Abstract: About two years ago, at the urging of child advocates, the Federal Trade Commission (FTC) spearheaded a crusade to protect children from exploitation by television advertising. The FTC staff proposed rules that would have resulted in a ban of most children’s television advertising. The FTC primarily premised its far-reaching rulemaking proceeding on “unfairness,” a standard with few legal precedents, rather than on “deception,” a well-established standard with more confining limits. Like a true believer, Michael Pertschuk, the chairman of the Commission, led his followers into battle: “Setting legal theory aside, the truth is that we’ve been drawn into this issue” because of the “conviction” that “children’s advertising is inherently unfair.”