Companies Must Manage Lead Generators Responsibly

Law360 (September 25, 2019, 4:44 PM EDT) -- Successful manufacturers make supply chain management a top priority — asking questions about the source of raw materials they buy, building product specs into their contracts, reserving audit rights, exercising oversight authority, and insisting that vendors hold subcontractors to the same high standards. Recent law enforcement actions involving the lead generation industry show that advertisers should consider similar standards when the raw materials they buy are consumer leads.

The Federal Trade Commission’s settlement with Career Education Corporation[1] is the latest in a series of cases that pull back the curtain on the arcane world of lead generation. The complaint alleges that...

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