Direct Selling Self-Regulatory Council Recommends Limbic Arc Modify and Discontinue Certain Product Performance and Earnings Claims

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McLean, VA – August 5, 2021 – The Direct Selling Self-Regulatory Council (DSSRC) of BBB National Programs recommended that certain product performance and earnings claims made by Limbic Arc, LLC, a wellness-related technology product direct selling company, and its salesforce be modified or discontinued. 

The DSSRC inquiry was commenced through the non-profit watchdog’s ongoing independent monitoring of advertising and marketing claims in the direct selling industry. The claims that were the subject of the inquiry were disseminated by Limbic Arc and its salesforce members on social media as well as on the company website.

Product Claims include, but are not limited to:

• “IT WORKS!!! We also have a Boost for Corona Virus specifically!” 
• “After two weeks, I am pain free, following over 20 years of chronic Fibromyalgia pain. These extraordinary InfoBoosts have changed my life! I could have never imagined these astounding results so quickly. -Irene Lauria”
• “I twisted my right ankle and fell one Saturday afternoon after not seeing an uneven pavement and landed on my hands and knees on the concrete. Nothing hurt at the time, not even my pride, because I was intent on getting to my destination. Within the hour, my foot and ankle began hurting and I barely made it to my car. Over the next hour, the pain increased and became excruciating so I couldn’t put weight on it without screaming – despite ice, heat, and elevation. I prayed... then remembered someone else had given a testimonial about ‘Pain Relief’ InfoBoost. I searched, found, and activated the boost. The pain began to subside and later that night, I was able to walk. The amazing thing is it never swelled up, I am VERY grateful to Vaughn for sharing this Godsend with us! -CJG, MD”
• “Using "Allergy", "Immune", and "Focus" InfoBoosts. Within seconds of activating the "Focus" InfoBoost, I could feel it coming into my third-eye area. When I activated the "Sleep" InfoBoost, I started to feel relaxed and my sleep seems deeper when it's active. The "Calm" InfoBoost is felt on both sides of my head and crown like a soft warm blanket Thank you! – Rev. Pam Hurst”
• “About ten years ago, I was diagnosed with asthma, and it’s been really concerning because it gets worse every single year. So I have been using this technology, Limbic Arc, which was developed by Dr. Cook. It provides my body with information. This information seems to be working because after three and a half months using this technology, my asthma symptoms, the tightness in my chest, the coughing, the inflammation, hard to breathe sometimes, I don’t have anymore. It’s totally gone!”
• “My main interest in it was the fact that it could help with pain. I twisted my knee several years ago in a fall from slipping on black ice and I actually twisted all the cartilage of my knee, and as a result I’ve had pain for years... I’ve been on it, maybe now about two to three weeks and I have not experienced any major pain at all with my knee. I also tried out the energy, and again, with the energy, I have had a lot more energy that I’ve had because I don’t sleep a lot. And, one other I tried, I tried the one that allows you to concentrate and I do know that when I tried that, I seemed to be taking in and retaining more information than I normally retain.”

DSSRC informed Limbic Arc of its concern that these product claims may convey unsubstantiated health-related and wellness benefits.

Earnings Claims

• “A better quality of life is made up of many facets. First & foremost...HEALTH. Without health you are already in the minus column. Second, financial health. It’s hard to have balance in life if you are always worrying about where the next dollar is coming. Limbic Arc combines these 2 aspects of health. Physical health & financial health. Get on board for an amazing 2020! 
• Passive income & a healthy future together amazing!”
• “Did you know that you could GROW a business to $2000+ per month and never talking about the money side of it. That’s how we are building Limbic Arc, 1 testimonial at a time!”
• “Coupled with our powerful web app, your financial freedom is closer than you think!”
• “Comp Plan Basics: A full 50% of every dollar is paid out weekly, Receive up to $20,000 per week from out ‘Non-Flushing Binary’ pay plan, Receive up to 3 generations of ‘Weekly Check Match’ with no earning cap, Our weekly ‘Leadership Bonus Pool’ rewards all leaders
• The Limbic Arc opportunity has been designed to help you build successful, thriving, and long-term business. Our comp plan empowers you to create the future you want!”

DSSRC informed Limbic Arc of its concern that a reasonable consumer may interpret these and similar claims to mean that salesforce members can earn significant income from the Limbic Arc business opportunity.

As stated in DSSRC’s Guidance on Earnings Claims for the Direct Selling Industry, while DSSRC will evaluate any claim based upon the context in which the claim appears and the potential net impression of such claim to the audience, some words and phrases commonly used in earnings claims can carry a particularly high risk of being misleading to consumers. Such words and phrases include claims such as “financial freedom,” “full-time income,” “replacement income,” “residual income,” and “career-level income.” Furthermore, earnings claims must be substantiated and representative of a level of earnings that can be generally expected by the audience. 

DSSRC recommended that Limbic Arc make a bona fide effort to remove the social media posts claiming, “Physical health and Financial health” as well as “Passive income & a healthy future together amazing” in the context in which those claims appeared along with a statement that “It’s hard to have balance in life if you are always worrying about where the next dollar is coming Limbic Arc combines these 2 aspects of health.”

DSSRC acknowledged Limbic Arc’s enforcement steps to terminate the salesforce affiliate that had disseminated the post stating “Did you know that you could GROW a business to $2000+ per month and never talking about the money side of it,” an action and the which DSSRC determined to be necessary and appropriate.

With respect to the earning claims made on the corporate website, DSSRC remained concerned with the statements that “Coupled with our powerful web app, your financial freedom is closer than you think” and “receive up to $20,000 per week” that are presented in an unqualified context and recommended that this language be removed or significantly modified.

Regarding the product claims at issue in this inquiry, Limbic Arc addressed social media posts which stated that Limbic Arc’s products were effective in the treatment of COVID-19. Limbic Arc noted that it contacted the affiliates responsible for the posts and the affiliates immediately deleted the claims. With respect to one of the affiliates, Limbic Arc noted that it engaged in a one-on-one training session with the affiliate regarding the compliance documents on the company website. Regarding the other affiliate, Limbic Arc noted that it provided additional training for the affiliate as well as the affiliate’s associates.

DSSRC acknowledged and appreciated that Limbic Arc addressed the health-related claims made by its affiliates. As to the product testimonials featured on the company’s websites and social media accounts, DSSRC recommended that Limbic Arc remove any social media and website testimonials that depict atypical results or significantly modify such testimonials to include a disclosure of generally expected results. DSSRC also recommended that the company remove any testimonial conveying a strong health-related or disease treatment message and refrain from disseminating any such claims in the future.

All BBB National Programs case decision summaries can be found in the case decision library. For the full text of DSSRC decisions, visit the DSSRC Cases and Closures webpage.

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About BBB National Programs: BBB National Programs is where businesses turn to enhance consumer trust and consumers are heard. The non-profit organization creates a fairer playing field for businesses and a better experience for consumers through the development and delivery of effective third-party accountability and dispute resolution programs. Embracing its role as an independent organization since the restructuring of the Council of Better Business Bureaus in June 2019, BBB National Programs today oversees more than a dozen leading national industry self-regulation programs, and continues to evolve its work and grow its impact by providing business guidance and fostering best practices in arenas such as advertising, child-directed marketing, and privacy. To learn more, visit bbbprograms.org.

About the Direct Selling Self-Regulatory Council: The Direct Selling Self-Regulatory Council (DSSRC), a division of BBB National Programs, provides independent, impartial monitoring, dispute resolution, and enforcement of false product claims and income representations made by direct selling companies and their salesforce members across digital platforms. The DSSRC seeks to establish high standards of integrity and business ethics for all direct selling companies in the marketplace.