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Volume XII, Number 276


September 30, 2022

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CARU Wades Into the Water With “Gotta Go Turdle” Toy – Recommends Better Disclosures for Kids and Adult Supervision in Ads

The Children’s Advertising Review Unit (CARU) has recommended that Moose Toys, an Australian toy company, modify ads and packaging of its “Little Live Pets Gotta Go Turdle” toy to disclose that kids should not eat the synthetic “Turdle food” that comes with the toy. CARU also recommended that future promotions of the toy depict adult supervision.

The Gotta Go Turdle is an “interactive, toilet-trained turtle.” TV and YouTube ads of the Gotta Go Turdle featured young children excitedly feeding the electronic toy turtle brightly-colored aqua sand Turdle food, then watching the turtle excrete the food into a toy toilet.

In reviewing the ads of the toy, CARU concluded that they reasonably could convey to kids that the Turdle food is edible and safe for consumption. The Turdle food is, in fact, composed primarily of silicon dioxide. CARU also determined that because no adults were shown in the ads, it gave the impression that adult supervision is not required when playing with the toy.

In reviewing the product packaging, CARU further found that it did not adequately disclose that kids should not eat the Turdle food. A warning of a “choking hazard” was found to be insufficient.

Moose Toys agreed to pull the advertising in its current format and follow CARU’s recommendations.

Children’s advertising compliance, enforcement, and litigation should be handled in connection with counsel. 

Copyright © 2022, Hunton Andrews Kurth LLP. All Rights Reserved.National Law Review, Volume XII, Number 83

About this Author

Phyllis H. Marcus Partner Consumer Products Food Industry Retail Practices

With 17 years of experience at the FTC, Phyllis brings a unique advertising and children’s privacy vantage point to our clients.

Phyllis heads the firm’s advertising counseling practice, and focuses on all aspects of advertising, from the initial development of a claim to its ultimate defense in the marketplace. Phyllis’s practice includes claim creation and substantiation, pre-acquisition due diligence, dissemination in traditional and digital media, and both offensive and defensive competitor challenges. She also counsels clients on the intricacies of compliance with the Children’...

Perie Reiko Koyama Associate Attorney Washington D.C. Data Breach Law Hunton Andrews Kurth LLP

Reiko is a litigation associate in the Washington, DC office, with over five years of practical experience. Reiko handles a range of complex litigation matters, including class actions, consumer protection, data breaches and other commercial litigation. She also litigates constitutional and Title IX issues on behalf of public schools. Reiko began her legal career as a judicial law clerk in federal district court.

Reiko represents and counsels a wide array of clients in various civil matters involving consumer protection and deceptive trade...