Date of Award

Spring 1988

Degree Type

Thesis - Restricted

Degree Name

Master of Arts (MA)



First Advisor

Crowley, John H.

Second Advisor

Pokrywczynski, James V.

Third Advisor

O'Neill, Patrick G.


During the early 1970s the amount and intensity of advertising regulation by the Federal Trade Commission (FTC) , an agency of the federal government, increased exponentially. Among a great many actions taken by the FTC at this time was issuance of a new rule requiring advertisers to be able to provide scientifically-valid substantiation for all claims contained in advertising in regard to product safety, product performance, product quality and comparative pricing. The FTC required the substantiation to be in existence prior to the appearance of the ad. This "prior substantiation" rule has been in effect ever since. At the time this rule was announced, the author was a copywriter at a medium-sized advertising agency in Milwaukee. In the ensuing months, it seemed that most people in the advertising business were challenged repeatedly to create ads that met the new FTC rules and standards as they evolved. Every large client of the agency reacted by expanding the size and authority of their internal legal departments, and for some years it seemed far more important to create ads that would satisfy the attorneys and the FTC than to create ads that would sell products to consumers. Many in the advertising business, both in the agency and in the client organizations, wondered what all the fuss was about, since they would never have knowingly had anything to do with deceptive advertising. The author was convinced then (and is still convinced today) that the most effective regulation of advertising is competitive pressure in a free market, and the most compelling influence on an advertiser is the consumer. Was this new, highly-publicized regulatory pressure from the government really necessary? Was it likely to produce lasting and worthwhile results? Ultimately, that curiosity evolved into the motivation underlying this thesis: a desire to find out whether there really was a widespread problem of false or misleading advertising, and whether the FTC's regulation and influence has provided an effective solution Of course that is a very large question, and this is an M.A. thesis undertaken by one individual acting under time constraints and with limited financial resources. Accordingly, the present investigation explores one aspect of the impact of FTC regulation, by attempting to measure the effect of the "prior substantiation" rule on actual advertisements. Using established content analysis procedures, it compares certain characteristics of the advertising copy of new car magazine ads, selected from four full-year data points at 10-year intervals, from 1966 through 1996. The study was designed to find content differences between automobile advertising that ran before the "prior substantiation" rule was announced (ads that appeared during the year 1966) and more recent advertising (ads that appeared in 1976, 1986 and 1996) that might have resulted from the presence of this rule.