Executive Summary
The Competition and Consumer Commission of Singapore (“CCS“) has taken enforcement action against a provider of fake review services and businesses that procured such fake reviews, and required them to cease their unfair practices, remove posted fake reviews, and post a public apology for six months.
As this is CCS’ largest fake review investigation to date (having regard to the number of businesses involved), it is being conducted in two phases. The first phase covers the fake review provider and the 47 businesses that procured such services. The second phase has also commenced, extending to other businesses that may have procured such services from the provider as well.
This Update summarises the key facts and findings from the first phase, as well as its implications for businesses.
Background Facts
CCS’ investigations revealed that, since or before 2023, one Julian Tung Yan Kai (“JT“), the sole director of Reputifly Pte Ltd (“Reputifly“), had created or facilitated the posting of fake reviews on various online review platforms for approximately 100 businesses. JT did this through businesses and websites that he owned and operated, such as BuyReviewSG and GetReviewSG (collectively, the “Fake Review Provider“). Briefly, the modus operandi was as follows:
- Package purchase: Businesses could purchase packages of fake reviews to be posted periodically. To facilitate their selection of packages, they could use a ratings calculator to determine how many five-star reviews they would need to reach their desired Google rating.
- Fake review creation: The content was either supplied by the businesses or generated by the Fake Review Provider. For the latter, the Fake Review Provider used generative artificial intelligence (“Gen AI“) to create fake reviews designed to resemble genuine customer experiences and to engineer the veneer of authenticity, e.g. by making stylistic variations, incorporating details and localised context, introducing natural imperfections, and intentionally expressing initial reservations before setting out positive experiences.
- Pre-publication: Prior to publication, businesses were permitted to amend the fake reviews. At the same time, the Fake Review Provider utilised various Telegram channels and accounts to recruit individuals to post the fake reviews, offered them payment for such posts, and cautioned them not to post duplicate reviews so as to reduce the chances of being found out.
- Publication management: The Fake Review Provider offered a sophisticated online dashboard, which was utilised to: (i) create, monitor and track the fake reviews; (ii) draw from a business’ existing four and five-star reviews to create new ones; and (iii) issue links for businesses to review screenshots of posted fake reviews and monitor the status of their purchases.
- Post-publication: If the fake reviews were taken down by any of the relevant online review platforms, the Fake Review Provider committed to replace up to 30% of the reviews purchased.
Findings and Enforcement Action by CCS
CCS found that the fake reviews were presented as authentic customer reviews when they were not, and customers could reasonably have been misled into thinking that the businesses, or the various goods and services offered, were more well-received than they actually were. Pursuant to CCS’ investigations:
- The Fake Review Provider admitted to creating fake review content with the veneer of authenticity, and recruiting and paying reviewers to post the same, thereby aiding and abetting these unfair practices.
- The Fake Review Provider has committed to: (i) stop providing fake review services and facilitating unfair practices; (ii) issue a prominent public apology for six months on Reputifly’s website; and (iii) donate the proceeds arising from such services.
- 45 businesses admitted that they had procured and purchased fake reviews from the Fake Review Provider, and that some or all of these had been posted on online review platforms.
- Undertakings were provided by these businesses to CCS, including commitments to stop obtaining or posting fake reviews, and to cease various other unfair practices.
- The businesses are also required to: (i) identify and take down fake reviews relating to their businesses; (ii) report on the status of this to CCS; (iii) strengthen compliance; and (iv) issue a prominent public apology for six months on their websites, social media accounts and physical premises.
- Two businesses declined to provide the undertakings required by CCS. As such, CCS will continue to pursue its investigations and will take firmer enforcement action against them, provided that this is supported on the facts.
Key Insights
At a glance, this unfair practice of procuring fake reviews appears to have spanned a wide range of businesses, including those offering medical services, beauty and aesthetic services, the hospitality industry, and the food and beverage industry, among others. Taken together with the sophistication of the Fake Review Provider’s operations (e.g. its ratings calculator, online dashboard, and Gen AI use), as well as its sheer reach (extending to approximately 100 businesses), this could potentially raise concerns regarding consumer and marketplace trust.
Importantly, CCS has indicated that businesses who have procured fake reviews but who voluntarily disclose this to CCS prior to the initiation of formal investigations against them will have such cooperation regarded positively. Yet, businesses should be well advised as to the risks and implications before engaging in a voluntary disclosure, and we are able to guide further on this.
If you have any queries on the above, please reach out to our team set out on this page.
For regional Competition & Antitrust matters, please see Rajah & Tann Asia’s Competition & Antitrust Practice for more information.
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