Gary Ruskin writes: "Put simply, TV networks and stations are shifting advertising from commerical breaks to programming itself. They are inserting branded products directly into programs, in exchange for substantial fees or other consideration. This advertising technique, called “product placement,” has become closely integrated into program plots, to the point that the line between programming and “infomercials” has become increasingly blurred. Some commentators see no line at all.

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The interweaving of advertising and programming has become so routine that television networks now are selling to advertisers a measure of control over aspects of their programming. Some programs are so packed with product placements that they are approaching the appearance of infomercials. The head of a company that obtained repeated product placements actually called one such program “a great infomercial.” Yet these programs typically lack the disclosure required of infomercials to uphold honesty and fair dealing.

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American children are suffering from an epidemic of marketing-related diseases, including obesity, type 2 diabetes and alcoholism, while millions will eventually die from smokingrelated illnesses. Gambling is a serious problem for millions of young people as well.

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This is an affront to basic honesty. We urge the Commission to investigate current TV advertising practices regarding product placement and other embedded ads, and to take the steps necessary to restore some honesty and fair dealing to the presentation of these ads, by requiring concurrent disclosure that the ads are, in fact, ads. required of infomercials5 to uphold honesty and fair dealing.