Try actually reading your Google hits instead of just counting them Of the 114 unique hits for aluminum underwear 79 have nothing to do with shoplifting 28 directly concern the Colorado law and only seven generally concern shoplifting not specifically in reference to the Colorado law Of the 35 unique hits for aluminum underpants 18 have nothing to do with shoplifting 17 reference the Colorado law and zero reference shoplifting in general It is obvious from these Google results that the use of the phrase in either form did gain some popularity surrounding the passage of the Colorado law but disappeared shortly thereafter and did not fall into the general vernacular Either form is therefore not ubiquitous and is inappropriate for this section title