Without notice, Facebook updated its Promotions Guidelines as of May 11, 2011.  In some respects, Facebook has largely liberalized its requirements for promotional activities on its social media network.  Now, promotions advertised or offered on Facebook need not be limited to persons who are 18 years of age or older. So, Facebook members of all ages (including those as young as 13) may enter promotions on Facebook.  In addition, Facebook eliminated its prohibition on certain types of prizes, such as dairy products. In many instances, the revised guidelines simply reorganize and clarify elements from the last update to the Guidelines in December 2010.  For example, administration of promotions on Facebook must still be effected via applications (“apps”) on www.facebook.com. While a Company cannot provide an entrant with an automatic entry by “liking” its page, it may still require an entrant to “like” a page prior to collecting full entry information.  However, there are some interesting new developments. Primarily,  Facebook’s “like” functionality cannot be used as a voting mechanism for a promotion. Needless to say, the new Guidelines (available at www.facebook.com/promotions_guidelines.php) are subject to Facebook’s interpretation and enforcement which, in the past, has been unpredictable if not erratic.    Please feel free to contact Cohen Silverman Rowan to discuss.