Crisis management

When something goes wrong, the instinct is to speak first and establish facts later. That instinct is almost always wrong. Our approach is facts first, then a plan, then the statement, in that order, and documented as it happens so the response can be reconstructed and defended afterward. In creator work, a crisis can be a disclosure failure, a claim that outran the evidence, an impersonation, or a piece of content that reads differently than intended once it is amplified.

The regulatory environment has raised the stakes. The FTC's Rule on the Use of Consumer Reviews and Testimonials, in effect since October 2024, authorizes civil penalties of up to $53,088 per violation, the figure the FTC cited when it sent its first enforcement warning letters under the Rule in December 2025. Enforcement now treats undisclosed material connections and fabricated endorsements as penalizable rather than merely discouraged. A calm, documented response depends on already having the records: who approved what, what was disclosed, what was licensed. When those exist, a crisis is a manageable event. When they do not, it is a spiral.

• Facts and timeline first, before any public response.
• Contract and usage obligations checked immediately.
• Legal questions go to lawyers; we handle communications.
• Decisions and approvals are logged as we go.

Increasingly, crises will involve synthetic media, including deepfakes of creators and fabricated endorsements attributed to real people. Provenance is the defense. Content that carries C2PA Content Credentials can be verified as authentic, and an impersonation can be shown to lack them. We build the record before it is needed, because the value of documentation is entirely a function of having it in advance.