This fall, the Federal Trade Commission will begin a series of hearings entitled “Protecting Consumers in the Next Tech-ade,” which intends to explore the issue of whether the use of viral videos by marketers constitutes advertising.

Over the past year, the increasing popularity of do-it-yourself video sites like YouTube and the growth of ad-skipping technologies such as Tivo, have inspired some ad agencies and marketers to look to viral video as a stealth marketing tool. Aside from serving as an avenue to reach ad-avoiding consumers, by posting a clip to such a site, companies have the ability to better track its audience as well as steer clear of regulations that currently govern commercials.

So far, the Internet Advertising Bureau has broadband ad creative guidelines at its site, but nothing on the use of viral videos.

The problem is that, like video news releases, such tactics tend to blur ethical lines when seeking to reach out to consumers. Furthermore, the move can provoke an unintended backlash as most video sites contain a comments area where watchdogs can slam a video as a commercial. Therefore, what may begin as a wondrous creative solution for marketers could end in a public relations headache.