The FTC announced this week that Publishing.com LLC and its two principals will pay $1.5 million to settle charges that the company misled consumers about the income they were likely to earn through its self-publishing programs. The case hits three distinct deception theories: false earnings claims, illusory refund guarantees, and undisclosed material connections in testimonials.

What Publishing.com Was Selling

Publishing.com sold online self-publishing programs and services, primarily two products: AI Publishing Academy (AIA), a self-publishing course priced at up to $1,995, and Publishing Accelerator, an add-on coaching program launched in 2022. The pitch was familiar: a foolproof passive income system through e-books and audiobooks, promoted via free online videos and personal success stories from the company's own founders. The FTC alleged that CEO Christian Mikkelsen and Chief Product Officer Rasmus Mikkelsen claimed that consumers could use these products to earn $1,000 to $3,000 per month in passive income.  Most consumers who purchased the programs, the FTC alleged, never came close to those numbers.

Three Deception Theories

The complaint hits three pressure points that should be on every advertiser's radar.

First, earnings claims. The FTC's position is straightforward: if you are telling consumers they can make a specific amount of money using your product or service, you need a reasonable basis for that claim, and it needs to accurately reflect what a typical purchaser can expect. Highlighting the rare success story while burying or omitting typical results is exactly the kind of gap that draws FTC attention.

Second, refund guarantees. Publishing.com advertised a "no questions asked" money-back guarantee, but consumers who sought refunds allegedly encountered a long list of conditions buried in fine print or lengthy terms of service that made refunds difficult or impossible to obtain. 

Third, material connection disclosures. The FTC alleged that Publishing.com used positive consumer reviews and testimonials in its marketing while failing to disclose that some were written by company employees or relatives of the Mikkelsens, and that others were incentivized through prizes, cash, or additional services. The company also allegedly conditioned refunds on consumers providing positive testimonials. The lack of material connection disclosures were alleged to violate Section 5 of the FTC Act, not the Consumer Reviews and Testimonials Rule that took effect in October 2024 and that the FTC signaled enforcement intent on through a round of warning letters in December 2025. You can check out Terri Seligman's reporting about those warning letters here. While violations of Section 5 of the FTC Act and the Consumer Reviews and Testimonials Rule involve different enforcement tracks, the FTC's focus on them should reinforce the same basic message: the agency has multiple tools for going after deceptive review and testimonial practices, and it's not afraid to use them. 

What the Order Requires

The proposed consent order prohibits Publishing.com and the Mikkelsens from making earnings claims without adequate substantiation, misrepresenting refund or cancellation terms, and failing to clearly disclose material connections between the company and endorsers, as well as any payments or incentives given in exchange for reviews. The order also imposed $1.5 million in monetary relief.

The Takeaway

This case is not limited to self-publishing courses or passive income programs. Any advertiser using testimonials, earnings claims, or satisfaction guarantees should read the Publishing.com complaint. The questions to ask are: (1) Do our earnings claims reflect what a typical consumer actually experiences? (2) Can consumers actually redeem our refund policy without jumping through undisclosed hoops? (3) Have we disclosed every material connection our endorsers or reviewers have to our brand, including incentives baked into our own policies? If the answer to any of those is "not sure," the time to find out is now, and before the FTC does.