The Texas-based skincare company sells a variety of cosmetic products at Sephora, which allows consumers to leave reviews of products sold on its website. In its complaint, the FTC alleges that between November 2015 and August 2017, Sunday Riley managers, including Riley herself, posted reviews of the company's branded products on the Sephora site using fake accounts, and requested that other employees do the same.
After Sephora removed the fake reviews, Sunday Riley employees suspected the retail chain had recognized the reviews were coming from their IP addresses. As one of the company's managers alleged, Sunday Riley then obtained “an Express VPN account [to] … allow us to hide our IP address and location when we write reviews.”
The complaint also stated that in July 2016, Riley wrote an email to her staff directing each of them to “create three accounts on Sephora.com, registered as … different identities,” adding “if you see a negative review – DISLIKE it. After enough dislikes, it is removed. This directly translates into sales!!”
As a result, the company and Riley herself have been charged with two violations of the FTC Act. While the settlement does not require the company to admit to posting the fake reviews, it has promised not to do so in the future.
"The administrative order settling the FTC’s allegations against Sunday Riley Skincare and Ms. Riley is intended to ensure the respondents do not engage in similar allegedly illegal conduct in the future," the FTC wrote in a press release. "First, the order prohibits the respondents, in connection with the sale of any product, from misrepresenting the status of any endorser or person reviewing the product. This includes misrepresentations that the endorser or reviewer is an independent or ordinary user of the product. Next, the order prohibits the respondents from making any representation about any consumer or another product endorsers without clearly and conspicuously disclosing any unexpected material connection between the endorser and any respondent or entity affiliated with the product. Such disclosures must be made in close proximity to the product review or endorsement."