How Did a Cult Beauty Brand Get in Trouble With the FTC?

A promotional image for Sunday Riley's Good Genes serum shows a pair of hands using a small bottle.
“Always leave 5 stars.”
Sunday Riley

If you follow the skincareternet at all, you’ve probably been hearing for years that you simply must try a serum called Good Genes by a cult beauty brand called Sunday Riley. It was billed as a one-product miracle worker—and at $105, it was priced that way too. I am not immune to the hype; I too had eyed its product page on Sephora and thought, “Maybe one day.” But now I’m glad I saved my hundred bucks and change, because a lot of that hype may have been created by the brand itself filling the internet with fake reviews.

The Federal Trade Commission announced on Monday that Sunday Riley agreed to settle an FTC complaint from October 2018 over deceptive online review practices. The complaint charged the company with two violations of the FTC Act, alleging that between November 2015 and August 2017, Sunday Riley managers instructed employees to create fake accounts to post positive product reviews on Sephora.com. Sunday Riley herself, the CEO of the brand (and surprisingly, a real person), directly participated in and encouraged these fake review antics. Sunday Riley, like other beauty brands, figured out that consumers frequently base their purchase decisions of whether products are well-reviewed, all of which has created an arms race online among companies to inflate their star ratings.

After Sephora removed some reviews it suspected of fakery, according to the FTC, Sunday Riley began to use a virtual private network, or VPN, to mask its office’s IP address. It’s unclear how Sephora spotted the fake reviews or how pervasive they are, but the company told Vox last year that it employs “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.” The complaint was filed after a former employee supposedly shared on Reddit an email that Riley sent to her staff in 2016 giving them specific instructions for creating new accounts to leave fake reviews that would look authentic. The complaint quoted from the leaked email:

4. Connect to the internet ONLY using the VPN. Make sure to choose a city of origin that goes along with where your character lives. …

5. Leave a review – make sure to NOT compare the product to other products, to not use foul language, and to be very enthusiastic without looking like a plant. Always leave 5 stars.

6. Review a few other products as well – no skincare. Only review makeup, color, hair.

7. Leave a review for a different product every other day so you build up history. 

All in the service of better ratings: As Riley continued, “Tidal and Good Genes are 4.2 and I would like to see them at 4.8+,” naming two products in the company’s line.

So there you have it, Sunday Riley; there’ll be plenty of time to perfect your skin … IN JAIL. Just kidding, she’s not going to jail. In fact, the only penalty seems to be that the company has to cool it with the fake reviews—which is why two of the five FTC commissioners actually voted against the settlement, writing that it “sends the wrong message to the marketplace” and won’t deter other brands from following suit. But as of this writing, Good Genes is hovering around just 4.3 stars on Sephora.com. If things keep going this way, the company may have to change the name to Just OK Genes.

Future Tense is a partnership of Slate, New America, and Arizona State University that examines emerging technologies, public policy, and society.