The encyclopedia · Advertising & PR · Marketing decision · 2026
Imoto's WiFi sold 'Satisfaction No.1' — the survey behind it verified no one
'Customer Satisfaction No.1', from a survey that verified no user and compared nine hand-picked rivals. CAA: ¥172.6M surcharge — after a 2024 order.
Excom Global · 2026-03-12
What happened
Imoto's WiFi, the overseas travel rental-WiFi service run by Excom Global, told Japanese travellers it was number one. Its website and two editions of the Chikyū no Arukikata (Globe-Trotter) guidebooks — Indonesia 2020–21 and Germany 2023–24 — carried displays claiming 'Customer Satisfaction No.1', 'No.1 Chosen by Overseas Travelers' and 'Customer Service Satisfaction No.1'. The claims had been running since February 2020. The survey behind them, the Consumer Affairs Agency found, did not verify that any respondent had actually used the services being ranked.
The methodology was thinner still: only nine operators, arbitrarily selected as comparison targets, and respondents were asked about their impressions of websites rather than actual use. The displays also cited the surveys inaccurately. Japan's CAA had already issued a cease-and-desist measure order on 1 March 2024 against the same displays as misleading representations under the Act against Unjustifiable Premiums and Misleading Representations — and the violations continued.
On 12 March 2026 the CAA therefore ordered Excom Global to pay a surcharge of 172,620,000 yen: 3% of the 5,754,289,344 yen in sales recorded between 22 June 2023 and 21 June 2026, payable by 13 October 2026. The displays had run continuously from 12 February 2020 until 7 May 2026 — through the 2024 measure order, which had already mandated that they stop, that consumers be notified, and that recurrence be prevented. The surcharge added the financial penalty to those obligations.
Why it happened
- The 'No.1' survey verified no users: respondents were not screened for having used the services, and only website impressions were asked about.
- Nine hand-picked operators were the entire comparison set — the survey was built to produce the answer the ads needed.
- A 2024 cease-and-desist order on the same displays did not stop them, which converted the case from a warning into a surcharge.
The lesson
A 'No.1' claim is only as solid as the survey behind it: Imoto's WiFi ranked itself first using a survey that verified no users, and paid ¥172.6M in surcharges after repeating it.
Aftermath
The CAA's surcharge order of 12 March 2026 was the second action against the same displays: a cease-and-desist measure order had been issued on 1 March 2024. The surcharge, 172,620,000 yen (3% of the relevant sales), followed the continued use of the No.1 displays after that order; Excom Global's Imoto's WiFi service remains a major provider of rental connectivity for Japanese travellers abroad.
Sources
- ITmedia Mobile: 「イモトのWiFi」運営会社に課徴金1.7億円 根拠ない満足度No.1広告の景表法違反で (12 March 2026)
- Advertimes: 「イモトのWiFi」に1.7億円の課徴金 「満足度No.1」表示、客観的調査に基づかず、2024年にも措置命令 (12 March 2026)
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