I’m curious to understand exactly how the FTC plans to enforce this and what exactly is the motivation behind it — while I generally like to think that I am into more ethical, authentic concepts of marketing, I’m a bit baffled by this.

For the sake of full disclosure here, revealing my own potential defensive bias, my ‘day job’ is online marketing + PR, mostly in music, but also with a number of film/tv/entertainment/fashion clients. But my background has mostly been in the music industry, and mostly on a ‘grassroots’ level — I’ve always worked with street teams, fans, bloggers, and small or local publications.  My job, essentially, is giving free shit to people, who proceed to either tell me they hate it, or tell me they like it and then write about it.  A “good” publicist knows his/her “targets” and knows how to set up a talented artist (or a good product) with an outlet who will care; I think it’s fair to say that most people would not find this “morally offensive” and admit that marketing/PR is a necessary part of ANY industry.  And in writing this, we’ll factor in that my “identity” in the “digital” realm is two-faceted: I consider myself on both ends of the spectrum (marketing and media, no matter how small-fish I may be in both ponds) discussed here.

So to what extent are the review copies of CDs I send, or the promotional vinyls, or the concert tickets, objectionable, or “freebies” that need to be disclosed?  How does this work, and above all, why is it only bloggers? Why don’t you see “a publicist may have sent this CD to us” as a footnote on the pages of Rolling Stone’s reviews?  When I have leftover ‘promotional swag’ in  my office or leftover concert tickets and I send them to a writer or friend as a favor or to say thanks or just because I know they really like the band, is this ‘bribery’ and ‘corruption’ which needs to be ‘disclosed?’  Why are we comparing this to radio  payola instead of discussing the complexities of the overlaps between advertising/marketing/PR in the digital realm?

What about links to streams of music? What about a .zip file of MP3s that could be purchased elsewhere? Is a digital download “worth” the same as a “promo” CD, and is a burned “promo” CD or a watermark the same as a plain consumer copy of the CD slotted for promotional use?  Do list spots to an already free concert count as schwag that needs to be disclosed? Do “my” bloggers now need to write “Meg hooked me up!!!” in every post, and do I need to mention if a friend is a publicist or in a band whose video I post here? What about when I write about an artist I represent but also am a fan of?  When I invite a writer to a concert or showcase with an open bar, do they need to mention that the alcohol and the party and quite possibly their personal friendship with me, my colleagues, or even the band factored in, or disclaim the photos of us tagged on Facebook holding the branded items my company procured for the party photos? Are we honestly expected to footnote every post with “a press release and PR and possibly a digital download of an album were involved in the creation of this post?”  What about digital download copies of software for review by tech outlets?

We’re not talking about blatantly pathetic celebrity endorsements of gross or harmful products here, where I think we can all agree some transparency is great.  What I want to know is more complex: When you read CD reviews in a magazine, do you feel the review is ‘less authentic’ because you know a publicist sent the CD to the writer?  Do you find fashion spreads ‘suspicious’ because you know the designer’s PR flacks sent the pieces to the magazine?  When you read a fashion blog and the writer mentions that their friend at Rodarte hooked them up with those leggings, do you think that makes the ‘cooler’ or ‘less authentic’?  Should celebs on the red carpet pin “Vera Wang let me borrow this dress so you’d photograph me in it” to their clothes? When you read an interview with a celebrity in a magazine, do you feel that it is less ‘authentic’ because a publicist coordinated it? If so, does that make the celebrity’s ‘time’ and ‘image’ a commodity which the magazine should disclose they were given as a promotional item?  What about fashion magazines tending to write about their advertisers because of internal politics and paranoia, or, even more confusing, because of their friendships and real personal relationships with ad account execs and publicists? (We’re all real people, and some of us are fun to hang out with too! Woah!)

These things aren’t new issues to blogs — once again, it’s just a new level of transparency created by the internet, and in this case, the criticism seems to be strangely disregarding that “conventional” media is widely regarded as “more corrupt.” It also raises another point, one PSFK recently addressed in reference to Monocle with their editorial media as creative agency/advertising concept — which in turn goes along with recent discussions about the inefficacy of advertising as compared to  editorial/journalistic endorsement/”word of mouth” marketing (which is of course uber-difficult to quantify and even harder to connect to profit in a linear way.)  So all this makes it nearly impossible to differentiate between “authentic” and “sponsored” journalism.  (I’d generally like to give the reader the benefit of the doubt and assume they’re bright enough to know when they’re being “brainwashed,” as generally the media outlets that thrive are the ones with a strong sense of self/brand, and not those who cater to every corporate whim.)

But at the end of the day, is the public disclosure of the existence of my job — digital, grassroots marketing focused on blogger + fan outreach — and my industry really that horrifying? I’ve gotten into arguments with people over this since they percieve blogs as “authentic” and “personal,” rather than as “media outlets” which are inherently “corrupt” — as if these things don’t ever overlap, and as if a media outlet doesn’t have a personal spin, or as if the existence of a publicist denies a blogger any and all creative agency?  It seems like such a futile argument of ethics defending the “authenticity” of “independence,” two things which can’t even be clearly defined here.

This, in turn, brings into light the whole question of where do we draw the line between “personal” blogs and “media publications.”  We all (and I include myself and possibly my own idealised “personal blog” in that “we”) have this romanticized vision of  the ever-so-authentic PERSONAL BLOG, totally free of bias and absolutely isolated from consumerism, immune to marketing and untainted by corporate PR.  But in reality, this is patently untrue — and essentially the FTC is just asking us (well, threatening us) to own up to what we are: the ever-so-untrustworthy less-than-divine prone-to-human-bias media, who may or may not be influenced (directly or indirectly) by the forces of corporate marketing.