I feel that advertisements that say “could be free” or “up to X% off”, or similar should only be legal if the statements are accurate for the overwhelming majority of customers.
E.g you could advertise “free filing” if your free filing applied to 90% off people filing on your platform, you could say up to 20% off everything if more than 90% of expected sales are in the 19-20% range (also prohibit”sale” prices that are functionally the normal price with a fake markdown)
E.g you could advertise “free filing” if your free filing applied to 90% off people filing on your platform, you could say up to 20% off everything if more than 90% of expected sales are in the 19-20% range (also prohibit”sale” prices that are functionally the normal price with a fake markdown)