[cribbles]

Would such a thing be legal, per FTC guidelines on social media endorsement? (Let's set aside whether Netflix is "really doing this" for a moment.)

The FTC's Sponsorship Identification Rule requires influencers and marketers to "clearly and conspicuously disclose their relationship to brands when promoting or endorsing products through social media."[1] This is the reason you see hashtags like #ad on promoted posts from celebrities. Violations of this rule "can result in penalties far larger than any imposed to date by the FTC."[2]

I'd think that creating phony, low-follower accounts _en masse_ to promote a product would not circumvent the rule, simply because these accounts don't belong to "influencers." But I don't know. Can anyone with a better legal grasp on this chime in?

[1] https://www.ftc.gov/news-events/press-releases/2017/04/ftc-s...

[2] https://www.allaboutadvertisinglaw.com/2018/01/fcc-revives-i...