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The proper functioning of online marketplaces requires the information to be truthful and offered to the consumers transparently. Fake reviews on digital platforms are one of the main challenges to Consumer Protection Law on the Internet, as they jeopardise this. Despite a growing attention to consumer rating systems and online fake reviews in the academic literature, legal research on the topic is still rare. Most scholars focus on contributing to the identification of counterfeit reviews, which often entails considering linguistic aspects of the reviews (Fiedler and Kissling 2020, p. 79). Hence, this paper aims to fill the gap in research by presenting a detailed analysis of the legal framework applicable to fake reviews, comparing law and enforcement practices in the US, EU and the UK. In particular, this study seeks to answer how do the laws in the US, EU and the UK respond to the problem of fake reviews. This study approaches it in four steps. First, the problems of fake reviews in online platforms and their seriousness are discussed. Second, illegality of fake reviews is assessed. Third, we compare enforcements by the US and European public bodies. Finally, this paper proposes some measures that can be adopted to increase efficiency of enforcement. EU legislation allows Member States to choose what type of control they want to exercise over illegal advertising, whether it is judicial or administrative.Footnote 46 The three countries that we are considering by way of illustration have different approaches to this issue. In the UK, consumer law enforcement is entrusted to the Trading Standards Services, which is funded by, and accountable to the local authorities as well as to the Competition and Markets Authority (CMA).Footnote 47 The focus of the CMA is the market, while the Trading Standards Services tackles detriment to the consumers more generally. In Spain, the actions against illegal advertising are resolved by ordinary courts.Footnote 48 When illegal advertising affects consumers, regional authorities may impose administrative sanctions.Footnote 49 In Italy, ordinary courts resolve conflicts due to unfair competition and illegal advertising. In addition, advertising regulations attribute the power to prosecute and punish illegal advertising to the administrative body Autorità Guarante della Concorrenza e del Mercato (AGCM).Footnote 50

Video game players broadcast themselves playing the game, usually with an audio commentary. A chat box helps them connect with their audience. Twitch broadcasters can apply for the Twitch Affiliate or Partnership programs, which enable them to get a cut from the advertisement and subscription revenue Twitch receives. Acceptance into the program requires approval, which is based on certain requirements, such as having a minimum number of viewers and a minimum of broadcasts per week.8

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