For those who know their skin care products, Sunday Riley is a beloved brand. Good Genes face acid is a best-seller at Sephora and frequently hailed as a holy grail product. But the company got some unwelcome scrutiny at this time last year after a former employee shared on Reddit an email allegedly directing employees at the company to open fake accounts and leave glowing Sephora reviews of Sunday Riley products.

The deception shocked some customers and served to highlight the questionable trustworthiness of online product reviews at retailers like Sephora. On Monday, the FTC offered the company an arguably generous settlement that again got people talking.

After the initial leak, the Federal Trade Commission (FTC) filed a complaint against the brand, alleging Sunday Riley made misleading claims in the reviews and didn’t disclose that the company was behind them. The FTC had copies of several emails, including from founder and CEO Sunday Riley herself, encouraging employees to use a “virtual private network” (VPN) to leave reviews that would be untraceable to the company’s IP address. (Apparently Sephora had gotten wind that some of these reviews were not from legitimate customers and had been deleting them.)

The FTC has offered a settlement with Sunday Riley that includes agreeing it will never write fake reviews again. The company was able to accept the settlement without admitting any wrongdoing. It is not being otherwise fined or punished in any other way.

But the decision was not unanimous within the FTC. Two of the five commissioners, Rohit Chopra and Rebecca Kelly Slaughter, contested what amounted to a slap on the wrist in a strongly worded letter, shared with Vox by Commissioner Chopra’s advisor.

The letter read in part:

Going forward, the FTC should seek monetary consequences for fake review fraud, even if the exact level of ill-gotten gains is difficult to measure. The agency should also comprehensively analyze the problem of fake reviews, including whether or not ecommerce firms have the right incentives to police their platforms...Today’s proposed settlement includes no redress, no disgorgement of ill-gotten gains, no notice to consumers, and no admission of wrongdoing. Sunday Riley and its CEO have clearly broken the law, and the Commission has ordered that they not break the law again.

Neither Sunday Riley nor Sephora responded to requests for comment.

How Sunday Riley planted fake reviews on Sephora’s website

In October 2018, a user and supposed former Sunday Riley employee calling themselves “throwawayacctSRiley” posted on Reddit and shared a copy of an email that clearly shows that employees had been asked by the company to register as fake Sephora users in order to leave glowing reviews for new acne products that the company was launching. The email laid out in great detail how employees should register as reviewers to avoid having their IP address traced back to the company, and to leave reviews on other brands as well to avoid drawing suspicion to themselves. It was recommended that employees set up several different profiles and “mix and match your identities.”

The most eye-opening section of the email reads:

It helps to make yourself seem relatable — like you know how hard acne is and you’ve tried everything, and this one actually works or mention things like, yes it’s a little more expensive but works incredible [sic] well compared to the cheaper masks out there. If you need any help with things to come up with to say, feel [sic] to ask myself, Sunday, or Addison. As reviews come in, read them too. If you notice someone saying things like I didn’t like “x” about it, write a review that says the opposite. The power of reviews is mighty, people look to what others are saying to persuade them and answer potential questions they may have.

It caused a huge commotion in the beauty world, racking up over 500 comments on r/skincareaddiction. And the news only got bigger when Sunday Riley confirmed that it was true. A brand representative wrote in the comment section of the anonymous beauty industry watchdog/gossip Instagram account Estee Laundry:

As many of you may know, we are making an effort to bring more transparency to our clients. The simple and official answer to this Reddit post is that yes, this email was sent by a former employee to several members of our company. At one point, we did encourage people to post positive reviews at the launch of this product, consistent with their experiences. There are a lot of reasons for doing that, including the fact that competitors will often post negative reviews of products to swing opinion. It doesn’t really matter what the reasoning was. We have hundreds of thousands of reviews across platforms around the globe and it would be physically impossible for us to have posted even a fraction of these reviews. Client word-of-mouth, sharing how our products have changed their skin, has been the cornerstone of our success. In the end, our products and their results stand for themselves.

(Sunday Riley did not return Vox’s request for comment.)

Responses were swift and decisive. Fans of the brand on Reddit commented things like, “Joke’s on Sunday Riley, even if they actually have good products now I’ll never believe it because of their manipulation” and “As someone who suffers with acne, I find this extremely upsetting. Advising your staff to write a review saying a product cleared your acne is preying on the vulnerable.”

People have strong attachments to brands, especially when it comes to skin care. This was largely seen as a breach of trust.

The FTC complaint alleges that this practice had been going on for about two years, between 2015 and 2017. Riley herself reportedly told employees to create at least three accounts “registered as different identities,” to use the VPN, and to dislike negative reviews so that they would be removed. “This directly translates to sales!!” she wrote.

So how common is this practice, really?

Online reviews are really important to brands. Studies have shown that customers trust products that have a lot of reviews, and it’s human nature to look to peers and “real people” for their opinions. It’s why, especially for makeup and other beauty products, so many people follow bloggers, YouTubers, and Instagrammers. They’re perceived to be authentic (though recent drama in that world has revealed that their reviews can sometimes be purchased for a lot of money).

This is not the first time the authenticity of online reviews has been called into question. Amazon has been singled out frequently in stories alleging that brands pay people to write reviews. It happens enough that there are now even plenty of tips for recognizing when a review might not be what it seems.

In 2017, I reported on this phenomenon in the beauty industry for Racked. There are a variety of companies that offer free products in exchange for “honest” reviews, and small brands admitted feeling pressure to solicit fans to leave positive reviews. But this is the first time a major brand has been called out on the practice, with receipts. It provides insight into the way the beauty industry sells products, and how cutthroat and dishonest it can be.

Sunday Riley is likely not alone here. “This happens a lot. Sephora puts the pressure on brands — they really ‘encourage’ reviews,” says a beauty industry source who wished to remain anonymous so as not to jeopardize their relationship with Sephora and beauty brands. “When you have a new launch, the sales will increase with a ton of good reviews. I do want to reiterate how common this practice for brands is. Sunday Riley just got caught. I’m not defending it, but it’s a vicious cycle.”

Caroline Hirons is a popular and well-respected UK-based skin care blogger and beauty brand consultant. She posted a sponsored video with Sunday Riley a few days prior to this controversy and worked as a consultant to the brand five years ago. She says she was never asked by the brand to post any sort of fake review, and wouldn’t ever agree to do so. But she concurs that it’s a common practice in the industry.

“It’s not the brands. The direction comes from the retailers,” Hirons, who has called out the practice in the past on her blog, says. She notes that she’s never had a request quite as detailed as the Sunday Riley email, though. “I’ve never come across anything that organized. I’ve just had verbal requests in retailer meetings.” (She also clarifies that she’s never heard those requests from UK-based retailers like Space NK, Cult Beauty, or department stores like Selfridges.)

In Hirons’s skin care fan group on Facebook, which has almost 10,000 fans, a user shared a screenshot of communication she had supposedly had with Sephora’s customer service department after she’d asked about the Sunday Riley issue. The email read: “Thank you for taking the time out of your day to reach out to us about this matter. We have recently found out about it and we are looking into it. We do not condone this type of activity. Rest assured we are working diligently on this.” It was signed “Jazlyn, Sephora Client Services.”

Sephora provided the following statement to Vox at the time:

At Sephora, we believe in the power of the beauty community and that knowledge should be shared to benefit all. Sephora has very strict brand rules regarding our Ratings and Reviews, which we know are an important decision tool for our clients. Additionally, we have teams dedicated to protecting the integrity of our Ratings and Reviews, ensuring through detailed moderation that it’s a constant trusted, unbiased, authentic source for all. We do not believe this incident is representative of the Sephora Ratings and Reviews culture, or the countless hours our clients have spent sharing their product experiences with us and others. We’ve been in touch with Sunday Riley on this matter, and they have committed to adhering to our review policy.

The pressure to sell

The shelves of Sephora are crowded, and competition in the beauty industry is fierce. Brands, especially small ones, are under a lot of pressure to sell and to conform to the whims of retailers. Retailers often hold a lot of the cards. (Read this cautionary tale about Sephora and the now-defunct makeup brand OCC for an example of how this can sometimes play out.)

A small brand owner who wished to remain anonymous wrote in an email to Vox, “We are under a lot of pressure to drive reviews for our products on Sephora.com, but Sephora’s site is also really good about weeding out reviews that aren’t legitimate, so it’s very hard to build up a product page by leaving a large number of ‘fake’ reviews.”

Sunday Riley has struggled in the past few years, facing a lawsuit about false advertising, which was eventually tossed out. It also launched a foundation called The Influencer earlier in 2018, which is no longer available. It’s been actively trying to build its business in the UK, launched a wellness-focused beauty box, and relaunched its website. It’s not clear that this settlement will either affect Sunday Riley’s business or protect consumers going forward.

As FTC Commissioner Chopra wrote: “This settlement sends the wrong message to the marketplace. Dishonest firms may come to conclude that posting fake reviews is a viable strategy, given the proposed outcome here. Honest firms, who are the biggest victims of this fraud, may be wondering if they are losing out by following the law. Consumers may come to lack confidence that reviews are truthful.”

It’s all just a modern-day example of the old adage, “Buyer beware.” As one redditor suggested, perhaps be wary of any review that’s too glowy, and head for mediocre territory: “This is why I tend to trust only the reviews that are 3 stars. That’s where the honesty is.”

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