So, it's a prequel to a bigger con?

The interior illustration for the NYT's review of Jeffrey Toobin's new book on the Supreme Court, The Nine:

The MPAA has gone after unauthorized uses of its rating systems in expressive works before, sending cease & desist letters to fan fiction sites, for example. But will it challenge the No Longer Gray Lady? And, more important, what the heck did Toobin find out that justifies an R rating?