Synthetic media labeled when used in marketing

FTC Act §5 and the FTC's AI Impersonation Rule both address synthetic media used in marketing in ways that deceive consumers about authenticity. AI-generated face images on testimonial sections falsely imply real customers exist. AI-generated product screenshots showing capabilities the product does not have are fabricated product demonstrations. AI voice-overs or synthetic video presenters implied to be real employees misrepresent who is behind the product. Each of these constitutes a deceptive material claim about a different aspect of the product's legitimacy and capability.

Replace AI-generated faces on testimonials with real user photos or abstract avatars, and ensure product demo videos reflect actual product behavior.

// Use real photos or labeled illustrations — not AI-generated faces
function TestimonialAvatar({
  src, isReal, customerName
}: AvatarProps) {
  return (
    <div className="relative">
      <img
        src={src}
        alt={isReal ? customerName : 'Illustration'}
        className="w-10 h-10 rounded-full"
      />
      {!isReal && (
        <span className="sr-only">
          Illustrative image — not a real customer photo
        </span>
      )}
    </div>
  )
}

Practical alternatives that avoid disclosure friction: initials-based avatars (no deception possible), genuine customer photos with permission, or abstract geometric avatars. For product demos: record the actual product — AI-generated or staged demos showing non-existent features are fabricated product claims under FTC Act §5, regardless of how photorealistic they look.

• ID: ftc-consumer-protection.ai-decisions.synthetic-content-labeled

• Severity: info

• What to look for: Count all relevant instances and enumerate each. Look for AI-generated images, AI-generated videos, AI voice-overs, or deepfake-adjacent content in marketing materials that are part of the application's content or landing pages. Check: (1) hero images or product screenshots generated by AI image tools (Midjourney, DALL-E, Stable Diffusion) presented as real product screenshots or authentic user experiences; (2) AI-generated "customer" profile photos on testimonial sections (stock photo services that include AI-generated faces, or tools like ThisPersonDoesNotExist); (3) demo videos with AI voice-overs or AI-generated presenters presented as real employees; (4) AI-generated product demo videos that show capabilities the product does not actually have. The FTC's emerging standards on synthetic media align with state-level deepfake laws and the general deception standard.

• Pass criteria: AI-generated images used in marketing are either clearly distinguishable as illustrations/creative content, or are labeled as AI-generated when they could be mistaken for real people, real screenshots, or authentic user experiences. Testimonial profile photos are either real user photos or clearly labeled as illustrative. Product screenshots are actual screenshots, not AI-generated representations of what the product might look like.

• Fail criteria: AI-generated human faces on testimonials are presented as real customers without disclosure. AI-generated product screenshots present capabilities the product does not have. AI-generated or synthetic voices are used in demo videos presented as real employee or customer recordings without disclosure.

• Skip (N/A) when: The application uses no AI-generated images, synthetic media, or AI-generated visual content in any consumer-facing marketing material.

• Detail on fail: Example: "Testimonial section uses AI-generated face images (detected via facial recognition patterns consistent with GAN-generated faces) attributed to named customers." or "Product demo video shows a feature workflow that does not exist in the current product — video appears to be AI-generated or staged with a future feature." or "Hero section background uses AI-generated photography showing 'users' of the product; no disclosure of AI-generated imagery."

• Remediation: Label synthetic media and replace deceptive uses:

  // Testimonial — use real photos or clearly labeled illustrations
  function TestimonialAvatar({
    src, isReal, customerName
  }: AvatarProps) {
    return (
      <div className="relative">
        <img
          src={src}
          alt={isReal ? customerName : 'Illustration'}
          className="w-10 h-10 rounded-full"
        />
        {/* If not a real photo, label it */}
        {!isReal && (
          <span className="sr-only">Illustrative image, not a real photo</span>
        )}
      </div>
    )
  }
  

  The cleaner fix: use real customer photos (with permission) or use abstract avatars/initials rather than AI-generated faces. For product demos: record the actual product. For hero images: stock photography or genuine product imagery is preferable to AI-generated human figures presented as real users.