Deceptive Digital Marketing Claim Filed Against Pepsi


Consumer groups filed a complaint against Pepsico and Frito-Lay for online marketing to teens that included immersive games and intrusive social media.

The online marketing campaigns included video games labeled “Hotel 626”, “Asylum 626” and “Doritos Rhianna Late Night” an music experience with pop star Rhianna.


The complaint was filed by the Center for Digital Democracy, Consumer Action, Consumer Watchdog and the Praxis Project, with assistance from the Institute for Public Representation at Georgetown University.

The consumer groups allege the digital marketing is deceptive because:

1) It disguises marketing content as immersive on-line entertainment

2) Despite claims to users that their privacy is “protected”, the sites collect a wide range of personal information without meaningful notice and consent

3) The viral marketing techniques violate Federal Trade Commission guidelines

Hotel 626, a game designed to (quote) “scare the crap” out of teenagers, incites users to check into an online hotel between 6:00pm and 6:00am, asks them to post and share photos of themselves, asks them to distribute invites via their social networks and requires the use of mobile phones to “escape” from the game.

In order to participate in Hotel 626, teens are asked to provide their name, email address and date of birth and enable their webcams and microphones. They are also asked to provide access to their Facebook and Twitter accounts.

A summary report on Digital Marketing to Teenagers is available for download below.