Spider-Man stuff is only starting to hit now, and that movie's got a Memorial Day release... so yeah

 

as if DW/Paramount would NOT market this movie

Spidey has a May 4 release, Pirates has a May 25, which I believe is Memorial Day Weekend.

Well there you go. Merchandise for SM3 officially hit yesterday, and that's like six or seven weeks prior to the film's opening. Transformers won't be out until two months after that point. And I don't recall seeing any TV spots for SM3 yet -- heck, we only just recently got the final trailer. I'm sure that the people responsible for these things do market research and what not to determine the most effective "drop point" for the advertising/merchandising blitz. (And I'm also sure that the existence of other similar-demographic movies affects these things as well. Putting out TF stuff now would be a bad idea because Spider-Man is getting the limelight now. After that movie is released, *then* the TF stuff can appear without fear of being overlooked.)

Who was it that said there was only 20 minutes of action?

There are 12 action scenes... Divide that into twenty and each action scene would be less than a minute, strange movie.