The Federal Trade Commission (FTC) has filed a complaint against Evoke Wellness and its executives for allegedly using deceptive Google Ads practices to mislead people seeking addiction treatment.
It’s likely that Evoke Wellness won’t be able to run ads on Google again. Thus crushing their business. As cited in the FTC complaint, over 85% of those seeking addiction treatment use Google search.
Massive.
This case highlights several critical lessons for operators.
Have Integrity in What You Do:
The complaint alleges that Evoke used Google's dynamic keyword insertion to make their ads appear as if they were other legitimate treatment centers
From 2021 to 2023, this practice generated over 68,510 search ad impressions and led to at least 3,502 calls to Evoke's call center
When people specifically asked about the other centers they were trying to reach, Evoke's staff allegedly continued the deception rather than being transparent
Work with Partners that Have Integrity:
The FTC cited both Evoke Wellness LLC and Evoke Health Care Management LLC in the complaint
Company executives Jonathan Moseley and James Hull were named individually for their roles in approving the deceptive advertising practices
Treatment centers should carefully vet any marketing partners and review their practices
Avoid Dynamic Keyword Insertion for Competitor Campaigns:
The FTC specifically called out Evoke's misuse of Google Ads' dynamic keyword insertion feature
The company allegedly bid on competitor names and inserted them into ad headlines, making ads appear to be from those facilities
This practice violates both FTC regulations and Google's own advertising policies
Answer Calls by Stating Your Company’s Name:
Rather than clearly identifying themselves, Evoke's call center staff allegedly used vague greetings like: "Admissions, this is [name]. Who do I have the pleasure of speaking with?" "Good morning/afternoon. This is [name]; how may I assist you today?" "Recovery helpline, this is [name]. How can I help you today?"
The FTC views this lack of transparency as part of the overall deceptive practice
The legal consequences for these actions include potential civil penalties, permanent injunctions, and other relief under both the FTC Act and the Opioid Addiction Recovery Fraud Prevention Act (OARFPA).