Legal Question in Business Law in Massachusetts
I am about to launch a travel website that generates income through advertising and will be primarily marketed to young people within the United States. As part of our marketing plan we are planning on offering internships in all majors cities within the US to help with promotion. The internships we would be offering would be very short (we are estimating they could vary from 20-80 hours total) and will mainly consist of talking to local news outlets, contacting local college organizations, getting involved in local events and flyer distribution. We think it could be a valuable learning experience for college students and could be a way for them to improve their resume. We are also considering offering a bonus to interns that are successful in getting a press release published in a local newspaper, establishing a presence at a local event etc. Our business is an LLC based out of Massachusetts but as I said the site is targeting people in all areas of the US so we must market it around the country. We would not be able to meet with most of the interns directly so we would only be communicating with them through email and phone interviews. We are a new company and simply do not have enough money to pay an hourly wage to all these interns and we are not established enough to be able to offer college tuition. I know that Intern laws may vary state by state but we are not sure of the legal implications of having many interns working for us simultaneously throughout the country. At first glance does there appear to be any serious legal considerations we are over looking? Would there be a better way to structure this program? Any thoughts or advice is greatly appreciated.
1 Answer from Attorneys
It is possible but difficult to tailor an unpaid position in Massachusetts to be consistent with the law. There are several factors, but ultimately you must limit: time (and length of service), duties, and the work must be directed at their development and not yours. This is not a complete answer, but I'd be happy to discuss it further.