No, they just mention his words. They do not endorse or oppose the candidate. Under CFR, its perfectly legal. And THAT's what gives it such punch is it doesn't look or sound like a typical political ad at all.
I just went back and listened again, and several of them mention him by name directly. As I understand it, the standard is no longer an endorsement or opposition, but just even referring to a candidate in a way that identifies him/her, it doesn't have to even be by name.
It's primarily personal.
ABK = Anyone But Kerry.
Payback time.
You need to look at the FEC FAW page on the CFR law. They indicate that express support or opposition is not required to be in violation. If the purpose of the ad is to oppose a candidate, and that candidate is in any way identified, the ad would be in violation of the law, as interpreted by the FEC.