This means that the (head) judge could upgrade this penalty. If I had a player who was consistently missing things about the game state during an event and I considered it a significant problem, but I was not ready to DQ the player for Fraud, I would consider upgrading a FtMGS penalty to a Game Loss. Note that this would be unusual, but it would be similar to the suspension of Katsuhiro Mori for accumulated Game Play Errors, as made public here: http://www.wizards.com/Magic/Magazine/Events.aspx….

While we do not want to cause players to believe they will get significant penalties for failing to notice their opponent's mistakes, we do have the option to assess a stiffer penalty when a player is excessively careless about maintaining the game state. It's just the difference between 'never' and 'almost never'. I'd like to note that I have not ever seen this infraction upgraded in my 2+ years as a judge.