Yeah, but it has also been proven that using those 'flex toning' muscle stimulus pads can help sick patients who can't exercise at all to maintain muscle mass/get some strength back.
In both of the above cases we are talking about subjects who are very weak and ill. They will have minimal strength and we are talking about getting them/keeping them at the point where they can get through the day. The small AS allows their bodies to assimilate more of their food and so slow down wastage. To compare this to an athlete looking for exceptional gains on top of an already strong muscle base is not valid.