Correct. The "rules" are just guideposts. Campbell is essentially the FTC saying what a company should do in order to avoid an enforcement action (for food ad

Correct. The "rules" are just guideposts. Campbell is essentially the FTC saying what a company should do in order to avoid an enforcement action (for food ads). You don't need to follow the rules set forth in Campbell, but then you run the risk that if your ad is even the slightest bit deceptive the FTC will come calling with a fine.