Competitive Advertising Guidelines

Through comparative advertising Responselink LLC (Company) intends to accurately compare its own services with those of competing companies. Company will run comparative advertising that complies with the current state of the law relating to that practice. That advertising may identify either directly or by implication, other direct and adjacent competing products or services (Comparative Advertisements); however, all comparative advertising claims must be research-based and factually accurate as required by law.

In its Comparative Advertisements, Company will use best efforts to ensure that each substantive claim, direct or implied, is adequately substantiated. Our advertisements will hew to the following:

1. Truthfulness and Accuracy: Comparative advertisements will be truthful and accurate with regard to each substantive claim.

2. Rigor: Comparative advertisements are to be factual and research-based and not based on anecdotes or conjecture. Company will use credible external third party sources to supply and validate facts in Comparative Advertisements where necessary and appropriate.

3. Noticeable Differences: The specific differences in the qualities or properties being compared in the Advertising will be measurable, noticeable, and specific.

4. Prices: Comparative advertisements with price comparisons will accurately, fairly, and substantially reflect the actual price differentials available and that are not likely to change during the period for which the advertisement is running.

5. Fairness: Comparative advertisements will be fair and reasonable. Advertisements will provide some benefit to consumers.

6. Timely: Comparative advertisements will be timely. Claims made in Comparative Advertisements should be checked on no less than a once every quarter basis to verify continued accuracy of claims.

7. Parity: Comparative advertisements with specific parity claims will be supported by reliable empirical or scientific evidence indicating that the product is effective and/or operates at the same level as its competitors

8. Limitation: Products should be compared on a feature-to-feature basis, particularly in cases where the claim is limited to one feature or attribute. In cases where testing is limited to one specific quality or feature, Company will not make explicit or implied claims about the overall performance of the products being compared.

9. Review: In the event a third party objects to a Comparative Advertisement, Company shall use best efforts to review the advertisements subject to the objection. In the unlikely event that the claims are not able to be substantiated, Company shall withdraw the advertisement in a timely fashion.

Revised 12/8/2014

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