Eric Goldman’s article starts, “In reading the FTC’s new rules on endorsements and testimonials in advertisements, I was struck by the FTC’s expansive vision of advertiser liability for third party-caused violations. In particular, the FTC apparently has made the same analytical error that the SEC recently made in the SEC’s proposal to hold securities issuers liable for third party content they link to. In my comments to the SEC, I explained that trying to hold a linker liable for content at the terminus of a link violates 47 USC 230.