Substantiation "Specific Factual Basis" claim The claim includes an explicit or implied specific factual basis for a claim Scientific evidence equal to the claim must exist. "clinical studies prove" "Reasonable Basis" claim The claim does not express or imply a specific factual basis, but does express or imply that the claim is supported by objective proof. Evidence that will satisfy a "reasonably prudent business person" must exist. "our hairspray lasts longer than the most popular brands" "Puffing" A claim of overall superiority that is (1) not capable of objective measurement, and (2) a reasonable consumer would not interpret it as an objective claim. NO substantiation required. "this is the best hairspray in the world."