was quoted in an article about how kids shouldn’t be fair game for online celebrity pitches in FTC:Watch
on September 29, 2017.
"The FTC always refers to the reasonable consumer," Mudge said. "The reasonable consumer is not one size fits all. If the intended audience for an ad is a child, then that is the reasonable consumer. If the intended audience for an ad is an adult, then that is the reasonable consumer, and you adjust and judge your lens of what would be expected for your audience."
"If you have a child audience, you have an audience that absolutely is more impressionable, is less understanding of things like sarcasm or humor or other things, but the FTC never ignores children, and it never ignores other vulnerable audiences [such as] people for whom English is a second language," Mudge said.
"They are always taking the audience of the intended ad into account when they look at the advertisers’ obligation," Mudge noted. "The guides are equally applicable when something is child-directed as when something is adult-directed."