One of the most fascinating/saddest/stupidest experiences of my life was seeing how an FTC consent order was drafted (by someone who didn’t know what they were doing), and then how even that person didn’t understand what it said. Not surprisingly, it was not effective!
If there's one thing I've learned from publishing this story is that there is a very, very, very wide chasm between what the law says about all this... and what people *think* the law says and/or *should* say.