filed a proposed class action (Dubreu v. Celsius Holdings Inc., C.D. Cal.) against Celsius and three influencers, alleging the influencers promoted Celsius energy drinks on social media without disclosing their paid relationship with the brand. These are allegations; parts of the case were later dismissed with leave to amend.",
      "source_url": "https://www.morganlewis.com/pubs/2025/06/influencer-marketing-class-actions-on-the-rise-common-themes-and-key-takeaways",
      "source_title": "Morgan Lewis, Influencer Marketing Class Actions on the Rise, June 16, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2024-11-lawsuit-mcobeauty",
      "date": "2024-11",
      "actor": "Private plaintiff",
      "action_type": "Competitor lawsuit filed",
      "company": "MCoBeauty Pty Ltd",
      "category": "Beauty",
      "platforms": [
        "YouTube",
        "Instagram"
      ],
      "summary": "Sol de Janeiro sued MCoBeauty in the Southern District of New York (1:24-cv-08862) for trade dress infringement and false advertising, citing among other things an influencer video stating MCoBeauty's fragrance mists 'smell exactly like' Sol de Janeiro's and an Instagram 'dupe alert' post that MCoBeauty allegedly liked and commented on. These are allegations; a motion to dismiss was pending as of early 2026.",
      "source_url": "https://www.thefashionlaw.com/sol-de-janeiro-expands-lawsuit-accuses-mcobeauty-of-deliberate-dupes/",
      "source_title": "The Fashion Law, Sol de Janeiro Expands Lawsuit, Accuses MCoBeauty of Deliberate Dupes, December 1, 2025",
      "scope": "Creator content"
    },
    {
      "id": "2024-08-19-lawsuit-temu",
      "date": "2024-08-19",
      "actor": "Private plaintiff",
      "action_type": "Competitor lawsuit filed",
      "company": "PDD Holdings and Whaleco Inc. (Temu)",
      "category": "Apparel",
      "platforms": [
        "Instagram"
      ],
      "summary": "Shein's parent company sued Temu's parent in the U.S. District Court for the District of Columbia, alleging among sixteen counts that Temu directed influencers to post on Instagram that Temu's products were cheaper and better quality than Shein's. These are allegations; no ruling on the merits was reported in the source.",
      "source_url": "https://www.thefashionlaw.com/shein-accuses-temu-of-running-fraud-marketplace/",
      "source_title": "The Fashion Law, SHEIN Accuses Temu of Running a Fraud Marketplace, August 20, 2024",
      "scope": "Creator content"
    },
    {
      "id": "2024-07-25-fda-matte-beauty",
      "date": "2024-07-25",
      "actor": "FDA",
      "action_type": "Warning letter",
      "company": "Matte Beauty",
      "category": "Beauty",
      "platforms": [
        "Instagram"
      ],
      "summary": "FDA issued a warning letter stating that the company's chemical peel products were unapproved new drugs, citing claims on its website and on Instagram posts, including an August 2023 post stating that chemical peels help skin disorders like acne and rosacea.",
      "source_url": "https://www.fda.gov/inspections-compliance-enforcement-and-criminal-investigations/warning-letters/matte-beauty-679463-07252024",
      "source_title": "FDA warning letter, Matte Beauty, July 25, 2024",
      "scope": "Brand's own posts"
    },
    {
      "id": "2023-11-15-ftc-aspartame",
      "date": "2023-11-15",
      "actor": "FTC",
      "action_type": "Warning letters",
      "company": "American Beverage Association, Canadian Sugar Institute, and 12 health influencers",
      "category": "Food and beverage",
      "platforms": [
        "Instagram",
        "TikTok"
      ],
      "summary": "FTC staff sent warning letters to two trade associations and 12 registered dietitians and health influencers over Instagram and TikTok posts promoting aspartame or sugar-containing products, stating the posts failed to adequately disclose that the influencers were paid by industry, and noting civil penalties of up to $50,120 per violation for future failures.",
      "source_url": "https://www.ftc.gov/news-events/news/press-releases/2023/11/ftc-warns-two-trade-associations-dozen-influencers-about-social-media-posts-promoting-consumption",
      "source_title": "FTC press release, November 15, 2023",
      "scope": "Creator content"
    },
    {
      "id": "2023-03-03-ftc-doterra",
      "date": "2023-03-03",
      "actor": "FTC",
      "action_type": "Civil penalty",
      "company": "Three doTERRA distributors",
      "category": "Supplements",
      "platforms": [
        "Online webinars"
      ],
      "summary": "The FTC obtained proposed court orders requiring three high-level doTERRA distributors to each pay a $15,000 civil penalty over claims made in a series of 2022 online webinars that doTERRA essential oils and dietary supplements could treat, prevent, or cure COVID-19.",
      "source_url": "https://www.ftc.gov/news-events/news/press-releases/2023/03/ftc-takes-action-against-doterra-distributors-false-covid-19-health-claims",
      "source_title": "FTC press release, March 3, 2023",
      "scope": "Creator content"
    }
  ]
}