Charlotte McKinney really is the next Kate Upton!  

We dubbed her such when she came into the FOX411 studios in September, and now the Guess model is indeed following in Upton’s footsteps as the star of a racy Carl’s Jr. Super Bowl commercial.

The 22-year old-stunner is showcased walking around in her birthday suit in the ad, but McKinney told FOX411 it was all done with smoke and mirrors, as she was actually wearing a bikini for the entire shoot.

“I’m used to working in a bikini and the crew made me feel comfortable," she said.

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The blonde bombshell hopes the Carl’s Jr. ad will bring more job opportunities, but as for her constant comparison to Miss Upton, she says “I wish the comparison would stop. I’m my own person. I think we both have a different style of what we’re going to do.” 

“I hope it’s Charlotte McKinney and not the next Kate Upton," the next Kate Upton added.

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Fox Reporter and FOX411 host Diana Falzone covers celebrity news and interviews some of today's top celebrities and newsmakers.  You can follow her on Twitter @dianafalzone.