0:30 Hi. Thank you very much for joining us. We're here to talk about the very recent FTC proposed ruling. And to discuss that, I have assembled a panel of experts here at Bazaarvoice. 0:42 This is session one of a series of others where we would draw that additional details about this regulation as well. And I'm honored to be serving as your moderator for the session today. 0:54 We've actually been recent receiving some questions, and we just thought that maybe we will start off with some of these. So the question is, What is the FTC actually proposing specifically on the topic of fake reviews? 1:09 There is this term about review hijacking and product reformulation in association with that. What is that? And what they entail? 1:18 And what they may or may not apply to you and your role and your company. And what are some of the common practices brands used to make sure to mitigate and as well as to avoid exposure. 1:31 There is one more question that among us and among some of our customers also talk about who in the company, and in your business is really responsible and accountable for this. 1:42 So, with that, I have, wanted to first welcome my, esteemed, panelists here. And I was beginning with Gracie Renberger, who is our general counsel, as well as compliance officer here at Bazaarvoice. 1:56 And she spends a great deal of time advising not only Bazaarvoice, but also other regulatory, regular organizations as well as the brands and clients and the like. 2:08 Next is Abi. Abi Shuman is actually our senior director of content management service. And on that day in and day out, she advises and guide both Bazaarvoice as well as our communities of customers and brands and retailers and the likes on how we ensure it to be that we have the right content, right elements, and most importantly being authentic. 2:33 Alex Roselli, who is our global brand, director of partnerships, And truly, Alex, you spend years and days and nights spending on the ground with customers and with our clients, and we felt really, I felt really awesome to have you bring a very, very practical for that matter, all three of you. So, I just thought that to set this stage before we have our conversation, if I may just ask each of you to spend just a few minutes on your perspective and specifically your expertise in the area. So, Gracie, I'm gonna have you start. Alright. Hello. 3:08 I'm Gracie Renberger. And, as Zarina said, I'm the general counsel and compliance officer at Bazaarvoice, and I do spend a lot of time looking at the regulator that apply to ratings and reviews and other forms of, UGC and, social media posts and things like that. 3:27 What what I wanted to talk about with you all today is a proposed regulation that the FTC came out with a couple months ago. That, identifies and describes and details seven types of deceptive behavior relating to reviews these types of behaviors are really not new. We've known that they are deceptive and the FTC has already been taking enforcement actions against them. 3:54 But what's new is that the FTC is really putting people on notice that they intend to focus on these seven types of behaviors. And they can enforce, or impose very significant fines if someone is found to be deceptive. 4:11 What we're gonna focus on today is one of these seven rules. As Zarina said, we're gonna have a series of these webinars, so we'll talk about some of the other ones in the future. 4:19 But the one we're gonna talk about today is what she calls, or what is called review hijacking. That's when you apply reviews for one product to a substantially different product, and that can be misleading. 4:32 So what is review hijacking? And so as I said, that's when you apply a review from one product to a different product. 4:41 And it can be misleading because the reviews for one product may describe attributes and things that are important to consumers that really don't apply to the other product that that is being described. 4:54 There's a real world example, that happened not long ago where the FTC did bring an enforcement action against a supplement maker. 5:03 The supplement maker was using what's called variation relationships where you can, if if the product is just a variation of one, like size or count, something like that, you can actually share reviews between the two products in that circumstance, but you're not supposed to do it if the products are substantially different. 5:25 And what's substantially different is not always clear. We'll later in the webinar give you some examples to try to help clarify this. 5:34 But it's it's not always clear when something is substantially different. It's sort of a continuum. One one area where this can come up is in product reformulation. 5:44 So you have an existing product. It's got reviews. Maybe it's a best seller. And then you're gonna tweak it a bit. You're gonna change the formulation a little bit. Can you reuse those same re reviews that you had for the previous version of the product. Is that okay? Well, if it's, quote, substantial if the new product is quote substantially different, then it's not okay. And again, what is substantially different is not always clear. 6:12 We'll have to give you some examples and try to help make some clarity around that. To do that, and care continue the conversation, I think it would be good to turn it over to our, Abi Schuman, who actually has all the experience in operationalizing these rules. So I, as the lawyer say, This is what the rule says, and Abby says, okay, let me apply it. And that's really her area of expertise, so we'll turn it over to her. Thanks, Gracie. 6:38 So as I mentioned, I'm Abi Schuman. I've been at Bazaarvoice fifteen years working in content services, which includes moderation authenticity. I also helped author ISO 20488, which is a, world standard on the moderation and collection of content. 6:53 And so I'm gonna talk to you a little bit about, like, what are the real things that stick out for me? We're gonna go through some specific examples, but there's a couple of high level things that I try to guide clients on when I advise them on how to think practically about this. 7:07 So the first thing is perception and reality are both important. What do I mean by this? When you're trying to consider whether or not a product has changed enough, it's not just about if the FTC thinks it's changed enough. 7:19 It's also about what your consumers are going think. So, an example I have is there's a certain lipstick that I use, and it has this long cap. And so when you put it on the back, it looks like a paper. 7:29 Right? If they go in and they change that cap. The product itself is no different. The way it looks on me is no different. The formulation is no different. 7:37 But it might be that if you start to see old reviews where somebody has a picture with the other cap and I'm a new a new buyer, I may start to ask, is that real? 7:46 Are these the same thing? There are ways to get around this. It doesn't mean you always have to get new reviews, but it's important to consider not just what is real, but also what consumers might believe. Right? 7:55 They don't know your product like, like you do. You may have long term buyers. You may have a brand new buyer. The other thing I'll say is when it comes to making these decisions around product formulation, we formulation. 8:08 I think the bar is much higher when it comes to products that you ingest or use topically. Right? And so if you think about it, Zarina, Gracie, Alex, everybody, like, the impact that ingesting something a small product change could have is very different than changing something in your sheets or your television or your washer and dryer. Right? 8:27 And so in those cases where you're really not sure, probably best to proceed with caution. And then the last kind of guidepost that I give clients when they're trying to decide if a reformulation is like too much or too little, in terms of getting new reviews is How would your repeat customers or brand advocates respond? Right. A lot of us, like, I shop on subscription. There are certain products. 8:48 I buy the same thing all the time. They come every few months. Would I notice there's a difference? Would my feeling about this product change? Good or bad? If so, it may be time to get some new reviews. 8:58 So I know we've talked a little bit about review hijacking and we thought it might be good to go through a couple of practical examples of product reformulation. To think a little bit about how this might look. 9:10 There is gray area here. I think we can all call that out. Right? There is not These attributes always matter. These attributes never matter. Right? It is very dependent on a product. 9:20 So this is the first example. A brand's best selling Ibon has relaunched with the same formula, but in a more user friendly format. The product now has an angled tip As opposed to a flat tip, it offers a smoother guide guide for easier use and the packaging is made of post consumer recyclable materials. 9:37 So would we consider this product reformulation or not? My sentiment is I think it would be okay to maintain the reviews for this product. 9:46 They're not substantially changing. Like, if I'm somebody using it to, you know, decrease my my eye bags, probably gonna have the same experience. This is one of those places though. 9:55 You might wanna be cautious of perception. And so there are ways where you can respond to reviews publicly. There's a way on your product page that you can sort of denote that you're changing from one thing to the next. 10:05 So somebody who's not a repeat buyer and is seeing this for the first time can understand the difference between those older views and new reviews. But I don't know. Gracie, Alex, other thoughts here? 10:14 What would you guys guide clients on? Like you said, it depends on what's important to the So if you absolutely love the fact that it's flat and you you like the way it goes on flat, you're gonna wanna know, that they've changed, and now it's got the angled tip. 10:34 So it really just depends on an individual consumer. Exactly. And, Gracie, you've touched on it. I think part of it is the communication with the consumer. 10:43 They need to know what's being changed and why they're changing it. Completely agree with the both of you on that. And we're based. If I may jump in as well too. Right? 10:52 So at SCMOS, Brand Shepherd, that if there is a distinctive consumer desirable feature, it's always good to have whether it's you keep the existing one, but also at additional say, well, I really, really like this land. You know, some people might, and some people may not, but just just thinking that I like how you this is, you know, plus, you know, asking us to think about this, Abby. Thanks. Yep. 11:15 And you could choose to get new reviews. You could also choose to think about how you kind of publicly handle product page and address it in that manner. So if we wanna jump to the next example, so a thirty year consumer favorite product is now available in vegan formula, a new pump and more shades for better color matching. 11:33 Is this reformulation or not? This is a place where I would advise a brand to probably expire their old content and get new content. Right? To my point, when you're putting it on your skin, right, you think about A lot of us spend a lot of time trying to have our nice, lovely, clear skin. Right? 11:47 Those changes you made to make it a vegan formula, it may change the way someone's skin reacts to that product. And so I think it's a fair thing to say it is, you know, they may have the exact same experience. They may not. 12:00 And so this is a place where I would probably advise that they start to to gain fresh content. Yeah. So, I'm gonna sound out as a consumer. I totally agree. 12:10 Again, not in my work profile. This is just Serena as a shopper. If I really see that you've changed the formula, you know, whatever vegan may or may not entail, I I would like to know differently. Yeah. 12:24 One second, I think you've really hit something on the head where you said as a consumer. That's what I advocate for our clients. Stop thinking like the person who owns the brand, right, and ask yourself if you were the person shopping for this product, how would you feel? Right? 12:38 So I think that's a great callout. So I think we've got one more. So a well known diaper brand now offers thirty diapers in a box with a leaner design of the box. As opposed to previously, it was twenty five diapers, were offered in the box. 12:52 Is this reformulation? So assuming the diapers themselves are the exact same diaper, No. Right? This is a case where when you're actually using the product, right, and you're putting it on your baby, that experience is going to be the exact same. 13:06 And so this is a place where I think it would be totally fine to continue to use the reviews that you have. We see this commonly with patient, right, where you share reviews from something that has fifty or a hundred, because that end user experience really is the same. 13:20 Yeah. Grace and Alec's thoughts. Yeah. Yeah. If I could break in, and in fact, this is an example of where it's clear under the FTC rules that just differences in the number of counts, or size generally, like if it's a piece of clothing and it comes in small, medium, and large, or if it's, like, this example account where you could have a they could sell a package of twenty or a package of fifty. You know, then as long as the internal product is the same, then it's not gonna matter. 13:50 And the FTC is clear on that. It's just so there are examples where it's really clear. There are examples where it's And I think you're understanding that. And Abby's point about being empathetic to your consumers is the key. 14:02 Even if the FTC says, oh, no. That would be okay. If your consumers are gonna react, negatively, you you that's that's important. 14:11 You wanna make sure that you're anticipating their reactions and their needs. Yep. So with that, I've talked to you a little bit about how we kind of have these high level conversations. 14:21 I wanna pass over to Alex who Works with our clients day in and day out to think about their digital shelves, think about how do they get content on-site and talk to us a little bit about how does she help advise clients to move you know, once they thought through these things, how do you move on and make decisions about what to do going forward? So, Alex, Wendy, you know, talk to us a little bit about that? My name is Alex Rosselli. 14:39 I am global brand partnerships director here at Bazaarvoice. I've been with the company for over eight years focusing on food and CPG. That's really my specialty. 14:49 I work with clients day in on day out to support their launches, to support their products, how they come to market, provide recommendations, strategize, and work with them. 15:00 As a part of the role, what I've mentioned, really, if we think about kind of transformations, reformulations, however you wanna call them. 15:10 Not every brand has them. To to be completely clear, not every Ram will have reformulation. Some brands actually decide to just sunset the product and start fresh. 15:20 For those brands that do have reformulations, they typically happen every few years. So this isn't a short and easy process for the brands. 15:28 What happens during this time is that the brands are collecting consumer feedback through reviews, social social content, focus groups, insights, and beyond. 15:37 Once they've gathered all of the information to provide the consumer with the best information moving forward, they'll actually, work with their research and development teams, internal teams to develop the product, which can take quite some time. 15:51 In terms of kind of what that impact looks like, depending on the volume of SKUs that are affected or even if that one SKU is that brand's hero SKU, it can be quite significant. 16:03 When we think about from a digital standpoint on the other end, when we look at our data, if a product in the health and beauty space has five hundred reviews on that SKU. If that if those reviews are then taken away, What happens is when we go from five hundred to zero, you risk your conversion rate decreasing by nearly forty percent on average. 16:26 So I would recommend not letting that happen to kind of appease your digital shelf to make your consumers and buyers happy. But really the main point about all of this is no kind of what it what's in it, what the issues with the concerns may be communicate that to your consumers to be your loyal clients and consumers from here on out. 16:49 El, Alice, you just said something that does trigger thought in my mind is that when we would talk when you're talking about, if if you used to have five hundred and now all of a sudden, the all of a sudden triggered by the fact that you a newly reformulated product as an example, but the fact that this deal is askew, that that almost triggered to me that, you know, if I have a new product, I would have to have the same kind of consideration as well too. Right? Because we do know the volume piece, the the quality, and and all that can you wanna come in a little bit on that? 17:19 Exactly. And so while this information may be new regarding the FTC's review hijack making maybe new to some consumers versus, others that may be something that they were aware of prior to this. For those who may not know, they may have been able to plan for this according re lead through budgets, communications, and and beyond. 17:39 And so what I'll typically do is provide them with a good, better, and best option. And so the good option is typically to generate at least, you know, a hundred reviews per skew. 17:49 Need those retailer minimums, appease the retailers, and Additionally, the better option would be look at where your competitors are in terms of that review volume. 18:00 Meet that number. Alternatively, the best option is to be where you were before. So if you are a deodorant product, you had two thousand reviews get back up to that two thousand mark. 18:11 We know not all these options are feasible for everyone, so we wanna provide them with stepping stones to, meet their needs as soon as possible so that you don't see those different conversion rates. 18:22 Yeah. I think you're also hinting in the reality is that, you know, sometimes I get into these conversations with our clients is that the more open exchange that they share with us in terms of what may be upcoming and that will give us all a lot more leeway and a lot more capability to help each other out as well, which is great. 18:42 And you touched on a good point too as well. So It's not just about review volume. It's making sure that people are okay with the product that you've changed that you're showing them that you've made it a better experience for them. But for those, there are gonna be situations like Abby mentioned before where the consumer may not like that slanted tip versus the flat tip. 19:02 So we just wanna make sure that people are aware of those packaging changes or physical changes, internal changes, that they know that what to expect, and then if they want to repurchase that product from there on out. Yeah. 19:14 And and just as I'm hearing you and and digest, seeing both what you and Abby mentioned in terms of the examples. I know we're skewing on the CPG or the beauty or the FNB kind of material. But it I I could totally relay this to because we're working on a remodeling project. I mean, what I'm gonna use and what tools I'm gonna have and what you know, it's just kind of bring it right to home. 19:37 That that totally relays us as well too, I mean, especially. So Absolutely. It applies to everything. Awesome. So, with that, I just thought that maybe what I will do is to stop sharing of the slides and, just really maybe have us be in a conference station, if that's alright with you all. 19:57 So, I I wanted to, just kinda share we kinda touch on it and what I call a little bit of base lining. But I wanna really go back to the very beginning. Gracie, we've always been since I came on board just under two years ago, you and Abby have educated me very, very quickly in terms of there are regulations, there are compliance, and there are preferred practice and what have you. So, we have, gotten a couple of real questions from the field, from my customers. 20:26 So if you don't mind, why don't we start from there? Is that okay? Yeah. Okay. So we're we're talking about being authentic and addressing this potentially unintentional or intentional deception that to practice for fake reviews. 20:42 So the first question that came up was that, is there, you know, with this proposed ruling? Is there a deadline gotta make sure that something needs to be done. Is it like tomorrow? Is it what what is it? 20:53 Right. So, it is a proposed rule, and it won't take effect until after the comment period closes, which will be the end of this month, and then it'll take some time for the FTC to digest the comments, and then they may modify the proposed rule somewhat, but I anticipate it'll be final probably around the first of the year. That's sort of typical. It takes them a few months, but no guarantees. 21:15 We don't really know. The important thing though is, as I mentioned, these are not new. It's not new that these behaviors are considered to deceptive. 21:24 The FTC has always considered these behaviors deceptive and has brought enforcement actions against them. What's new about this proposed rule is it's just that they are emphasizing to companies out there that this is these seven behaviors are what they are going to be focusing on. This is what FTC is gonna consider an enforcement priority. And so that it's like putting you on notice that, This is what we're really gonna focus on. 21:52 We we've already focused on it somewhat, but we're really gonna focus on it now. So clean up your act. That's kind of what it means. Yeah. So so if I may, though, I'm gonna flip around the other perspective. 22:01 Right? Cause what you just articulated is that if you are a brand, if you're a retailer, if you have you own that merchandise, Again, I I'm a avid consumer. I buy things practically too often. 22:14 I would also look at that is that I wanted to make sure that somebody is actually taking charge of making sure that whatever I see and whatever I may want to express, is real. And, I mean, because we all know that. Right? 22:28 Seventy some percent of us now look at things before we go buy or shop anything else. And so we all rely on what other people say and as in my case as well, heavily. 22:39 Relating to this though, I wanted to, just brought up a question that was, commented that came up is that there are times, and we are partly in this business as well, where we actually incent generation of reviews, not to prescribe what they actually say, but intense incentivizing where there is a free sample or something along those lines in the creator and the influencer economy. 23:05 Can you all three comment a little bit of that? Is it as if What's the practice? Do I do? Do I not do? Well, I can jump in real quick from a legal perspective, but then I will quickly turn it over to the real experts so from a legal perspective, it's okay to incentivize reviews as long as what you are asking for is an honest review. 23:29 You cannot say, I will give you a free sample if you give me a good review. You can't do that. That would be a problem. And then the other thing is you have to disclose to the public, other reviewers of the the readers of the reviews that it was the review was incentivized. 23:46 That's an important thing for other consumers to know is that you, you got a free sample or a discount or something like that for this review. 23:54 But the important thing is it has to be honest, and it has to be disclosed. But otherwise, it's it's okay to incentivize reviews. Abby, Alex? Yeah. No. So I agree. And I think, you know, the disclosures are so important because realistically, as humans, you have a different opinion about something that you got for free than something that you paid for. 24:13 Right? Like, the the barrier of what makes you happier and unhappy about that product, right, is a little different when it didn't take money out of your paycheck. What we do see though is that, you know, the star rating of incentivized content versus non incentivized content, well, slightly higher is is very minimal. Right? 24:28 It's not like you're seeing a product that is normally two and a half stars, suddenly five stars. Right? We find that the consumer response in incentivized content is pretty, consistent with what you see from organic reviewers. 24:41 And I think the reason that incentivized content can be so useful is one, it helps with net new products, right, that are not in the market yet, which means if you are the new buyer and you're trying to decide whether to take a risk or not, it it it takes some of that risk out of the equation. Right? 24:56 Because I'm not buying something not knowing what people think about it. Right? And so that's really beneficial. The other pro I will say is that incentivized content tends to be more detailed than or or what we would call organic content. Right? 25:10 It's really important to us that when we work on getting content from sampling community members that we don't guide them as Graci said. This is not about saying it has to be positive or about negative. 25:21 But we do help and think about what helps consumers make decision. Right? So for example, if you're sampling grass fertilizer, like, what would help me is to know what kind of grass you have, right? Like, what temperature zone do you live in? Right? 25:34 And so You can also help make sure that those reviews are a little more well rounded in order to educate other consumers trying to make a decision. Ellie. The other thing that I would add to that too, Abby, I completely agree. And, Gracie, as well. 25:47 Thank you for providing that direction. I think it's incredibly clear. When we haven't sent device content, you can control when it's actually created. So I think that's a pretty big benefit. 25:56 So if you tell us you come to us and say I have a reformulation or transition, how happening in January, what we can do is we can actually proceed some of those reviews and make sure that we're collecting those reviews through us through any other partner as well too and make sure that there is a kind of a rolodex of reviews that we can then flip that switch on on retail come January one. 26:18 Remove the other reviews before, and you'll be good to go. So incentivize content is easier to control. Organic content is also incredibly important as choose. 26:27 So both types of the content are great for for building brand trust as well. Yeah. I I think that's an important part. Right? You're building brand trust, I mean, as as brand champion that that's a really, really, and we get into actually also the brand safety space as well too. Alex, you just said something, and Abby, that I remember either yourself or some of the colleagues here at the Starbucks also, highlighted examples whereby people use incentivized, reviews for feedback, for product improvement. 26:56 Can can either of you comment on that? Yeah. So, you know, reviews fill a lot of needs of a company. Right? And so, typically, you know, one of the big things I try to advocate to people at Bazaar Voice, right, is reviews are for consumers typically not clients. 27:12 Right? It is easy oftentimes because clients are who we're interacting with to start thinking about it from point of view as opposed to reminding ourselves, like, it is the consumer point of view. And so there is that part of it that is, like, how do we help consumers make purchasing decisions. Right? 27:26 Especially like in the current economy and things that are going on, right? People will have so many money, much money. And we wanna help them spend it in a way that's beneficial to them. That being said though, that content is really helpful to clients, in using it as a feedback loop. 27:40 These are actual shoppers that are in your actual shopper channel. Right? These are not people you're running out trying to get. They're people that want to give you their money and they are telling you things in the reviews that would help them give you more money. 27:53 Right? And so four really sophisticated, product teams that know how to kind of take and receive that content and make product decisions. And we've seen clients have good success with that. 28:02 We've seen them hear about very specific suggestions or flaws with the product interviews and think about how they use that to actually drive the product reformulation. 28:10 Right? So if you think about an example like the eye stick, If a common thing you saw is like it's doing great for my eye bags, but I don't like this shape and then they go reformulate that shape based on that feedback. 28:23 It also takes some risk out of the situation for the client, right, because they're not doing a reformulation not knowing how consumers are going to feel about it. Right? They're kind of letting them they're letting consumers lead the way. 28:33 Yeah. Yeah. I I also wanna underscore Alex what you said as well too. Right? And and I being in this practice is that it's important to have the balance of organic, as well as intense incentivize. 28:45 It it they're, you know, the same notion as we talk about the whole content supply chain and the bias in terms of do I do branded content or do I do non branded, organic content? 28:55 It's actually a combination of both of them. That that would be powerful. But in either case, has to be authentic, has to be real, and has to be true experience. On that, there was a question that came up that says, do we need to eliminate all the past reviews And other things that, you know, we think we may be in the gray area. 29:12 What what's your advice? Grace and me and I'll come to you first. Well, as we said, there is a gray area, here. And, again, even if, my my advice typically is to be conservative. 29:25 And so if you think it is something that your consumers might, consider to be deceptive, it's a if it's if the change in your reformulation is an attribute that's important to your consumers, I would be conservative. 29:39 And Abby mentioned ingestibles and things like that. It's another reason to That's where people really care because it could affect their health, things like that. So, in general, there are some areas where it's really clear change in the packaging. That's not gonna require, you know, new reviews. 29:57 But beyond that, you may wanna be conservative. Have you have any practical advice? You've seen this so many times? Yeah. 30:05 I mean, I think ultimately, You know, the FTC doesn't sit down and, like, create a laundry list of, like, here's what is and what isn't. 30:13 Right? So you're gonna have to make a choice and you know, oftentimes when I talk to people, it'd be BSA, oftentimes, you we don't know what they're thinking until they take action. Right? 30:22 They put some stuff in guidance. We do our best to dissect that. And for that, we include our clients. But then when they start taking actions, that's when it starts to clarify, like, oh, that's what's over the line. 30:32 That's what's under the line. My advice to clients is, like, you don't want to be the example. Right? You do not want to be the one, and that's not how you want to learn. So, like, until those actions start to ramp up and that clarity starts to present itself. Yeah. My advice would be similar to Gracie. Right now, again, we are more cautious human beings. 30:49 So that's like a way that we we respond in the world, but I don't think anybody wants to be that use case. Right? And we're never gonna know definitively in every situation how they feel. 30:58 So I think it's always going to be best to act conservatively. Exactly. And I will just add to that. 31:06 What I'm advising my clients currently is that they should actually be preparing. Be be cautious as Gracie and Abby mentioned as well to be conservative. 31:16 If someone has taken out an ingredient in that deodorant that they've been using for years and years on end. We wanna make sure that no one has a reaction to things like that if that product that ingredient in that product is taken out. So be conservative. 31:29 That's probably the best rule of thumb we can give you without kind of giving it going through that laundry list that unfortunately doesn't exist by the FTC. Yep. So so so now I'm gonna switch role. 31:39 I'm gonna be a client now. I'm because because I am f as our voice customer. Do is there is there some service or some audit, some advisory that you would you would do as a part of your day in and day out, Alex, and Abby. 31:53 That you could help me just do a quick scan or do whatever that you might do. Yep. I'll assume take a stop here. Sure. Yeah. 32:03 So my first step would be or my first, you know, step probably if you were my client, what I would do is I would work with you, kind of figure out exactly how many skews are impact, look at how many reviews you have, how many reviews will then be taken away once those are added up, and develop a plan. 32:19 So maybe that plan looks different for you if you're planning six months in advance versus if that relaunch or reformulation is happening tomorrow. So we'll develop a plan together, but just making sure that there is a plan in place is the most important thing depending on the time that you can get to. 32:34 If you can get to it quicker, be prepared, get those reviews ahead of time so that nothing is down to zero. So you don't see those conversion decreases potentially as well as that's a really good first step. 32:47 Okay. So so I would presume that for those of you who are listening, that if you are a bizarre voice customer, you can reach out to the account team. Is that where you would have them start? 32:56 Okay. Exactly. Reach out to your full account team, your client success director, and even your account director as well. Some here. Abby, do you have any other comments that you wanna add? No. 33:08 I think Alex is right. You know, we go through. We look at, we formulate a plan that plan's gonna be unique for every client to fit their needs. Right? And that's where, you know, you have great account teams that know what you need and can talk through your best options. 33:19 And we're always here at kind of work in a consultative manner in terms of helping them discern, right, when maybe that line has been crossed in terms of product for pre formulation. 33:28 Yeah. And and as the lawyer, let me chime in and put in a plug for lawyers. If you have legal counsel, I highly recommend that you talk to your own legal counsel. 33:37 They know you your business. They know your products. They know your risk appetite far better than we ever could. And I, you know, I've been talking about this FTC regulation and providing general information, but I honestly can't provide legal advice specifically to any other company other than bizarre voice. And so it's just, always better to talk to your own legal counsel. 33:59 They they know you better than I ever could. Yeah. That's a that's a great call. And that's usually my first response. Like, when we get asked questions, I'm like, I will give you my, you know, sort of unbiased opinion, but, like, They're, you know, you guys clients that are listening to this call, it is ultimately your risk to take or not take. Right? 34:15 And so to Gracie's point, like, your own legal teams are gonna have to make that choice. Around what their appetite is. Yeah. So so that just triggered one one thought. 34:23 Right? And and one of the earliest starting question that we were teeing out is that who's really responsible in your organization. Can you just, like, maybe maybe just collectively? Right? 34:34 Who are typically the different roles, you know, is it the brand manager? Is it the digital marketer? Is it the legal, any collective thoughts here? 34:43 All of the above. Okay. Okay. Yeah. I I guess we are we do carry the the the shield and the pride the brand. And so they're -- Yeah. -- I think Alex. 34:54 Yeah. Alex probably works more closely with the clients the folks in who enroll so she can probably apply on that better than I could. 35:03 I agree with you. But, yes, it's typically the brand teams and e commerce teams Sometimes there is only one person to do both brand and ecomm. 35:11 So just wanna be mindful of that as well. So, but, yes, it's both equally their responsibility. The brand should know when products are changing, why they're changing in that messaging and communication. 35:21 And then the e commerce team should be armed with what to do next, how to replenish their reviews and how to take those next steps. Awesome. Yeah. So we're just a few minutes left. 35:32 I I'm gonna just as two quick questions. I think the first one is that and and it seems like a a small question, but it really is a big one. 35:42 So regulation in this space is frequently updating. So what advice do you have for the audience here to just keep abreast. Right? How how do I what do I do? 35:53 On regulations, the FTC is actually very helpful and proactive in providing guidance. So I would go to the FTC dot gov they have newsletters they put out. They announce the cases. 36:06 So, for example, the supplement case I mentioned, I learned about that because it was on the FTC's website. And you can subscribe. They have a newsletter you can subscribe to. 36:15 So there's a lot of ways you can keep abreast of regulatory changes like that. And if you don't have time to do that, talk to your lawyer. Yeah. I think a very practical thing, like, Google alerts. 36:25 Right? Like, I have Google alerts set to notify, but I think even taking a step back is what what what is the federal trade commission care about? Right? 36:33 They care about the fact that we are not misleading consumers. Right? They care about the fact that what you were putting in front of consumers to help them make purchasing decisions is like valid content. 36:43 Right? It is sentiment neutral It has, you know, by real users with real experience, right, that you're making necessary disclosures. 36:52 So I think the biggest thing is just if you're we talked about this earlier on the call. If you're acting with empathy, if you're putting yourselves in your consumer shoes first, right? If you take a minute and you take off your hat as, like, an employee, a marketer, you know, a brand manager, a product manager, and you just say, how would I as a consumer feel about this situation? 37:08 And you always make choices with that in mind. Typically, you're going to be in line with the stuff that the Federal Trade Commission is doing. Right? They're not coming out with rules that seem crazy. 37:18 They're really just telling you how to make sure that you consider consumers first. And so that would be my guidance. It's like in all the scenarios, just ask yourself if I was the person doing the shopping, How would I feel about this situation and make a decision based on that? Right? 37:35 So so just a quick part here. Right? I would like to maybe as a rep here, interview, if there is like a compelling most important that one advice that you have for the audience, What would that be? 37:50 I'm gonna reverse the order here, Alex. I'm gonna start with you at this time. Yeah. So my biggest piece of advice is to be transparent your consumers. 37:59 Being transparent with any changes minimizes customer confusion, it could also even potentially limit customer service inquiries as well too. So Don't forget about that B transparent. 38:09 It's incredibly important in in continuing that brand trust. That's my biggest piece of advice. Abby? Empathy, right, put yourself in consumer shoes, make decisions based on what's helpful for them in making a purchasing decision, and it impacts your brand, you know, like that brand trust for the way that your brand is perceived. Right? 38:28 Tracy. I already said it. Talk to your lawyer. Get your own lawyer's legal advice. They know your products better than I ever could. So, talk to your lawyer. Well, if I if I may add to this as well too as Samuel and as, Brand Shepherd, I think the most most critical one is always true to your brand and always true to your authentic entity and your products and capabilities and what have you. 38:53 Your panel here has actually teed up some next steps I think you all talked about that already in terms of, you know, consult. Gracie, we got it loud and clear. 39:03 Consult with the legal counsel, and then maybe contact your, bizarre voice account team, you know, Alex just like you talk about and Abby like you talk about. 39:11 And then there are actually a few because the whole practice of being authentic, the whole practice against fake review has always been a precious topic near and dear us here at the Starbucks since day one of our information with the company. 39:25 So we have quite a number of resources on our set website, and here's one on the hijacking article as well as a blog, written by you yourself, Abby, as as co author of the very important space here as well. 39:38 There are many others, including this webinar. So if you feel that for the audience here, if you feel that this has been a very helpful, insightful or in formational. 39:47 Please do pass along the link to other colleagues in your company and other cohorts that you might be in touch with. And, just as the last, commentary, we said that this is the session one of the first one, and which is, you know, one of the thing that we felt to be have a time balance, have a sense of urgency to it that we felt that we wanted to make sure that we tee it up regarding to the hijack, the review hijacking, in thirty seconds, Grace, if I may, just ask you just, T. 40:14 O. What are the other six areas? Just give us a hint of it. Not all of them. So that there will be other topics that we will be going into. One I have strongly in my head is that machines and AI are being now generated and used to write reviews. Is that fake? Yep. 40:32 Yep. That's that's one of the big ones we'll be discussing. And yes, there is a great risk that with the new generative AI tools that are out there that it will make it a lot easier for people to, create fake reviews. And one of the behaviors that the FTC listed was not allowing, reviews that were not written by a real person. 40:55 That's one of the one of the deceptive behaviors that they're focusing on. They're also gonna focus on, not incentivizing reviews that are, positive or negative. 41:08 So we talked about that a little bit, and and there's a few other one's influencer behaviors, trying to purchase likes or follows, things like that. 41:19 There's there's there's quite a few things we'll be able to talk about. Alright. Well, so, others stay tuned, and we will be issuing other schedules as well. And, for that, I wanna to, do a justice here and, share, these are the biles as well as the connection, the LinkedIn profile of each of us. 41:38 If you are likely I mean, if you would like to reach out to any one of us, we are available. And thank you Gracy. Thank you, Alex, and thank you, Abby for being here. 41:46 This is a very critical topic, but it's also fun being, you know, from all sides, right, being the consumer, being the brand, and being others. So thank you so very much, and thank you everybody for tuning in.
