I think product placements can be deceptive, because most viewers don’t realize they’re really advertisements,” says FCC Commissioner Jonathan S. Adelstein. “That’s why there’s a law that requires disclosure. The question is: How well are we enforcing it?” ABC, CBS and UPN all insist their policy is to comply with laws passed by Congress nearly 80 years ago requiring that broadcasters and other involved parties identify anyone who gave them “valuable consideration” to air anything. (Fox, NBC and the WB did not respond to a request for comment.) But Adelstein agrees that “we may need to change our rules to address the fact that, even when there is some disclosure, people still don’t know that they’ve been advertised to. At a minimum, it seems that advertisers should disclose up front (in the program) there’s going to be a product placement, so that when somebody sees it, they know what they’re seeing.” Adelstein is outspoken about cracking down on violations of federal payola laws, which (along with undisclosed product placements) can include video news releases misrepresented as legitimate news reports, and appearances by consumer product experts who evaluate products with which they have an unacknowledged financial tie. He has invited viewers “to hit their record button” when they see an apparent breach, then to share that tape with the FCC for a possible investigation. (Background information for the public on payola is available on the FCC Web site.) “Viewers shouldn’t be unwitting victims of a stealth campaign to manipulate their minds,” says Adelstein. “If they know that somebody’s trying to persuade them about something, they can take that into account.”