For many years the Federal Trade Commission has sought to prevent deceptive advertising under Section 5 of the Federal Trade Commission Act. The FTC’s focus has encompassed not only false advertising claims, but also advertising claims that, while literally true, tend to deceive consumers. “Up to” claims fall under this scrutiny since they can be misunderstood as promising consumer benefits (e.g. “up to 50% savings”) that might not be realized by all consumers. This paper presents the results of research conducted with 600+ members of a commercial consumer panel to evaluate a variant of this type of claim, the “As Low As” claim, and to extend prior research by examining how interpretation of the claim varies with audience characteristics. Implications for advertising practitioners are discussed.



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