The National Institute on Media and the Family released a statement calling on WOMMA to prohibit the "exploitation of minors in word-of-mouth campaigns." While WOMMA's code already prohibits marketing to children younger than 13, the organization is asking WOMMA to require parental notification and consent when engaging children between 13 and 16 years of age. In addition to possible exploitation, the Institute also raised the concern that children were being exposed to inappropriate sexual material by word-of-mouth marketing campaigns.

"We know from other research that it is that group that is most vulnerable to some of these things," said the Institute's founder and President, David Walsh. "For example, we know that it is that group that is more likely to give out personal family information without their parent's knowledge, and we know that it is that young teenage group that is most vulnerable to any of the inappropriate content that shows up in chat rooms."

Walsh also raised the possibility that sexual predators might approach minors involved in word-of-mouth campaigns conducted in Internet chat rooms, but said that his organization had not done any research to suggest that minors participating in chat room word-of-mouth marketing were at greater risk than the average young chat room user. "I think it could expose them to more danger," said Walsh. "There's that potential there."

WOMMA CEO Andy Sernovitz took issue with the Institute's contention that members might expose minors to inappropriate material or endanger their well-being.

"We were concerned about the glaring inaccuracies in the Institute's press release, beginning with their failure to note that this was not an established code, but a starting point and request for input," Sernovitz stated. "Their implication that our members would ever endanger children, promote inappropriate content, or release private information is absurd."

Sernovitz said that WOMMA would further investigate protecting minors involved in word-of-mouth marketing. "We are in complete agreement that the need to protect minors is a critical issue," he stated. "We look forward to working with leading educational, consumer, and children's advocate organizations in making sure that the bar is set properly high."

Another industry group, the Viral & Buzz Marketing Association, claims that the WOMMA proposed ethics code focuses too heavily on deceptive marketing practices, and dodges the issue of marketing to minors. Justin Kirby, the co-founder of the VBMA, said that condemning deceptive practices wholesale precludes some of what viral and buzz marketers do.

"What we're talking about is an ethical spectrum that goes from deception to transparency. There is this bit in the middle, which is like 'April Fool's'," said Kirby. "They say you can't fake word of mouth. Well, how do you do an April Fool, then?"

Sernovitz responded that WOMMA's code includes a clause specifically to exempt such a campaign. Sernovitz cited the "honesty of identity" portion of the ethics code, which reads in part: "Manner of disclosure can be flexible, based on the context of the communication. Explicit disclosure is not required for an obviously fictional character."

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