The Electronic Retailing Self-Regulation Program (ERSP) has
recommended that Coffee Shop Millionaire Education, Inc. modify or discontinue
certain claims for the company’s “Coffee Shop Millionaire,” a lead-generation affiliate
marketing business.
ERSP is an investigative unit of the advertising industry’s
system of self-regulation and is administered by the Council of Better Business
Bureaus. The marketer’s advertising came to the attention of ERSP pursuant to
its ongoing monitoring program.
ERSP reviewed online advertising for
the Coffee Shop Millionaire system and identified several claims for review,
including:
- "How a Flip-Flop Wearing Bum At A Coffee Shop Drives Luxury Sports Cars & Rakes In As Much As $3,846,373 A Year"
- "You don’t need ANY technical experience.”
- "You need to act fast or you will miss out. And if you decide to come back later? You’ll probably be too late.”
- "Anthony…I can’t thank you enough for the $21k cash machine. I made more with your system in a matter of weeks than I had made in my entire previous 18 months online. Plus I continue to make money every week like clockwork when I mail the list I build using the system.”
The marketer explained that consumers gain
access to the information by purchasing a subscription to the service at
coffeeshopmillionaire.com for a one-time fee. Once a member, subscribers have
access to a variety of information and resources and are provided fully-developed
products and corresponding rights to resell them. Products include, but are not
limited to: “The Bible of Bodybuilding,” “The Most Important Guide on Dieting
and Nutrition in the 21st Century,” and “Sleeping Sanctuary: Salvation for the
Sleep Deprived."
The advertising at issue featured a
disclaimer that stated in part: “Any reference to, or income examples from, my
businesses and/or the examples of others are exceptional results, which do not
apply to the average person and are not intended to represent or guarantee that
anyone will achieve the same or similar results.”
ERSP recommended that the marketer
discontinue use of the disclaimer in conjunction with testimonials and earnings
claims that indicate consumers can make large sums of money quickly and easily.
Further, ERSP recommended the marketer the amount of money that consumers can generally expect to earn based upon
reliable program usage data it has received from consumers.
Given
the absence of evidence in the record, ERSP recommended the marketer discontinue claims that indicate users of
the system can earn money quickly, easily, and with little or no
computer skills.
ERSP was additionally concerned with the lack of disclosure
language to explain to potential customers that technical skills (i.e., how to
build a website using HTML or how to host it) are not necessary because those
are types of services that outside vendors may perform. While ERSP understands
the marketer’s position that the techniques conveyed in Coffee Shop Millionaire
assist users in identifying vendors who can perform the services that require
technical expertise, ERSP nevertheless recommended that the marketer add clear
and conspicuous disclosure language to more accurately convey these details to
customers.
Finally, ERSP recognized the marketer’s voluntary removal of
claims that formed the basis of this inquiry, such as:
- “How a Flip-Flop Wearing Bum At A Coffee Shop Drives Luxury Sports Cars & Rakes In As Much As $3,846,373 A Year!”
- “People are making anywhere from a couple hundred dollars a day, to as much as $10,000 a day from their laptops, iPads and even cellphones.”
The company, in its marketer’s statement, said that it is in
the process of modifying its advertising to addresses the ERSP’s concerns.
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