--- title: "FTC Mobile App Enforcement: Mobile App's Acne Treatment Claims Require 2 Clinical Studies" date: 2011-10-26T13:01:56-04:00 author: Import Bot canonical_url: "https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/ftc-mobile-app-enforcement-mobile-apps-acne-treatment-claims-require-2-clinical-studies" section: Blog Posts --- # FTC Mobile App Enforcement: Mobile App’s Acne Treatment Claims Require 2 Clinical Studies October 26, 2011 Yesterday, the Federal Trade Commission (“FTC”) approved a final [settlement](http://ftc.gov/opa/2011/09/acnecure.shtm) with marketers of the ​“Acne Pwner” and ​“AcneApp” mobile applications (“apps”). This is the first FTC settlement targeting health claims by mobile app developers/marketers, but one of several FTC mobile app enforcement actions. In the AcneApp case, the defendants claimed that their apps could treat acne with colored lights emitted from a mobile device. To support the claim, the AcneApp marketers relied on a study published by the British Journal of Dermatology, claiming that the study showed blue and red light treatments eliminated p-bacteria (a major cause of acne) and reduced skin blemishes. The FTC determined that AcneApp falsely claimed that the British Journal of Dermatology study proves that red and blue light therapy is an effective acne treatment. The FTC order prohibits Acne Pwner and AcneApp ​“from making acne-treatment claims about their mobile apps and other medical devices” without at least two adequate and well controlled human clinical studies. The requirement for two clinical studies is the same standard that the FTC applied in recent settlements with a dietary supplement manufacturer over weight loss claims for its dietary supplements, and with a food marketer over its claims that one of its products reduced the duration of acute diarrhea and reduced school absences. In another recent settlement, FTC ordered [Reebok](http://www.adlawaccess.com/2011/09/articles/advertising-1/reebok-agrees-to-pay-25-million-to-settle-charges-of-unsubstantiated-advertising-for-toning-shoes/) to provide one clinical study to substantiate fitness claims for its toning shoes. The marketers of Acne Pwner and AcneApp were also ordered to pay the FTC $1,700 and $14,294, respectively. This blog post was written by [Alysa Hutnik](https://www.kelleydrye.com/people/alysa-z-hutnik). **Tags:** [Advertising](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/tags/advertising), [Federal Trade Commission](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/tags/federal-trade-commission), [Food and Drug](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/tags/food-and-drug), [Mobile Marketing](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/tags/mobile-marketing) - Share this entry - - - - - [ View entry pdf ](https://s3.amazonaws.com/cdn.kelleydrye.com/content/uploads/pdf-snapshots/ftc-mobile-app-enforcement-mobile-apps-acne-treatment-claims-require-2-clinical-studies-20251001122319.pdf) ### Search Blog ### Subscribe ### Explore Topics - [Food and Drug](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/food-and-drug) - [Mobile Marketing](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/mobile-marketing) - [Product Labeling & Marketing](https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/product-labeling-marketing) ### Related Services - [Advertising and Marketing](https://www.kelleydrye.com/practices/advertising-and-marketing)