"Every appearance is they've broken the law"
Right, but only if the FCC sees it as such, and probably depending on the number of complaints if they choose to take any 'legal' actions. The ATSC term "Recommended Practice" is a gray area as well. "The goal of the CALM Act is to eliminate, or at least discourage, 'loud commercials' by implementation of the RP"
What does this mean? CBS and the other deep pocket networks as well as the TV ad industry have lobbyists down on K Street with plenty of cash to hand out before or after 'problems' arise.