This is not a vague technicality, though? The FTC has to obey the law, and the law says that if they make a new rule that has more than $100M of direct monetary

This is not a vague technicality, though? The FTC has to obey the law, and the law says that if they make a new rule that has more than $100M of direct monetary impact, they have to use a more involved process. They originally tried to waive this by saying that the rule doesn't have more than $100M impact, but that's just clearly false. It's not a good thing to cheer rules being broken when you like the reason.