The One-Star Attack: Compensation Claims for Fake Reviews and Competitor Smear Campaigns in Turkish E-Commerce

For an e-commerce business, a customer review can have a direct economic value.

A seller with thousands of positive reviews may appear at the top of marketplace results, achieve higher conversion rates and generate millions of Turkish lira in monthly sales. A sudden wave of one-star reviews can reverse that position within days.

The problem becomes considerably more serious when those reviews are not written by genuine dissatisfied customers.

Imagine that a competing seller creates multiple customer accounts and begins posting comments such as:

“The products are counterfeit.”

“Do not buy from this company. They are scammers.”

“They sent a used product instead of a new one.”

“This company does not issue invoices.”

“Their products are dangerous.”

The competitor may also purchase inexpensive items simply to obtain “verified purchase” status and then use those accounts to attack the seller’s reputation.

Alternatively, a marketing agency may be paid to create dozens of artificial accounts and simultaneously publish positive reviews for one business and negative reviews for its competitors.

Under Turkish law, this conduct may amount to considerably more than unethical digital marketing.

Depending on the circumstances, it can constitute unfair competition, a tort, an infringement of commercial reputation, a misleading commercial practice and potentially even a criminally punishable act of unfair competition.

For the injured business, the available remedies may include:

• removal of the reviews;
• prohibition of further publications;
• correction of false statements;
• interim injunctions;
• compensation for financial losses;
• non-pecuniary damages;
• publication of the court judgment; and
• in appropriate circumstances, a criminal complaint.

The central legal issue, however, is distinguishing legitimate consumer criticism from an organised commercial smear campaign.

1. Negative Reviews Are Not Automatically Unlawful

A business cannot demand compensation merely because a customer gave it one star.

Consumers are generally entitled to describe genuine experiences and express opinions about goods and services.

For example, statements such as:

“Delivery took twelve days.”

“I did not like the quality.”

“Customer service did not solve my problem.”

or

“I think the product is too expensive for its quality.”

may constitute legitimate consumer criticism if they are based on a genuine experience.

Turkish courts also recognise the importance of freedom of expression when assessing statements alleged to constitute unfair competition. Courts examine the context of the statement and do not automatically classify every negative or uncomfortable comment about a commercial activity as unlawful disparagement.

The situation changes where the reviewer:

• was never a customer;
• invents an experience that never happened;
• knowingly publishes false factual allegations;
• acts on behalf of a competitor;
• uses multiple artificial accounts;
• coordinates reviews with other users;
• exaggerates genuine facts in a deliberately misleading manner; or
• uses unnecessarily damaging statements designed primarily to destroy commercial reputation.

The distinction is important because Turkish Commercial Code No. 6102 specifically regulates this form of conduct.

2. Competitor Smear Campaigns Can Constitute Unfair Competition

Article 54 of the Turkish Commercial Code establishes the general framework for unfair competition.

Its purpose is to protect honest and undistorted competition in the interests of all market participants.

Article 55 then identifies common forms of unfair competition.

One of the most important provisions for fake-review cases is Article 55/1-a-1.

It treats as unfair competition the disparagement of another person, or that person’s goods, work products, prices, activities or commercial affairs, through statements that are:

false, misleading or unnecessarily offensive.

This provision fits many online review attacks remarkably well.

Suppose Seller A sells electronic products on an online marketplace.

Seller B asks five employees to purchase low-value items from Seller A. After delivery, those employees publish comments claiming:

“They sell counterfeit goods. Stay away.”

Seller B then uses screenshots of those comments in advertisements suggesting that Seller A is unreliable.

If the allegations are false and the objective is to redirect customers toward Seller B, the conduct may fall squarely within the unfair competition provisions.

3. The Person Posting the Review Does Not Even Have to Be a Direct Competitor

An important feature of Turkish unfair competition law is that the claimant and defendant do not necessarily have to be direct competitors.

The purpose of the legislation is broader than protecting only two companies selling identical products.

Turkish case law and legal doctrine recognise that unfair competition may arise whenever dishonest conduct affects the competitive process. A person does not necessarily have to be a merchant or operate in exactly the same market as the injured business.

This can become important where fake reviews are produced by:

• employees of a competitor;
• marketing agencies;
• influencers;
• former employees;
• relatives of a competitor;
• paid freelancers; or
• organised reputation-management companies.

A company should therefore investigate who actually organised the campaign rather than focusing only on the username appearing next to the review.

4. False Reviews and “Unnecessarily Offensive” Reviews Are Different

Article 55 is particularly useful because a statement does not necessarily have to be completely fabricated before it can become unlawful.

There are three alternative categories:

False Statements

These are factually untrue allegations.

For example:

“The company sells fake Nike products”

where the seller can establish that all goods were purchased from the authorised distributor.

Misleading Statements

The statement may contain an element of truth but create an inaccurate overall impression.

Suppose one customer’s shipment was delayed because of a national courier strike.

A competitor posts:

“This seller never delivers orders on time.”

The underlying event may have occurred, but the generalisation may create a misleading commercial impression.

Unnecessarily Offensive Statements

A statement may sometimes relate to a real event but be expressed in a manner that exceeds what is reasonably necessary to communicate the criticism.

Turkish judicial practice treats unnecessarily damaging commercial statements as capable of constituting unfair competition even where the underlying issue is not entirely fictional.

The legal assessment therefore considers not only:

“Is the statement technically true?”

but also:

“What commercial impression does it create, and was that manner of publication necessary?”

5. Recent Court of Cassation Practice Shows That Online Disparagement Can Lead to Compensation

Online commercial disparagement is not a purely theoretical category.

In Court of Cassation 11th Civil Chamber, E. 2024/977, K. 2025/206, the dispute included statements published on a commercial website attacking another business and its products.

The underlying court concluded that expressions used against the competing company constituted disparagement within the unfair competition framework and awarded both material and non-pecuniary compensation. The appellate process upheld the essential unfair competition assessment.

The importance of the case is broader than the particular language used.

It demonstrates that statements published online about a competing business may generate:

commercial liability + reputational liability + monetary compensation.

The internet is not a legal immunity zone merely because the damaging statement appears as text on a webpage, marketplace profile or review system.

6. Turkish Consumer Law Now Contains Specific Rules Against Fake Reviews

The regulatory framework became even more significant following amendments to the Commercial Advertising and Unfair Commercial Practices Regulation.

As of the rules currently applicable in August 2026, Article 28/B specifically regulates online consumer reviews.

Where a seller, provider or marketplace allows consumers to review a product, service or seller, reviews may generally be submitted only by persons who actually purchased the relevant product or service.

The 2026 amendments go further: consumer reviews obtained from sources where the purchasing process cannot be verified cannot be published in the relevant framework.

This is particularly important for marketplaces.

A platform cannot design a review environment where anyone can simply pretend to have purchased a product and present the statement to consumers as a genuine customer review.

7. Businesses Cannot Buy Fake Positive Reviews Either

The rules operate in both directions.

A company that is itself the victim of fake negative reviews should ensure that its own marketing practices are clean.

Article 28/B expressly prohibits entering into agreements with natural or legal persons, or purchasing services, for the purpose of creating untrue reviews or endorsements designed to increase sales.

Therefore, the following practice is legally dangerous:

“We will create 500 verified five-star reviews for your Amazon, Trendyol and Google profiles for TRY 50,000.”

The business purchasing the service may not escape responsibility simply because an external agency physically created the accounts.

A fake-review agency can therefore create a double risk:

it may artificially improve its client’s rating while simultaneously damaging competitors.

Both sides of the scheme should be investigated.

8. Review Platforms Also Have New Obligations

The rules are particularly relevant to websites whose principal activity is publishing consumer complaints.

Under Article 28/C of the Regulation, dedicated complaint platforms must give the business concerned an opportunity to respond before publication.

Following the amendments effective from 1 August 2026, the response period is 48 hours.

The regulation also provides that a complaint should not be published where it is established that the allegation does not reflect reality.

This does not give businesses a right to suppress genuine criticism.

Indeed, the opposite is also true.

On 19 August 2026, the Ministry of Trade announced an administrative fine against a company for unjustifiably refusing to publish a genuine consumer review. The Advertising Board treated arbitrary suppression of consumer comments as an unfair commercial practice.

The regulatory principle is therefore balanced:

genuine reviews should not be censored, but fabricated reviews should not be treated as genuine consumer experience.

9. Can the Injured Company Demand Removal of the Fake Reviews?

Yes.

Article 56 of the Turkish Commercial Code provides several civil remedies to a person whose customers, credit, professional reputation, commercial activities or other economic interests are harmed or threatened by unfair competition.

The claimant may request:

1. a declaration that the conduct constitutes unfair competition;
2. cessation or prevention of the unfair competition;
3. elimination of the situation created by the unfair competition;
4. correction of false or misleading statements;
5. material compensation where fault exists; and
6. non-pecuniary compensation where the applicable requirements are satisfied.

This means that a lawsuit does not need to be structured solely as:

“Pay me damages.”

In many online-review cases, stopping the continuing reputational damage may be more commercially important than compensation.

The claimant can therefore seek an order requiring the wrongful conduct to cease and the false information to be corrected.

10. An Interim Injunction May Be More Valuable Than the Final Judgment

E-commerce moves much faster than litigation.

A false review posted today may influence thousands of customers before a final judgment is issued.

Suppose a seller normally generates TRY 10 million of monthly marketplace revenue.

A coordinated fake-review campaign reduces its rating from 4.8 to 3.5 and causes sales to collapse during the most important commercial season of the year.

Waiting until the conclusion of a multi-stage lawsuit may not adequately protect the business.

Article 61 of the Turkish Commercial Code therefore permits interim measures in unfair competition disputes.

Depending on the facts, the court may order measures directed at:

• preserving the current position;
• preventing continuation of the unfair competition;
• eliminating its consequences;
• correcting false or misleading statements; or
• taking another measure appropriate to the circumstances.

For digital disputes, an injunction request may seek temporary removal or disabling of specific content while the underlying claim is determined.

However, the claimant must present convincing initial evidence.

A bare assertion that:

“These reviews must have been written by my competitor”

will rarely be sufficient.

11. Evidence Should Be Preserved Before the Reviews Disappear

Evidence preservation is often the decisive part of a fake-review case.

The defendant may delete the accounts as soon as a legal notice is received.

The company should therefore preserve:

• screenshots showing the full review;
• URL or marketplace listing;
• username;
• publication date;
• star rating;
• product involved;
• seller profile;
• replies;
• account information visible to the public;
• identical or similar reviews on other websites; and
• changes in the overall seller rating.

For significant disputes, simple screenshots may not be enough.

Consideration should be given to stronger methods of establishing electronic evidence and, where necessary, a determination of evidence procedure before substantial changes occur.

The seller should also preserve its own internal records showing whether the alleged customer actually purchased the product.

12. Marketplace Data Can Reveal an Organised Campaign

Many fake-review cases initially appear anonymous.

Five different usernames may seem unrelated.

But platform records may show that the accounts:

• used the same IP address;
• used the same device;
• were created on the same day;
• used related telephone numbers;
• used the same payment method;
• ordered products to the same address;
• were connected to employees of a competitor; or
• displayed identical behavioural patterns.

The injured company may not be able to obtain all such information directly because of data-protection rules.

However, relevant records can potentially be requested through judicial proceedings where the legal conditions are satisfied.

The litigation strategy should therefore consider not merely the visible comments but the technical architecture behind the accounts.

13. Timing Can Be Powerful Evidence

Consider this pattern:

A business maintains a rating between 4.7 and 4.9 for three years.

It launches a new product competing directly with Seller B.

Within four days:

• 18 new one-star reviews appear;
• 14 use almost identical language;
• several accounts were recently created;
• all accuse the seller of selling counterfeit goods;
• Seller B launches advertising claiming that competitors sell fake products; and
• the reviews disappear shortly after legal notices are sent.

No single fact necessarily proves the campaign.

Together, however, they can create a compelling evidentiary picture.

Digital unfair competition cases are frequently established through the combination of many apparently minor indicators.

14. How Can Financial Damage Be Calculated?

Proving that a review is fake does not automatically prove the amount of compensation.

This is where many otherwise strong cases become weak.

The claimant should demonstrate the economic consequences of the campaign.

Potential evidence may include:

• monthly sales before and after publication;
• daily sales during the affected period;
• marketplace conversion rates;
• product-page traffic;
• advertising conversion rates;
• customer-acquisition costs;
• cancelled orders;
• ranking changes;
• Buy Box losses;
• decline in repeat purchases;
• lost commercial contracts;
• additional advertising costs required to restore reputation; and
• loss of marketplace visibility.

An accounting and digital-commerce expert may be required.

15. Lost Turnover Is Not the Same as Lost Profit

Suppose sales decline by TRY 5 million after the fake-review campaign.

The company cannot necessarily claim the entire TRY 5 million as damages.

Turnover must be distinguished from actual economic loss.

The analysis may need to consider:

• cost of products;
• commissions;
• shipping;
• advertising expenses;
• returns;
• taxes where applicable;
• variable operating expenses; and
• costs the seller avoided because the transactions did not occur.

The objective is to identify the economic position the claimant would probably have occupied if the unlawful campaign had not occurred.

A well-prepared expert damages model can therefore be as important as proof that the reviews were fabricated.

16. Causation Is Often the Hardest Part of the Case

An instructive Turkish commercial court dispute involved disparaging social-media statements that were found capable of constituting unfair competition.

The expert assessment nevertheless distinguished between the unlawful nature of the statements and proof of monetary loss. Because negative publicity concerning the claimant already existed from other sources, it was difficult to establish that the alleged customer losses resulted specifically from the defendant’s statements.

This illustrates a central principle:

unfair competition and compensation are not identical questions.

For declaration and cessation of unfair competition, proof of actual financial loss is not necessarily required.

For material compensation, however, causation becomes crucial.

The claimant must connect:

the fake reviews → deterioration of commercial position → measurable financial loss.

17. Turkish Law Provides an Alternative Method of Calculating Compensation

Article 56 contains an especially useful rule for cases where the claimant’s exact loss is difficult to calculate.

When awarding compensation, the court may, in appropriate circumstances, take into account the benefit that the defendant could have obtained as a result of the unfair competition.

This may become relevant where a competitor’s direct objective was to redirect customers.

For example:

Seller A’s rating falls substantially following the campaign.

During the same period, Seller B’s sales increase dramatically for the same products.

If the connection between those developments is established, the defendant’s commercial benefit may become relevant to the damages analysis.

18. Can a Company Claim Non-Pecuniary Damages for Damage to Its Reputation?

Potentially, yes.

Article 56 expressly refers to non-pecuniary compensation where the requirements of Article 58 of the Turkish Code of Obligations are satisfied.

Article 58 permits compensation where personality rights have been unlawfully infringed and also allows the court to order other appropriate forms of redress, including publication of a judgment condemning the wrongful conduct.

Commercial reputation can have enormous economic significance for a legal entity.

Allegations such as:

“fraudulent company,”

“counterfeit seller,”

or

“they steal customer money”

can therefore create issues extending beyond immediate lost sales.

The precise availability and amount of non-pecuniary compensation will depend on the seriousness, reach and circumstances of the attack.

19. The Judgment Can Be Published

Sometimes money alone does not repair reputational damage.

Article 59 of the Turkish Commercial Code allows the successful claimant to request publication of the final judgment at the defendant’s expense. The court determines the form and scope of publication.

This can be particularly valuable where a false allegation was widely distributed.

For example, if a competitor publicly accused another company of selling counterfeit products, a court ruling confirming that the allegation constituted unfair competition may have independent reputational value.

20. Can the Marketplace Itself Be Sued?

The platform’s position requires a more nuanced analysis.

A marketplace does not automatically become financially liable merely because a user publishes an unlawful comment.

Turkish legislation provides various protections for intermediary and technology providers, particularly where they did not create, select or modify the unlawful content.

Article 58 of the Turkish Commercial Code contains specific provisions concerning unfair competition conducted through media, communication and information technology organisations.

Where the intermediary did not initiate transmission, select the recipient, select the content or modify it in a way that created the infringement, the statute limits direct claims against the service provider.

However, where the consequences of the unfair competition are extensive or the potential damage is significant, the court may, after hearing the provider, order measures directed at stopping the unlawful activity, including temporary removal of the content.

Therefore, there is an important distinction between:

holding the platform liable for damages, and

obtaining an order requiring the platform to remove unlawful content.

The second may sometimes be easier to justify than the first.

21. Marketplaces Also Have Independent Review-System Obligations

Even where the platform did not personally write the review, current consumer rules create independent obligations concerning how review systems are operated.

As of August 2026, a marketplace permitting product or seller reviews must generally ensure that reviews are linked to actual purchasers, and reviews imported from environments where the purchase process cannot be verified are restricted.

Therefore, if a marketplace knowingly operates a system that represents completely unverified comments as authenticated customer experiences, regulatory questions may arise independently from the competitor’s civil liability.

A business seeking removal should therefore notify the platform with concrete evidence:

• the reviewer’s claimed order does not exist;
• the factual allegation is demonstrably false;
• the account appears linked to a competitor;
• identical comments appear across several accounts; or
• documentary evidence disproves the allegation.

A detailed legal notice is more effective than simply clicking:

“Report review.”

22. What If the Competitor Uses Its Employees or a Marketing Agency?

Using intermediaries does not necessarily insulate the business that organised the campaign.

Article 57 of the Turkish Commercial Code specifically regulates unfair competition committed by employees or workers while carrying out their duties and permits certain actions to be brought against the employer as well.

General principles of the Turkish Code of Obligations may also become relevant to compensation.

Accordingly, a company cannot necessarily defend itself by saying:

“Our marketing manager created those accounts without the CEO personally writing any review.”

The investigation should examine:

• who instructed the employees;
• whether company devices were used;
• whether management knew;
• whether an external agency was paid;
• whether invoices describe “reputation management” services;
• whether scripts were supplied by the competitor; and
• who ultimately benefited from the campaign.

23. Could Fake Review Activity Also Lead to Criminal Proceedings?

Possibly.

Article 62 of the Turkish Commercial Code establishes criminal consequences for certain intentional acts of unfair competition.

A person intentionally committing one of the unfair competition acts specified in Article 55 may, upon complaint by a person entitled to bring the relevant civil proceedings and unless the act constitutes a more serious offence, face up to two years’ imprisonment or a judicial fine.

This does not mean that every one-star review is a criminal offence.

Intent is required for the criminal provision.

But an organised scheme in which a competitor deliberately creates false customer accounts and knowingly publishes fabricated allegations to damage a competing business may require assessment under Article 62 in addition to civil remedies.

Depending on the content and method used, other criminal-law provisions could also become relevant in particular cases.

24. Do Not Miss the Limitation Period

Unfair competition claims have relatively short limitation periods.

Under Article 60 of the Turkish Commercial Code, the claims listed in Article 56 generally become time-barred:

one year after the claimant becomes aware of the right giving rise to the claim, and

in any event three years after the right arises.

If the conduct also constitutes a criminal offence subject to a longer limitation period, that longer period may apply to the civil claim as provided by the statute.

For businesses facing an ongoing review attack, delay is therefore dangerous both commercially and procedurally.

25. Which Court Should Hear the Case?

Because claims based on Articles 54–63 arise directly from the Turkish Commercial Code, unfair competition disputes are generally commercial cases.

The competent court will ordinarily be the Commercial Court of First Instance, subject to the specific jurisdictional circumstances of the dispute.

Where monetary compensation is sought in a commercial dispute, mandatory mediation requirements should also be considered before filing the compensation claim.

However, urgent interim protection should be evaluated separately where the fake reviews remain online and continue causing damage.

The litigation structure therefore needs to be planned rather than simply filing a damages claim immediately.

26. A Practical Legal Strategy for a Business Under Review Attack

Consider the following scenario.

A cosmetic-products seller has operated on a major marketplace for four years.

Its average rating is 4.8.

After a former distributor establishes a competing company, twenty-three one-star reviews appear within ten days.

The reviews repeatedly state:

“Fake products. Do not buy.”

The seller’s invoices establish that every product originates from the official European manufacturer.

Marketplace sales fall by 35%.

What should the company do?

Step 1 — Preserve Every Review

Do this before contacting the suspected competitor.

Step 2 — Preserve Sales and Analytics Data

Record ratings, rankings, conversion rates and turnover immediately.

Step 3 — Compare Review Accounts

Look for repeated wording, dates, purchasing behaviour and other relationships.

Step 4 — Verify Purchases

Determine whether the alleged reviewers actually purchased the products they claim to have used.

Step 5 — Notify the Marketplace

Submit a reasoned request supported by documents and expressly identify the suspected fabricated-review campaign.

Step 6 — Preserve the Competitor Connection

Collect public information concerning employees, addresses, telephone numbers, social media accounts and other legally obtainable links.

Step 7 — Send a Formal Notice

Demand termination of the unfair competition, removal or correction of the false allegations and preservation of evidence.

Step 8 — Consider an Interim Injunction

If continuing publication creates serious commercial harm, seek urgent judicial protection where the statutory conditions are met.

Step 9 — Calculate the Damage

Use historical commercial data rather than arbitrary numbers.

Step 10 — Pursue the Appropriate Civil and, Where Justified, Criminal Remedies

The final claim may combine cessation, correction, compensation and publication of the judgment.

27. What Makes a Fake-Review Case Particularly Strong?

A strong case generally does not depend on a single screenshot.

The most persuasive cases combine several forms of evidence:

Proof of falsity

For example, the review claims no invoice was issued while the invoice and electronic invoice records are available.

Proof that the reviewer was not a genuine customer

The platform has no matching order.

Proof connecting the reviewer to the competitor

Employment, corporate, technical or communication evidence.

Evidence of coordination

Multiple reviews use the same unusual expressions or appear within a short period.

Commercial motive

The reviews coincide with a product launch or competitive campaign.

Measurable financial effect

Sales, conversion rates or rankings decline immediately following publication.

Conduct after notification

The defendant deletes accounts or repeats the allegations despite receiving documentary proof that they are false.

The case becomes considerably stronger when these elements support one another.

28. A Common Mistake: Suing Only for an Arbitrary Amount

Businesses frequently approach these cases by saying:

“My reputation was destroyed. I want TRY 10 million.”

That is not an effective damages methodology.

A more persuasive claim explains:

• what the business sold before the campaign;
• what changed after publication;
• how long the impact lasted;
• which customers were lost;
• which ranking positions changed;
• which additional costs were incurred; and
• why those developments are economically connected to the unlawful conduct.

The objective is not merely to show that the defendant behaved badly.

It is to translate digital misconduct into legally provable economic damage.

Conclusion: Fake Reviews Are Not Just a Reputation Problem — They Can Be a Compensable Act of Unfair Competition

Consumer reviews are an essential part of modern e-commerce.

Businesses must tolerate genuine criticism, including criticism they consider unfair or unpleasant.

But freedom to review does not include a right for competitors to fabricate customers, manufacture false experiences and intentionally manipulate marketplace reputation.

Turkish law provides a strong framework against such conduct.

Under Article 55 of the Turkish Commercial Code, false, misleading or unnecessarily offensive statements disparaging another business, its products or commercial activity may constitute unfair competition.

Article 56 then gives the injured company a substantial range of remedies, including:

declaration, cessation, removal of consequences, correction, material compensation and, where the legal conditions exist, non-pecuniary damages.

Current consumer legislation adds another layer of protection. Online review systems are now subject to specific verification requirements, and purchasing fabricated reviews to manipulate sales is expressly prohibited.

The practical question for a business should therefore not merely be:

“How can I delete this one-star review?”

It should be:

“Who created these reviews, are they genuine customers, can I prove that the allegations are false, is there evidence connecting them to a competitor, and how much measurable commercial damage did the campaign cause?”

Once those questions are answered, what initially appears to be a collection of anonymous online comments may instead reveal an organised act of unfair competition capable of supporting a substantial commercial claim.

For e-commerce businesses, the most valuable response is usually rapid and evidence-driven:

preserve first, investigate second, stop the continuing damage third, and calculate compensation with commercial data rather than assumptions.