(September 18, 2015) -- There is more going on in the Federal Trade Commission’s Section 5 policy statement than initially meets the eye. At first glance the statement appears to have very limited substance. Its concrete guidance is limited to just a few innocuous truisms. But its real significance lies less in its principles than in the vocabulary that it has left for the future. Dueling commissioners have sprinkled the statement with buried code words and magic phrases, which they clearly hope will provide a starting point for their successors to argue for their favored interpretations....