Medical spas market heavily online, often with before-and-after photos, testimonials, promotions and social media content. The Federal Trade Commission requires that advertising be truthful and substantiated and that material connections to endorsers be disclosed, and state medical and consumer protection laws add their own requirements.

Devices and products raise separate issues. The FDA regulates the aesthetic devices and drugs a spa uses, and using a product outside its cleared or approved indications, or marketing it with claims the FDA has not allowed, can create regulatory exposure. Compounded or imported products raise further questions.

We review websites, advertisements, social media programs, influencer arrangements, membership and package terms, and gift card or prepayment practices before they launch, and we advise on disclosures, patient photo consents and review practices. If a regulator, board or competitor challenges a claim, we respond and defend the practice.

We also advise aesthetic brands and distributors that sell to medical spas on labeling, claims and distribution agreements, and we coordinate with our trademark practice to protect the brand.