We have a legal team that gives us constant advice. I'm not losing sleep over the FTC in any way. I think if it were as serious as some people like to make it out to be, you wouldn't be seeing a QuiBids commercial on every other channel you flip to.
no disrespect intended but you couldn't be more wrong. they love giving people lots of rope to hang themselves with.
The only thing I can see the FTC doing at the moment is trying to label Penny Auctions as gambling. That won't happen over night.
No, they are going to say that Penny Auctions sites have 'implied', or in the case of your shadier affiliates 'guaranteed', lower prices on items. I'm pretty sure that the hammer is going to come down and its only a matter of when.
Good luck though, I'm definitely not trying to be a downer, just calling it as I see it.