When Affiliate Marketing Becomes Brand Impersonation
Kim Luong
Marketing
Industry News
Brand impersonation is moving from marketplace listings to the point of purchase. A paid search ad, a lookalike booking page, or a local phone number can lead customers to believe they are dealing directly with a brand. Hotel booking is a clear example, and one that US regulators are now examining.
Our detection data from one hotel chain over a recent eight-week window shows:
2,300+ pages, listings, social accounts and domains using the chain’s name in ways that matched its brand-misuse criteria
250+ web domains containing the chain's name that it does not own, 120+ of them flagged for booking, payment or login content
25+ Google ads from a single third-party reservations site over two days, in markets where it does not operate
25+ listings on GuestReservations.com and BookOnline.com
Although the chain is British, infringements with a known location were more often linked to the United States (~450) than to the UK (~230).
The US Federal Trade Commission is reportedly preparing legal action against Booking Holdings, the owner of Priceline, over ads that appear to lead to a hotel’s own website but send consumers to a third-party booking site where they often pay more. Reuters reported that the agency is examining Booking’s relationship with Guest Reservations and considering whether it sites violate the federal rule against impersonating businesses, alongside possible fee violations.
In a related case filed in July, San Francisco City Attorney David Chiu sued GuestReservations.com, BookOnline.com, and Booking Holdings, the sites’ room-inventory supplier, alleging the sites imitate real hotels and charge travellers far more than booking direct.
In both cases the rooms and reservations are real. The alleged deception concerns who the customer is booking with, which places impersonation in paid search and booking pages rather than in counterfeit goods or fake storefronts.
Why hotel brands have become a prime target for impersonation
People who search for a hotel by name are usually ready to book. Search ads let any business selling that hotel's rooms buy the top spot in those results. Hotels have long encouraged guests to book directly to avoid paying commissions to intermediaries. Travellers who want to book directly look for the hotel's official website, so a third-party site that resembles it is more likely to win the reservation.
Large booking platforms such as Booking and Expedia remain a major source of business for chains including Marriott and Hilton. These platforms also sell rooms through partner websites, which extends their reach and earns them revenue on each booking a partner makes. San Francisco's lawsuit says Booking supplies rooms to Guest Reservations this way, through Priceline Partner Solutions, and alleges Booking knows about the deceptive practices but continues to profit from them. Because the rooms and confirmations are real, guests often do not notice a problem until they try to change or cancel.
We searched for the UK hotel chain’s name from ten countries where it has no hotels. Of the ~490 sponsored ads that appeared, ~435 were placed by booking platforms such as Booking.com, Expedia and Agoda.
How the alleged hotel impersonation works
The alleged process typically follows five steps:
Search advertising. The sites run Google and other search ads so they appear at the top of results for a specific hotel, often above the hotel's own listing.
Lookalike booking pages. The landing pages replicate authentic hotel booking portals. URLs follow patterns such as "hotelname.bookonline.com", placing the hotel's name in the address bar, and any third-party disclosure appears in small print.
Local phone numbers. Sites may list a number with an area code local to the property. The city alleges that some call agents do not disclose that they work for a third-party booking site.
Upfront, nonrefundable payment. Reservations generally require full payment at booking, are often nonrefundable and cost 35% to 85% more than booking direct.
Delayed discovery. Many travellers learn they used a third party only when they try to change or cancel and the hotel tells them the booking was made elsewhere, or when they notice the confirmation email did not come from the hotel.
The same infrastructure, including phone numbers, search placement and lookalike pages, is used in fake customer support scams, where it targets refund requests rather than new bookings.
The Cost of Losing Direct Customer Relationships
These bookings rarely register as fraud. The room is real and the guest arrives, so to the hotel it can look like ordinary third-party business. However, guests may pay up to 85% more than the hotel's own rate, and the markup goes to the reseller. When guests find out, the complaints, refund requests and bad reviews go to the hotel.
The same pattern appears outside travel. After fake sites bought top Google placement for Jones Road Beauty's name, its customer service team received hundreds of tickets from confused buyers during peak sales periods.
Regulators are responding, but slowly. The FTC’s Impersonation Rule carries civil penalties of up to US $53,088 per violation, yet San Francisco says the sites in its case have operated since around 2022.
What this means for brands
A reseller can have every right to sell a hotel's rooms and still have no right to present itself as the hotel. Brand protection built around counterfeits and unauthorised sellers misses that distinction. Brands should:
Monitor brand search results. Track who advertises on your name, what they claim and where each click leads.
Judge sellers by how they present themselves. A partner using your name, logo or a lookalike web address to suggest it is you is a risk, wherever its inventory comes from.
Check lookalike web addresses and phone numbers. Flag subdomains and numbers that use your name but do not belong to you.
Link customer complaints to monitoring. Complaints about rates or terms you never offered are often the first sign of impersonation.
Keep dated evidence. Ads and landing pages change quickly, and records support escalation to platforms, partners and regulators.
Bottom line
Real rooms sold through search ads and lookalike booking pages can take customers, revenue and goodwill from the brand being imitated. Enforcement takes years, so brands that monitor their name across search, domains, phone numbers and partner channels are in a position to act much sooner.
