The 20-year-old actress became embroiled in controversy last week (ends07Aug09) when a new set of explicit photos leaked online - the second lot of snaps to emerge since her 2007 embarrassment.
Cook decided to poke fun at Hudgens as he presented the Choice Hottie prizes by quipping, "Vanessa Hudgens! - Girl, you got to keep your clothes on!.
But his joke didn't go down well with the teens in the audience, who expressed their disapproval at the funnyman by loudly heckling him.
Lawyers for Hudgens sent cease and desist notices to various blog websites immediately after the latest topless snaps hit the web, demanding the removal of the raunchy images amid fears she was underage when the shots were taken.
In 2007, pictures taken of Hudgens posing provocatively both nude and in lingerie appeared online - forcing the Disney star to issue a public apology.