Sunday Riley, the maker of the cult—and extremely pricey—skincare product Good Genes, has been found by the Federal Trade Commission to have misled its customers “by posting fake reviews of the company’s products on a major retailer’s website, at the CEO’s direction, and by failing to disclose that the reviewers were company employees.”
According to the FTC, the company’s managers and even company founder Sunday Riley herself posted fake reviews of the skincare line’s products on Sephora’s website using “fake accounts created to hide their identity.” And while the FTC press release doesn’t quite say it so baldly, managers also forced, or “requested,” employees to write fake reviews as well.
Sephora became suspicious of the reviews, apparently, and removed them. But Sunday Riley then came up with a new tactic, according to the FTC:
The FTC alleges that after Sephora removed fake employee-written reviews, Sunday Riley Skincare employees suspected this was because Sephora recognized the reviews as coming from their IP addresses. Sunday Riley Skincare then allegedly obtained, according to one of the company’s managers, “an Express VPN account [to] . . . allow us to hide our IP address and location when we write reviews.” A VPN (virtual private network) lets users access the internet privately, by using separate servers to hide their online activity.
None of this is news, exactly—the company’s writing of fake reviews was uncovered in October 2018 when an alleged former employee of the company leaked an email that shows management encouraging employees to write reviews and included instructions on how to use a VPN so that reviews would not show up linked to the IP address of the company. “We were forced to write fake reviews for our products on an ongoing basis, which came direct from Sunday Riley herself and her Head of Sales,” the former employee wrote.
In its investigation, the FTC uncovered more evidence, including an email written by Riley herself in July 2016, in which she told her employees to “create three accounts on Sephora.com, registered as... different identities.”
Per the FTC:
The email included step-by-step instructions for setting up new personas and using a VPN to hide their identities, and directed employees to focus on certain products, to “[a]lways leave 5 stars” when reviewing Sunday Riley Skincare products, and to “dislike” negative reviews. “If you see a negative review – DISLIKE it,” Ms. Riley wrote, “After enough dislikes, it is removed. This directly translates into sales!!”
But in response to this misconduct, the FTC is merely proposing a settlement that would simply bar Sunday Riley from engaging in similar misconduct in the future, a relatively light slap on the wrist. Two FTC commissioners, Rohit Chopra and Rebecca Kelly Slaughter, believe the FTC is not going far enough in sanctioning the skincare company. They want the company to pay, literally.
“The proposed resolution of this matter suggests that even the narrow subset of wrongdoers who are caught and attract law enforcement scrutiny will face minimal sanctions,” they wrote, adding that they believe Sunday Riley should be fined. “It is difficult to imagine more egregious facts, yet all the Commission is imposing is an order that the company and its CEO not repeat their lawbreaking.”