SmartClick (2016) entered into a settlement with the FTC consisting of a permanent injunction and a monetary judgment for about $600,000. This settlement exceeded SmartClick’s gross revenues from the challenged activities (but most of the payment was suspended based on upon the Defendants’ financial disclosures). SmartClick operated a “certification” program for third-party health-related websites and hosted a lifestyle “blog” at www.betterlivingjournal.org. The FTC alleged that the Better Living Journal was composed of paid promotions, and SmartClick received commissions and other payments each time a consumer clicked on links or purchased the products featured in the blog posts. The only disclosures of these arrangements were located in the “About Us” and “Disclosures” links at the bottom of the page. SmartClick also operated two other websites at www.prematurecures.com and www.pheromonemen.info where it was paid to promote certain products on these websites and failed to make clear and conspicuous disclosures of these material connections. (All three of these websites were forms of native or disguised advertising because the content was sponsored, but they were made to look like independent or editorial websites.) The FTC also imposed many years of costly compliance monitoring.