Legal landscape note: This article was originally published in 2016 and describes the law as it stood at that time. New Jersey law changes frequently.
Overview
You check the reviews before you book the contractor, pick the restaurant, or buy the product -- five stars, hundreds of happy customers, done. But some of those glowing reviews were written by people who never bought anything at all. A 2016 analysis by legal scholar Neil Helveston in "Regulating Digital Markets" confirmed what many shoppers suspected: the growth of online applications has created massive economic incentives for businesses to manipulate their reputations through manufactured reviews. For consumers in New Jersey and New York, this translates to distorted purchasing decisions and potentially fraudulent business practices.
How Fake Reviews Operate
The fake review ecosystem functions through several mechanisms. Some businesses create their own reviews using dummy accounts. Others hire third-party "reputation management" firms to generate positive reviews en masse. In more egregious cases, review-hosting platforms themselves have been accused of manipulating review visibility -- including filtering positive reviews for businesses that refused to purchase advertising.
The Federal Trade Commission has long held that endorsements and testimonials must reflect the honest opinions of genuine consumers. See 16 C.F.R. § 255.0 et seq. Under the FTC's Endorsement Guides, businesses that create or purchase fake reviews may face enforcement actions for deceptive trade practices.
The "Clean Turf" Operation
In 2016, New York Attorney General Eric Schneiderman launched "Clean Turf," a targeted investigation into the reputation management industry. The operation resulted in settlement agreements with more than ten search-engine-optimization (SEO) companies responsible for generating thousands of fraudulent reviews across platforms including Yelp, Google, and TripAdvisor.
The companies involved allegedly hired freelance writers to pose as satisfied customers, creating detailed narratives about businesses the writers had never patronized. The scheme spanned industries from dog trainers to piano teachers to wedding DJs -- demonstrating the breadth of the problem.
Legal Remedies Available
Under the New Jersey Consumer Fraud Act, N.J.S.A. 56:8-1 et seq., businesses that misrepresent themselves through fake reviews may face significant liability, including treble damages and attorney's fees. Similarly, the New York General Business Law § 349 prohibits deceptive acts or practices directed at consumers.
Class action litigation presents another avenue for addressing systemic review fraud. Consumers who relied on fabricated reviews to make purchasing decisions may have claims for misrepresentation and unjust enrichment, though proving damages in such cases requires careful factual development.
Helveston proposed an additional regulatory approach: requiring businesses that use third-party contractors for review solicitation to disclose those relationships on a government regulatory page. Such a requirement could expose non-compliant businesses to class action liability while providing consumers with greater transparency.
Practical Guidance for Consumers
Consumers can protect themselves by cross-referencing reviews across multiple platforms -- Google, Yelp, Facebook, Better Business Bureau, and industry-specific sites like CNET or Consumer Reports. Red flags include a disproportionate number of five-star reviews, similar writing styles across purportedly different reviewers, and reviews that lack specific details about the customer's experience.
Key Takeaways
- Fake reviews violate FTC guidelines and may constitute consumer fraud under state law
- New York's "Clean Turf" operation demonstrated that enforcement is increasing
- The New Jersey Consumer Fraud Act provides remedies including treble damages
- Cross-referencing multiple review platforms helps identify manipulation
- Third-party disclosure requirements may be coming to increase transparency
Reviewed by Britt J. Simon, Esq., Managing Partner -- Simon Law Group, LLC -- May 2026
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