If a product is advertised as having a “satisfaction” or “money back” guarantee, then that “constitutes an offer of a full refund for any reason.” 16 C.F.R.
(a) A seller or manufacturer should use the terms “Satisfaction Guarantee,” “Money Back Guarantee,” “Free Trial Offer,” or similar representations in advertising only if the seller or manufacturer, as the case may be, refunds the full purchase price of the advertised product at the purchaser’s request.
(b) An advertisement that mentions a “Satisfaction Guarantee” or a similar representation should disclose, with such clarity and prominence as will be noticed and understood by prospective purchasers, any material limitations or conditions that apply to the “Satisfaction Guarantee” or similar representation.
Often, of course, the refund is contingent on the product being returned. Something to bookmark for the future in case you need to say, “but it’s mandated by federal statute!”. — BEN POPKEN