I'm not experienced in this area, but I think the idea is that you shouldn't post the game on your website or someone else's website to gather feedback. So, I would directly ask anyone and everyone that you know(in real life or online) that fits into your target market. I personally believe that requesting feedback is something best done on a more intimate setting anyway, which fits well with their suggestion.
Since they allow you to submit a video for your game directly from youtube, I believe it's ok to provide people with gameplay footage and screenshots without having to worry too much about controlling how many people see them, so feedback based on those is much less restricted.
When it comes to play testing, though, I think you simply shouldn't post your game online. Just do it in a face-to-face fashion (which is a better way to gather info about how people respond to playing your game anyway), and you should be good with the 100 testers restriction.
That said, I think the best place to ask is the FGL boards themselves, or maybe via email to the FGL staff.
I've already gotten all the feedback I can from family and friends, which isn't much. Almost no one in my family are gamers, and while nearly all my friends are, this type of game isn't their cup of tea. I'd love to do face-to-face playtesting, but outside of a booth at a con which I can't afford, I have no idea how I'd do that. My experience with my Ludum Dare game was that I didn't get meaningful feedback until nearly 1,000 views, which is quite a bit more than 100.
I did think to ask on the FGL.com forums, but none of the forums there seem remotely applicable, and moreover there's almost no one /on/ the forums there.
Seems a bizarre suggestion to me. I've not seen positive publicity before a game release affect it's ability to sell. Even to sponsors, which the company I work for deals with regularly. Including FGL.
If you've got a good game, why hide it unless it's meant to be a mystery?
It's a bit baffling to me as well, and I would love nothing more than to be able to solicit feedback from as many people as I can. I just don't want to lose all ability to monetize to do so.
From the FGL.com Developer's FAQ:
"But there's a catch: Flash games lose most of their value to sponsors if they have already been exposed to the public. So make sure you don't reveal your game to the public before it is sold! An exposed game is worth very little to sponsors and we probably won't be able to sell it. For example, don't place your game on Newgrounds or Kongregate before you complete the bidding. You can get valuable feedback there, but the cost may be the ability to sell your game at all!
To work around this problem, FGL developers give each other feedback on their games. We also have a new system called the Preview Players program, where game-players sign an NDA to play games and give you feedback. Finally, we have a for-pay service called First Impressions where random users play your game for a few minutes and give you their first impressions. All of these options help you play-test your game without risking overexposure to the general internet. (Of course, if you have a private list of people who can test for you, that works too! Just make sure that the game doesn't leak out.)"
I don't have the money to pay for any substantial use of First Impressions, and I'd like to get feedback from more than just random Flash game devs (especially because I'm approaching the development more like a traditional indie game, I've spent more than a year on it).
If you have any more experience/info to share, I'd love to hear it, because I'm not very satisfied with things as they appear.