I don't understand, they did an estimate and found it below 100$ million. That seems to have followed the process. An estimate can always be challenged and is just a best effort prediction. Now it seems this create a pretty flaky ground for precedence that the FTC simply can never estimate less than 100$ million as it could always be challenged in court, what if it was more? And they now have to always follow the more effortful process of assuming it is more than 100$ million.
It really seems like a weird line in the sand that the court will just randomly decide on a case by case now, with the FTC having no way to know if the court will agree with their estimate or not.