Eleven stakeholders filed comments addressing the FTC's rulemaking authority under Section … See more

As described in Section I above, the NPRM proposed to codify the Commission's longstanding interpretation of Section 5's requirements governing substantiation of unqualified … See more

The Commission received several comments arguing the proposed Rule was unclear or provided insufficient guidance for marketers. To remedy these asserted problems, s… See more

Some commenters requested tailored guidance for specific industries. Specifically, representatives of the beef and shrimp industries requested guidance on whether th… See more

Some commenters proposed a series of other amendments, arguing variously that the Rule should preempt state law entirely; [104] cover MUSA advertising generally; [105] make … See more