With respect to JuliStarz, where does it indicate that she is a paid spokesperson? According to the ad (as I read it) she simply mentioned a product that she thought helped her lose weight. Just because somebody 'famous' mentions a product doesn't necessarily mean that he or she has been paid for that mention. More than likely she was, but it doesn't say it directly.

I agree with Shawn, make all the "should"'s either "must"'s or "shall"'s, then this might mean something. Another case of our government being here to help us

Edgar replies: 1. For purposes of the hypothetical, the FTC learns that she has been paid, and thus instructs how that should be disclosed in the ad/tweet. 2. The dotcom dislcosures are "guidelines", meaning they do not have the force of law, but rather explain how the agency views these issues should a case come before them. That is why "should" is used rather than "must."