Is Avigilon 95 Camera Claim Violating FTC Guidelines?

Author: John Honovich, Published on Jul 23, 2012

One of our industry's most ridiculous marketing claims is Avigilon statement that their 29MP camera "can replace up to 95 conventional cameras." Grounded on the resolution = quality myth, virtually no one will ever replace 95 cameras with the Avigilon 29MP. Despite this, it makes great ad copy. Fortunately, the US FTC is cracking down on ‘up to' claims with tightened guidelines. In this note, we examine how this will impact surveillance manufacturers like Avigilon.


Marketing people love to use ‘up to' claims because it allows them to promote a very aggressive, unrealistic number (e.g., lose up to 100 pounds, make up to $100 million, etc.) even if the typical results are dramatically less. They know from experience that non experts will regularly mistake the maximum claim with the average experience. Defenders of this practice will laugh and say "ha suckers", ‘buyer beware' or ‘they should have known better'.

Thankfully, most governments have departments that regulate and restrict unscrupulous marketers from taking advantage of buyers. In the US, that department is the Federal Trade Commission (FTC).

US FTC Guidelines

While the FTC has always had guidelines on ‘up to' claims, until now they have been fairly subjective and broad. Past rulings said that ‘up to' marketing had to have, "appreciable number of consumers under circumstances normally and expectably encountered by consumers" to meet that claim - whatever that means. Additionally, the National Advertising Division, a self-regulatory group, advised that at least 10% had to experience the maximum benefit claimed.

Now, the US FTC has strengthened those guidelines based on a newly released study. In it, the FTC found that a significant percent of people mistook ‘up to' claims to be exact claims (i.e., instead or ‘replacing up to 95 cameras', the survey respondent believed that it was ‘replacing 95 cameras'). Based on the study, the FTC declares that:

"Advertisers using these claims should be able to substantiate that consumers are likely to achieve the maximum results promised under normal circumstances."

This is a much tougher test that many advertisers, including Avigilon, will struggle to meet.

The ‘Up To' 95 Camera Claim

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The Avigilon ‘replacing up to' 95 cameras fails on many levels:

  • While the Avigilon 29MP camera can only be installed at a single location, multiple conventional cameras can and normally are used at many locations to get different angles and more direct views of subjects.
  • Many of the pixels are wasted as the Avigilon only has a single FoV while multiple conventional cameras can be optimized for specific target areas and to avoid obstacles / walls, etc.
  • The Avigilon camera has 93% lower frame rate than conventional cameras (2 vs 30) and 75% lower than what is typically used (2 vs 8).
  • The Avigilon camera consumes 10x the amount of bandwidth per pixel than conventional cameras (JPEG2000 vs H.264).

This does not mean that the Avigilon 29MP is a bad camera. While it can play an important and somewhat unique role in surveillance systems, it will not replace anywhere near 95 conventional cameras.

Another surveillance example of ‘up to' claims is NVR manufacturer Timesight who used to claim storage reductions of ‘up to 90%' leading to a classic IPVM debate. That noted, today, most of the ‘up to' claims in surveillance center around camera replacement (Arecont is another frequent offender here).

Avigilon's Response

We shared our concerns with Avigilon, noting the FTC guidelines and calling out their 95 camera claim.

Avigilon says they adhere to the FTC Guidelines noting that, "comparing purely pixels you would need up to 95 analog or conventional to capture an image of the same resolution." Indeed, their product overview page notes that the 29MP "gives you the same resolution as 95+ VGA cameras."

Avigilon declined to answer what percentage of customers replaced 95 analog cameras with a single 29MP camera nor what percentage were planning to deploy 75+ analog cameras choose instead to use a single 29MP camera. They stressed that they are, "speaking to the resolution equivalency to help people understand the scope of coverage they can achieve."

If Avigilon wants to speak purely about resolution, than they should do so and refrain from talking about camera replacement because replacing 95 cameras is rarely, if ever, feasible and does not seem to meet the FTC's guideline that "consumers are likely to achieve the maximum results promised under normal circumstances."

Impact on Manufacturers

Ultimately, the impact will depend on how afraid manufacturers are of FTC penalties. FTC monitoring is traditionally not as vigilant as local policing so many advertisers can fall through the cracks. As such manufacturers may view it as a tactical risk worth taking.

That noted, strengthened guidelines empower the public to protest and to file complaints directly with the FTC. We are excited that the FTC has done this. These marketing claims hurt the industry by rewarding unscrupulous manufacturers. We look forward to calling out future egregious ‘up to' claims.

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