Paavana L. Kumar of Davis+Gilbert LLP

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Paavana Kumar helps major advertisers and retailers assess risk as they create compelling campaigns, run high-exposure promotions and streamline the online customer experience. She is a particular asset to clients seeking to leverage influencer talent, engage more creatively on social media, and reimagine their online e-commerce and subscription programs.

Paavana’s ability to assess problems and provide quick, efficient risk assessments enables her to partner effectively with companies across industries, especially those pursuing a deeper e-tail focus. She is a sounding board for C-suite executives and general counsel when making high-stakes judgment calls about social media opportunities, FTC disclosure requirements and major changes to their business models.

As many clients move toward subscription models, Paavana’s knowledge of the highly regulated automatic renewal and negative option laws across all 50 states enables her to help companies draft transparent marketing disclosures and design compliant user flows. She also advises on high-exposure consumer promotions, including sweepstakes, contests, loyalty rewards and gift cards, cause marketing and donation programs, text message and email marketing, and major entertainment and sports collaborations.

Whether she’s counseling on a discrete issue or working with global legal teams for clearance for an international campaign, Paavana delivers practical advice with enthusiasm and a sense of humor. She is a recognized thought leader who frequently speaks and writes about leading-edge e-commerce and influencer marketing topics for in-house counsel and industry stakeholders.

Paavana actively supports the firm’s recruiting efforts and enjoys mentoring summer associates.

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FTC Staff Report Brings Dark Patterns to Light

Trick or treat? The Federal Trade Commission (FTC) staff is focused on one “trick” this spooky season: Designing user interfaces to trick or manipulate users into taking actions they would not otherwise approve of, or putting obstacles in place to discourage consumers from exercising certain rights. These so-called “dark patterns” are a continued focus of … Continue Reading

SEC Penalizes Kim Kardashian Over $1 Million for Paid Crypto Post

The Securities and Exchange Commission (SEC) settled with Kim Kardashian over allegations she violated Section 17(b) of the Securities Act (the “Act”) by publishing an Instagram post promoting the crypto-currency, EthereumMax token (EMAX), to her 250 million followers, without adequate disclosures. Kardashian received approximately $250,000 for this post.… Continue Reading

FTC To Focus on Subscription Services — Hints at Taking Action Against “Dark Patterns”

The FTC has issued a new Enforcement Policy Statement Regarding Negative Option Marketing (Policy Statement), generally warning companies about their compliance obligations relating to negative option programs and against using website design features to deceive consumers into signing up for subscription services (i.e. by using “dark patterns”). The Policy Statement was released in light of … Continue Reading

The Role of Artificial Intelligence

The use of artificial intelligence (AI) in the fashion and beauty industries — and the marketing of the same — has steadily gained traction over the last few years and it’s not hard to see why. AI provides a myriad of opportunities and potential applications within the fields of fashion and beauty, but it can … Continue Reading

FTC Brings First Ever Enforcement Action Against Individual Social Media Influencers; Updates Warnings and Guidance for Influencers and Marketers

On the heels of issuing more than 90 letters to celebrities, bloggers and other influencers in April 2017, as well as receiving continued petitions by watchdog organizations such as Public Citizen, the Federal Trade Commission (FTC) brought its first direct action against individual influencers for failing to disclose their material connections on social media. At the … Continue Reading


The Federal Trade Commission (FTC) sent more than 90 letters to celebrities, athletes and other influencers – as well as to marketers – highlighting the need for influencers to “clearly and conspicuously” disclose their relationships to brands when they promote or endorse them on social media. The FTC letters mark the first time that the … Continue Reading