PepsiCo has long been my poster child for food corporations whose actions speak louder than words when to comes to responsible marketing. CEO Indra Nooyi loves to tout the company's "Performance with Purpose" and show off the company's "good-for-you" foods that it gets to define. Most don't realize that PepsiCo is the nation's largest food company, with five divisions spanning from soda to salty snacks to breakfast cereals. With annual revenues of $60 billion and 285,000 employees, PepsiCo is an multinational corporate behemoth.
Now the company's true colors are revealed in all their twisted marketing glory. A legal complaint filed today with the Federal Trade Commission by the Center for Digital Democracy and several other groups called upon the agency to investigate PepsiCo and its subsidiary Frito- Lay for “engaging in deceptive and unfair digital marketing practices" in violation of federal law.
Even if you thought you already knew that teenagers were being targeted online by junk food brands, I can guarantee that the marketing strategies revealed in this complaint and accompanying report will freak you out, either as a parent or just a human being.
Among the clever techniques PepsiCo has deployed are horror video games called Hotel 626 and its even scarier successor, Asylum 626, which, the company's ad agency (Goodby, Silverstein & Partners) explained, were designed to “scare the crap out of teenagers,” in the hopes of selling more Doritos.
The websites for these games were only available from 6pm to 6am (626 - get it?) because the agency explains: "We wanted people to visit the site at night, after hours, when guards are down and they are the most immersed in what could happen."
The purpose, according to the complaint, is to engage youth in a multi-dimensional, interactive environment, using a variety of under-the- radar techniques, each with increasing levels of creepiness. Teens registering on the site are asked to provide name, email, and date of birth, and to enable their webcam and microphone.
Then the game encourages teens to post and share photos of themselves as they participate; prompts them to “send a scare” to friends in their social networks and even required them to use their webcams, microphones, and mobile phones to “escape” the nightmarish experience.
These techniques are not just gross, they also happen to violate the law. As the press release explains, by "disguising its marketing efforts as entertaining video games," it's more difficult for teens to recognize such content as advertising (which of course is the whole idea). Also, PepsiCo claims "to protect teen privacy while collecting a wide range of personal information, without meaningful notice and consent."
As I was writing this (at 11pm) I decided to visit Asylum 626 myself. The music is the sound of a heartbeat, which I have to admit is already scary. The first screen warns the site is for "mature audiences only" and those "under age 18 must not view without an adult guardian" -- what a great marketing device for teens. The next screen helpfully explains that the experience is best viewed with my lights out and headphones on. Then, after showing off the brand with, "Doritos Presents," the site suggests that I log into Facebook or Twitter for the "full treatment experience." OK, now my heart is pounding along with the music and all I want to do is close the page. I can't even enter the damn thing I am so scared.
Obviously, this site is not intended for me. But by all accounts this campaign is a raging success with its target market, with the site getting millions of visitors. As noted by the ad agency: "The campaign was immensely successful. The two resurrected flavors sold out within three weeks." Bringing Doritos brands "back from from the dead" was the goal of the game. Nice marketing strategy: Scare kids, revive profits.
Jeff Chester, executive director of the Center for Digital Democracy and long-time expert in digital marketing explains the problem: “PepsiCo has used an arsenal of powerful online marketing tactics in these campaigns, including interactive games with storylines designed to heighten arousal and instill fear and anxiety in teens."
As if teens don't have enough fears and anxiety as it is. “PepsiCo’s covert ad campaigns take advantage of teens’ vulnerabilities and encourage them to buy and consume a product that is harmful to their health,” added Angela Campbell, director of Georgetown Law’s Institute for Public Representation, which drafted the complaint. She urged the FTC to begin its own investigation and act to prevent similarly deceptive advertising campaigns in the future.
Given the Obama Administration's reluctance to take on the food industry and its reliance instead on voluntary self-regulation, severe action doesn't seem too likely. Ironically, the feds recently announced it was backing off the idea to include teens in its own food marketing guidelines. Bad timing. Because if this case doesn't convince government regulators to protect our kids from predatory marketing, nothing will.
Kudos to the groups bringing PepsiCo's disgusting marketing tactics to light. I highly recommend reading the documents they worked so hard on and watching the videos, if you can stomach it. (The most revealing details are in the complaint appendixes.) They should should be required reading / viewing for anyone who says we don't need government oversight, that self-regulation is working just fine, and we can leave it all up to parents.