No, that is not Kate Upton. It's actually Charlotte McKinney. Carl's Jr. is all about risky ads, but the whole ad is not what you think it is.

Model Charlotte McKinney appears to be walking around naked but she is not actually. She is just wearing a small bikini top and bottoms. It shows people looking at her as she strolls through the city looking hot with her burger.

We all remember that Paris Hilton ad that Carl's Jr. aired a while back. This video won't be shown during the Super Bowl because it is too much for the viewing audience.