DSSRC Case Decisions and Administratively Resolved Inquiry Summaries
Case Decisions
Case #153-2024: Monitoring Inquiry – Trades of Hope LLC
Trades of Hope LLC (“Trades of Hope” or the “Company”) is a multi-level direct selling company that specializes in the sale of an assortment of goods including jewelry, personal accessories, home decor, and coffee. According to its website, Trades of Hope purchases its products from local artisans around the globe, including from Vietnam, Thailand, Cambodia, Uganda, Kenya, Peru,...
Case #152-2024: Administrative Closure – ibuumerang, Ltd
ibuumerang, Ltd (“ibuumerang” or the “Company”) is a direct selling company that offers discount travel for its members. The Company is headquartered in Houston, Texas and was founded in 2019.
Case #151-2024: Administrative Closure – Ruby Ribbon
Ruby Ribbon ("Company") is a multi-level direct selling company located in Burlingame, CA that was founded in 2011 and sells shapewear, athleisure, and intimates.
Case #150-2024: Administrative Closure – Vida Divina Worldwide, Inc.
Vida Divina Worldwide, Inc. (“Vida Divina” or the “Company”) is a direct selling company that markets health and wellness products, including beverages and nutritional supplements. The Company is headquartered in Ontario, Canada and was founded in 2016.
Case #149-2024: Administrative Closure – Innov8tive Nutrition
Innov8tive Nutrition ("Company") is a multi-level direct selling company that sells nutritional supplements and self-care products.
Case #148-2024: Monitoring Inquiry – LiveGood, Inc. USA
LiveGood Inc. USA (“LiveGood” or the “Company”) is a direct selling company that sells a variety of multivitamins and supplements with a focus on sleep aids, inflammation management, muscle recovery and weight management. The Company is headquartered in Jupiter, Florida and was founded in 2022.
Case #147-2024: Monitoring Inquiry – PaperPie f/k/a Usborne Books & More
PaperPie f/k/a Usborne Books & More (“PaperPie” or the “Company”) is a direct selling company that was founded in 1989 and based in Tulsa, Oklahoma.1 The Company distributes children’s books and educational products.
Case #146-2023: Administrative Closure – Enzacta USA
Enzacta USA (“Enzacta or the “Company”) is a direct selling company that sells nutritional and wellness products. The Company is headquartered in Cheyenne, Wyoming and was founded in 2003.
Case #145-2023: Administrative Closure – Tranont
Tranont (or the “Company”) is a multi-level direct selling company based in Utah. Founded in 2013, the Company sells health and wellness products, including a line of CBD products.
Case #144-2023: NGO Inquiry – Modere USA, Inc.
Modere USA, Inc. (“Modere” or the “Company”) is a direct selling company founded in 2012 and based in Newport Beach, California that markets health, beauty, and wellness products.
Case #143-2023: Administrative Closure – Traveling Vineyards
Traveling Vineyards (or the “Company”) was a direct selling company based in Ipswich, Massachusetts. The Company was established in 2010 and sells boutique wines.
Case #142-2023: Administrative Closure – Globallee, Inc.
Globallee, Inc. (“Globallee” or the “Company”) is a direct selling company located in Irving, Texas, founded in 2019. The Company sells various health and wellness supplements and has offices in Japan, Canada, Australia, and the United States.
Case #141-2023: Administrative Closure – Red Aspen, LLC
Red Aspen, LLC, (“Red Aspen” or the “Company”) is a direct selling company that markets beauty and cosmetic products. The Company is headquartered in Meridian, Idaho and was founded in 2017.
Case #140-2023: Administrative Closure – Younique, LLC
Younique, LLC (or the “Company”) is a direct-selling company based in Utah that sells beauty products.
Case #139-2023: NGO Inquiry – Elomir, Inc.
Elomir, Inc. (“Elomir” or the “Company”) sells nutritional supplements including its flagship product, Axis Klärity. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #138-2023: Monitoring Inquiry – Thrive Life, LLC
Thrive Life, LLC is a direct selling company that manufactures and markets freeze-dried and rehydrated foods. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #137-2023: Administrative Closure – Herbalife International of America, Inc.
Herbalife International of America, Inc., (“Herbalife” or the “Company”) is a direct selling company that sells nutritional and wellness products. The Company is headquartered in Los Angeles, California and was founded in 1980.
Case #136-2023: Administrative Closure – Grace & Heart
Grace & Heart (or the “Company”) was a direct selling company based in California. The Company was established in 2015 and sold fashion jewelry.
Case #135-2023: Administrative Closure – Global Domains International
Global Domains International is a direct-selling company based in California that sells domain names via an affiliate network. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #134-2023: Compliance Inquiry – B-Epic Worldwide, LLC
B-Epic Worldwide LLC is a Utah-based multi-level marketing company that sells health and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising in the direct selling marketplace.
Case #133-2023: Government Referral – Sweet Minerals, LLC
Sweet Minerals, LLC (“Sweet Minerals” or the “Company”) is a direct selling company based in Pasadena, Maryland. The company was founded in 2011 and markets makeup, personal care, skin care, and cosmetic products.
Case #132-2023: Administrative Closure – jBloom Designs
jBloom Designs (“jBloom” or the “Company”) is a multi-level marketing company that sells custom jewelry. The Company is headquartered in St. Peters, MO and founded in 2013.
Case #131-2023: Compliance Inquiry – Seint Beauty
Case #130-2023: Monitoring Inquiry – Healy World
Healy World, Inc. (“Healy World” or the “Company”) is a direct selling company based in Mainz, Germany with its domestic headquarters in Orlando, Florida.
Case #129-2023: Monitoring Inquiry – Zinzino, LLC
Zinzino, LLC (“Zinzino” or the “Company”) is a direct selling company founded in 2005 that offers nutritional supplements to consumers. The Company is headquartered in Frölunda, Sweden and has a subsidiary in Jupiter, Florida.
Case #128-2023: Compliance Report – The Juice Plus+ Company, LLC
The Juice Plus+ Company, LLC (“JuicePlus” or the “Company”) is a direct selling company founded in 1970 and based in Collierville, Tennessee. The Company markets fruit and vegetable juice extract supplements.
Case #127-2023: Administrative Closure – Traci Lynn Jewelry
Traci Lynn Jewelry (or the “Company”) was a direct selling company based in Florida. The Company was established in 1989 and sold affordable fashion jewelry.
Case #126-2023: Monitoring Inquiry – Zallevo, LLC
Zallevo, LLC (“Zallevo” or the “Company”) is a direct selling company founded in 2020 and based in St. George, Utah. The Company markets health and wellness products focusing on weight loss and anxiety/stress reduction.
Case #125-2023: Monitoring Inquiry – Pink Zebra
Pink Zebra At Home (or the “Company”) is a direct selling company founded in 2011 and based in Sugar Land, Texas. The Company markets home fragrance and décor products including a wide range of items such as scented wax melts, candles, reed diffusers, room sprays, and other related accessories.
Case #124-2023: Government Referral – Tori Belle Cosmetics
Tori Belle Cosmetics (“Tori Belle” or the “Company”) is a direct-selling company founded in 2019 and based in Woodinville, Washington. The Company markets beauty and cosmetic products.
Case #123-2023: Administrative Closure – Seint Beauty
Seint Beauty (“Seint” or the “Company”), formerly Maskcara Beauty, is a multi-level marketing company founded in 2013 and based in St. George, Utah. The Company markets consumer and personal care products with a focus on cosmetics and cosmetic accessories.
Case #122-2023: Government Referral – iCoinPro
iCoinPro (or the “Company”) is a multi-level direct selling company that markets education, information, and training for cryptocurrency services. The Company was founded in 2017 and is located in Carson City, Nevada.
Case #120-2023: Monitoring Inquiry – Pure Haven, LLC
Pure Haven, LLC (“Pure Haven” or the “Company”) is a direct-selling company founded in 2009 and based in Rhode Island. The Company markets household products and personal care products to consumers including a line of skin care products.
Case #119-2023: Government Referral – Wayal Health Sciences USA, Inc.
Wayal Health Sciences USA, Inc., (“Wayal Health” or the “Company”) is a multi-level direct selling company founded in 2016. The Company is headquartered in Salt Lake City, Utah and markets health and wellness nutritional supplements.
Case #118-2023: Administrative Closure – Daxen, Inc.
Unicity International, Inc. (“Unicity” or the “Company”) is a multi-level marketing company headquartered in Orem, Utah and founded in 1986. The Company markets nutritional and personal care products and operates in approximately 30 countries, including the United States, Australia, Brazil, Brunei Darussalam, Canada, Colombia, Hong Kong, Indonesia, Japan, Malaysia, New Zealand,...
Case #117-2023: Administrative Closure – Unicity International, Inc.
Unicity International, Inc. (“Unicity” or the “Company”) is a multi-level marketing company headquartered in Orem, Utah and founded in 1986. The Company markets nutritional and personal care products and operates in approximately 30 countries, including the United States, Australia, Brazil, Brunei Darussalam, Canada, Colombia, Hong Kong, Indonesia, Japan, Malaysia, New...
Case #116-2023: Administrative Closure – GelMoment, Inc.
GelMoment, Inc. (“GelMoment” or the “Company”) is a direct-selling company founded in 2014 and based in Montreal, Canada. The Company markets gel nail polish and other beauty products.
Case #115-2023: NGO Inquiry – The Juice Plus+ Company, LLC
The Juice Plus+ Company, LLC is a direct selling company founded in 1970 and based in Collierville, Tennessee. The Company markets fruit and vegetable juice extract supplements. An NGO identified to DSSRC certain earnings and product performance claims disseminated by salesforce members and the Company.
Case #114-2023: Administrative Closure – Reliv International, Inc.
Reliv International, Inc. is a direct-selling company founded in 1988, and based in Chesterfield, Missouri. The Company markets proprietary nutritional supplements. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of the direct selling marketplace.
Case #113-2023: Administrative Closure – Vic Beauty, LLC
Vic Beauty, LLC was a direct sales cosmetic and personal care company based in Los Angeles, California. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #112-2023: Compliance Inquiry – Magnetude Jewelry
Magnetude Jewelry (or the “Company”) is a multi-level direct selling company based in Maryland that sells bio-magnetic interchangeable fashion jewelry to consumers. According to the Company’s website, the Company’s independent representatives earn money through commission on product sales or recruiting other salesforce members.
Case #111-2023: Administrative Closure – Shaklee Corporation
Shaklee Corporation (“Shaklee” or the “Company”) is a direct-selling company founded in 1956 and based in Pleasanton, CA. The Company markets natural nutritional supplements, beauty products, and household products.
Case #110-2023: Administrative Closure – Prime My Body
Prime My Body LLC (“Prime My Body” or the “Company”) is a direct-selling company based in Carrollton, Texas. The company was founded in 2013 and sells CBD oils and other nutritional products.
Case #109-2023: Administrative Closure – Direct Cellars
Case #108-2023: Administrative Closure – Save the Day Seasonings
Case #107-2023: Administrative Closure – BeneYOU LLC (a/k/a Avisae)
BeneYOU LLC (a/k/a Avisae) (“BeneYOU” or the “Company”) is a direct selling company headquartered in Lindon, Utah, that acquired the Avisae brand in 2018. The company markets personal care and wellness products.
Case #106-2023: Monitoring Inquiry – Magneceutical Health, LLC
Magneceutical Health, LLC (“Magneceutical Health” or the “Company”) is a company headquartered in Clearwater, FL that markets a medical device called the Magnesphere, which is a magnetic resonance therapy system designed to help reduce the symptoms associated with chronic stress.
Case #105-2023: Monitoring Inquiry – Peach Underneath, Inc.
Peach Underneath, Inc. (“Peach Underneath” or “the Company”) was a multilevel marketing company headquartered in Waltham, Massachusetts that marketed premium, athletic-inspired clothing and intimate apparel.
Case #104-2023: Government Referral – Karatbars International
Karatbars International is a multi-level direct selling company founded in 2011 that markets small gold bars and gift items in gold bullion. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #103-2023: Monitoring Inquiry – Essential Bodywear, LLC
Essential Bodywear, LLC is a direct selling company founded in 2003 and headquartered in Commerce, Michigan. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #102-2023: Compliance Inquiry – Innov8tive Nutrition, Inc.
Innov8tive Nutrition is a direct selling company that was founded in 2016 and is headquartered in Seattle, Washington. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #101-2023: Monitoring Inquiry – NeVetica International, Inc.
NeVetica International, Inc. is a direct selling company headquartered in Louisville, Kentucky and founded in 2016. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #100-2022: Monitoring Inquiry – Youngevity International, Inc.
Youngevity International, Inc. is a direct selling company that sells health, nutrition, and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #99-2023: Government Referral – Perfectly Posh, LLC
Perfectly Posh, LLC is a direct selling company based in Salt Lake City, Utah that markets personal care and beauty products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #98-2022: Monitoring Inquiry – Ruby Ribbon, Inc.
Ruby Ribbon, Inc. is a multi-level marketing company that markets women’s apparel, handbags, and other accessories. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #97-2022: Administrative Closure – Unicity International, Inc.
Unicity International, Inc. is a multi-level marketing company that markets nutritional and personal care products and operates in approximately 30 countries. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #96-2022: Government Referral – ViSalus, Inc.
ViSalus, Inc. is a multilevel marketing company that markets weight management nutritional products, dietary supplements, and energy drinks. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #95-2022: Monitoring Inquiry – PartyLite Worldwide, LLC
PartyLite Worldwide, LLC is a multi-level marketing company that markets candles, home décor, and home fragrance products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #94-2022: Administrative Closure – Tealightful Treasures, Inc.
Tealightful Treasures, Inc. is a retail company with a direct-to-consumer website that markets several varieties of loose-leaf tea products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #93-2022: Administrative Closure – Ardyss International, LLC
Ardyss International LLC is a multi-level marketing company that markets reshaping apparel, nutrition, personal care, and home care products.This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #92-2022: Administrative Closure – Sunrider International
Sunrider International is a multi-level marketing company that markets herbal food and beverages, nutritional supplements, and skin care and personal care products.This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #91-2022: Monitoring Inquiry – Kannaway, LLC
Kannaway, LLC is a direct selling company headquartered in Poway, CA that sells CBD and wellness products to consumers. This inquiry was commenced by DSSRC pursuant to its ongoing independent...
Case #90-2022: Monitoring Inquiry – Zilis LLC
Zilis LLC is a multi-level direct-selling company headquartered in Argyle, Texas that sells wellness products to consumers.
Case #89-2022: Monitoring Inquiry – My Lala Leggings, Inc.
My Lala Leggings, Inc. is a multi-level marketing company headquartered in Palmdale, CA that sells women’s clothing, specializing in leggings.
Case #88-2022: Monitoring Inquiry – B-Epic Worldwide, LLC
B-Epic Worldwide, LLC is a multi-level direct-selling company located in Layton, Utah that markets health, detox, and fitness products.
Case #87-2022: Monitoring Inquiry – MWR Life, LLC
MWR Life, LLC is a multi-level direct selling company headquartered in Fort Lauderdale, Florida that offers discounts on travel services such as flights, hotels, resorts, cruises, vacation rentals, car rentals, excursions, theme parks, and trains. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling...
Case #86-2022: Monitoring Inquiry – Visi
Visi is a direct-selling company headquartered in Pleasant Grove, Utah specializing in a variety of health-related products, including protein, essential oils, and extracts. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims made in the direct selling industry.
Case #85-2022: Monitoring Inquiry – Reliv International, Inc.
Reliv International, Inc. is a multilevel direct-selling company located in Chesterfield, Missouri that markets and distributes nutritional supplements and personal care products. This...
Case #84-2022: Monitoring Inquiry – Navan Global
Navan Global was a multilevel marketing company located in Franklin, Tennessee, manufacturing and distributing health and CBD-related products. This inquiry was commenced by DSSRC pursuant to its...
Case #83-2022: Government Referral – Root Wellness LLC, a/k/a Root Brands
Root Wellness LLC is a direct-selling company founded in 2019 and located in Brentwood, Tennessee. The Company markets health and wellness products, most notably its Clean Slate, Restore, and Zero-In products. In February 2021, DSSRC initiated an inquiry regarding the dissemination of health-related claims by Root Wellness and its salesforce members and opened a...
Case #82-2022: Administrative Closure – LurraLife Global
LurraLife Global was a multi-level direct-selling company that marketed health and wellness products, including detoxification tea, to consumers. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #81-2022: Administrative Closure – QuiAri, LLC
QuiAri, LLC is a multi-level direct-selling company in Brandon, Florida, that markets health and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #80-2022: Government Referral – Fifth Avenue Collection, Inc.
Fifth Avenue Collection is a multi-level direct-selling company that sells fashion jewelry products headquartered in Moose Jaw, Saskatchewan. The Direct Selling Self-Regulatory Council (DSSRC) commenced this inquiry pursuant to its ongoing, independent monitoring of advertising and marketing claims in the direct selling industry.
Case #79-2022 – Government Referral – Vyvo, Inc.
Vyvo, Inc. is a multi-level direct selling company that markets a smart watch, DNA and genetics testing, and nutritional supplements. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising in the direct selling marketplace and concerns earnings claims disseminated by the Company and its salesforce members.
Case #78-2022 – Monitoring Inquiry – H20 At Home
H2O At Home is a multilevel marketing company headquartered in King of Prussia, Pennsylvania that offers consumers a line of non-toxic cleaning solutions. This inquiry was commenced by DSSRC...
Case #77-2022 – Compliance Inquiry – Root Wellness LLC
The Direct Selling Self-Regulatory Council (DSSRC) opened a compliance inquiry against Root Wellness after health-related product claims similar to those addressed in a 2021 inquiry appeared in the social media posts of Root Wellness salesforce members. In addition, during its inquiry DSSRC identified more than 30 other related issues.
Case #76-2022 – Monitoring Inquiry – Sanki Global LLC
This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. Sanki Global LLC is a multi-level direct selling company headquartered in Japan, with U.S. offices located in Henderson, Nevada.
Case #75-2022 – Monitoring Inquiry – Tranont
This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. Tranont is a multi-level direct selling company based in Utah. Founded in 2013, the Company sells health and wellness products, including a line of CBD products.
Case #74-2022 – Monitoring Inquiry – Opulence Global
Opulence Global is a multi-level direct selling company that sells skincare, personal care, and health & wellness products. This inquiry concerns product and earnings claims disseminated by salesforce members on social media regarding the Fountain of Life product, an antioxidant that includes a Picea Abies extract as one of its primary...
Case #73-2022 – Monitoring Inquiry – Financial Education Services
Financial Education Services is a multi-level direct selling company that markets credit repair services to consumers. This inquiry concerns earnings claims disseminated by company salesforce members on social media.
Case #72-2022 – Monitoring Inquiry – Stella & DOT, LLC
Stella & DOT, LLC is a multi-level direct selling company that sells jewelry, bags, accessories, and women’s clothing. The Direct Selling Self-Regulatory Council (DSSRC) began this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. This inquiry concerns earnings claims disseminated by Stella & DOT and its...
Case #71-2022 – Monitoring Inquiry – Lifebrook, LLC
Lifebrook was a multilevel marketing company headquartered in Vermillion, South Dakota that sells juices, supplements, and other products containing Aronia. The Direct Selling Self-Regulatory Council (DSSRC) began this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #70-2022 – Monitoring Inquiry – My Lala Leggings, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #69-2022 – Monitoring Inquiry – Max International, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #68-2022 – Monitoring Inquiry – Daxen, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #67-2022 – Monitoring Inquiry – WorldVentures Marketing, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #66-2022 – Monitoring Inquiry – Tastefully Simple
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #65-2022 – Government Referral – FutureNet, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs.
Case #64-2022 – Compliance Report – Young Living Essential Oils, LLC
Young Living Essential Oils, LLC (“Young Living” or the “Company”) is a global multi-level direct selling company that sells essential oils and other personal care and wellness products.
Case #63-2022 – Monitoring Inquiry – Innov8tive Nutrition
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #62-2022 – Monitoring Inquiry – MWC Living, LLC d/b/a BE (Better Experience)
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs and commenced this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #61-2022 – Compliance Report – Mary Kay, Inc.
Mary Kay, Inc.’s (“Mary Kay” or the “Company) business model is that of a direct sales company, which means Mary Kay products are sold by Mary Kay independent sales force members, person to person, away from fixed retail locations. The Company is headquartered in Dallas, Texas. Mary Kay was founded in 1963 and has an estimated three million independent beauty consultants selling Mary Kay®...
Case #60-2022 – Monitoring Inquiry – Morinda, Inc., Corporation
Morinda, Inc. is a multi-level direct-selling company that markets a noni juice blend (Tahitian Noni) and various dietary supplements, personal care products, and essential oils. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #59-2022 – Government Referral – BE Rules, a/k/a BE Factor, f/k/a Melius
BE Rules, a/k/a BE Factor, f/k/a Melius (“BE” or the “Company”) is a multi-level direct selling company that markets forex and cryptocurrency trading package subscriptions. BE Rules is based in Dubai, United Arab Emirates and also maintains offices in India and the United Kingdom.[1] The Company maintains a Facebook page[2], an Instagram page[3], a company...
Case #58-2022 – Monitoring Inquiry – Surge365
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #57-2022 – Compliance Report – Le-Vel Brands, LLC
Le-Vel Brands, LLC (“Le-Vel” or the “Company) is a multi-level direct selling company headquartered in Frisco, Texas that was founded in 2012. The Company sells health and wellness products including dietary supplements containing vitamins, minerals, plant extracts, antioxidants, enzymes, probiotics, and amino acids.
Case #56-2022 – Monitoring Inquiry – Immunotec
Case #55-2021 – Monitoring Inquiry – Wildtree, Inc.
Wildtree, Inc. is a spice and seasoning company headquartered in Lincoln, Rhode Island that specializes in healthy meal solutions for families. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #54-2021: Government Referral – Dot Dot Smile
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #53-2021: Monitoring Inquiry – Jeunesse Global
The Direct Selling Self-Regulatory Council (DSSRC) opened a monitoring inquiry with Jeunesse Global over concerns about earnings claims disseminated by salesforce members for the company. DSSRC appreciated Jeunesse’s good faith actions to remove the challenged claims on social media sites, but DSSRC recommended Jeunesse continue its communication with salesforce members to ensure that...
Case #52-2021: Monitoring Inquiry – Daxen, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #51-2021: Compliance Report – dōTERRA International, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. In 2019, DSSRC commenced an inquiry regarding several core health-related and income claims being disseminated on the social media pages of certain distributors of dōTERRA. More specifically, the inquiry included both...
Case #50-2021: Monitoring Inquiry – Chalk Couture
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #49-2021: Monitoring Inquiry – Lifebrook, LLC
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #48-2021: Government Referral – Q Sciences
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #47-2021: –Monitoring Inquiry– Root Wellness, LLC
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #46-2021: –Monitoring Inquiry– SwissJust USA
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #45-2021 – Monitoring Inquiry – Globallee, Inc.
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #44-2021 – Government Referral – ByDzyne
Case #43-2021 – Monitoring Inquiry – Limbic Arc, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs, Inc. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #42-2021 –Monitoring Inquiry– Max International, LLC
Case #41-2021 – Government Referral – Alliance in Motion Global, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #40-2021 – NGO Inquiry –Mary Kay, Inc.
Case #39-2021: –Monitoring Inquiry– Enagic, USA, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #38-2021: –Monitoring Inquiry– Zinzino, LLC.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #37-2021: –Monitoring Inquiry– Aihu, Inc.
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #36-2021: – Government Referral – Bulavita
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self- regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #35-2021: – Government Referral – UWell Life, Inc.
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Administratively Resolved Inquiry Summaries
Case #43-2021 – Monitoring Inquiry – Limbic Arc, LLC
BBB NATIONAL PROGRAMS, INC.
The Direct Selling Self-Regulatory Council
Case Number: 43-2021 – Monitoring Inquiry – Limbic Arc, LLC
Company Description
Limbic Arc, LLC (“Limbic Arc” or the “Company”) is a direct selling company based in Utah that offers a wellness-related technology product to its subscriber affiliates.
Basis of Inquiry
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs, Inc. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
DSSRC’s inquiry concerned earnings claims and product claims disseminated by both the Company and its salesforce members. The representative earnings claims and product claims that formed the basis of this inquiry appeared on the Company’s website and on social media accounts of Company salesforce members. Those claims are set forth below:
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!”
Product Claims:
- “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”
- “A little background is important to put my results in context. I’m 82 years of age and in better than average health, especially for my age. However, I've been dealing with recurring knee pain for several years. X-rays showed degeneration and meniscus damage. The pain has not kept me from my hiking/jogging the hilly trails, but each step is a painful reminder of the deterioration from 60 years of running marathons, triathlons, trails, and a genetic tendency for arthritis.
Lately, I noticed a lack of energy and the need for more naps than usual. My awareness of these two health challenges led me to choose the InfoBoosts, “Pain Relief” and “Energy”, on the Limbic Arc app.
Within just a few hours, I sensed a positive feeling of increased energy. It was a subtle thing, but I was less tired and walking and moving more swiftly.
This improvement in energy got me out for a hike on the hilly trails near my home and, what was intended as a 2 mile outing, became a more challenging 4-mile hike/jog on a trail that I take just a few times a year because it's steeper and longer than my usual outing.
The amazing thing for me was that I not only had the energy and desire to attempt it, but that I completed it feeling zero pain in my knees. The fact is the trail is very uneven with rocks and erosion making for uneven footing that puts extra stress and torque on the knees. No pain—only the memory of the usual pain!
It's still hard to believe that I can receive these quantum-energy InfoBoosts with no physical connection to their source. My cell phone is acting as a “Library Card” to the storehouse of wellness information at Limbic Arc. It seems almost like science fiction, but it's real and it certainly worked for me.
My next challenge is the InfoBoost “Weight”, so I look forward to reporting positive results in the future. – David ‘Mr. Ageless’ Tanner”
- “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”
- “When I heard about Limbic Arc, I was very skeptical but wanted to try it! In February 2018, I had open-heart surgery and have been in the hospital seven other times for various reasons. For the past couple of years, I've been taking medication to sleep and couldn’t sleep without it. I also have been on pain pills for over a year and couldn’t survive the day without some kind of pain killer. At age 35, I needed my life back so I could spend time with my wife and children! When my sister told me about Limbic Arc, she said there were InfoBoosts for pain relief and sleep - and many more. I may not understand everything about it, but I know it works as I no longer take sleep medicine or pain killers! I feel so much better now and am so thankful to be back to work and spending time with my family! Thanks to the Limbic Arc family for sharing this wellness with me! – Charles Deaton”
- I wanted to share my results on the Limbic Arc app: 1) Ten noticeable pounds gone in two weeks and I dropped two pants sizes with inches gone especially. Very noticeable! 2) 98% reduction in knee pain and no back pain. 3) During stressful situations, I'm calm as a cucumber, as pointed out by my son. 4) Energy! I am getting back to Darryl of old. Walked to the end of a city block last night at a brisk pace without breathing hard and no pain. 5) Focus! I can't say enough about the focus - completing tasks with a bulldog mentality and no mental fatigue. 6) I can literally feel my lungs open up with deep breathing and my coughing greatly reduced after using the "Allergy" InfoBoost. 7) My sleep is undisturbed and I'm sleeping through the night... deep, restful, and feeling good when I awaken.
- My wife says she has her husband back and my son mentioned that I'm not ‘creaking when I walk’. For people who are health conscious, this is completely undervalued and I'm grateful for the price. This product has exceeded my expectations! – Darryl Thomas Sr.”
- “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.”
- They allow you to try three products at one time so I tried the Energy, the Pain, and the Focus. So immediately I noticed that the pain that I had had since I was a teenager dissipated...And then the energy, my energy just picked up. And I lose focus at the drop of a hat because I’m a sleepy head. But my focus was there and I was able to concentrate.
I am on a journey to lose weight. And I have started engaging with more activities. So I said I was going to reincorporate walking into my lifestyle. But me with no energy, I would be drained. I couldn’t walk a half block without just wanting to pass the crap out. But since I’ve been using this app, oh my god. I walk two and half or more miles every single day...And I mean every day I walk these miles and I am so excited, so happy and eager to just get this out to the masses. This is something that will be beneficial and change everyone’s life.
DSSRC informed the Company of its concern that a reasonable consumer may interpret these and similar claims, to mean that Company salesforce members can earn significant income from the Limbic Arc business opportunity. In addition, DSSRC expressed concern that the product claims may convey unsubstantiated, health-related and wellness benefits.
Company’s Position
Limbic Arc is a company related to ZYTO Corporation which licenses via a retail platform software and sells hardware products to medical professionals. The Company noted that ZYTO is subject to regular audits by the United States Food & Drug Administration (FDA) and that it has previously had conversations with the Federal Trade Commission (FTC). The Company noted that given its previous dealings with these regulatory agencies it takes compliance very seriously and strives to be proactive in its approach to compliance with the Company’s affiliate software licensees. The Company stated that, as a foundational matter, Limbic Arc is committed to operating in a highly ethical manner.
Limbic Arc stated that, in addition to operating with strict adherence to all laws and regulations, its affiliate agreement contains the following language:
2.3 Customer represents, covenants, and warrants that Customer will use the Services only in compliance with Company’s standard published policies then in effect (the “Policies & Procedures”) and all applicable laws and regulations. Customer hereby agrees to indemnify and hold harmless Company against any damages, losses, liabilities, settlements and expenses (including without limitation costs and attorneys’ fees) in connection with any claim or action that arises from an alleged violation of the foregoing or otherwise from Customer’s use of Services. Although Company has no obligation to monitor Customer’s use of the Services, Company may do so and may prohibit any use of the Services it believes may be (or alleged to be) in violation of the foregoing.
Limbic Arc further noted that its Terms and Conditions also specifically commit users to adhere to the Direct Selling Association Code of Ethics:
1. BUSINESS ETHICS
DSA CODE OF ETHICS. The Company adheres to the Code of Ethics of the Direct Selling Association (DSA). Along with the ethical guidelines of this Section, you must comply with the DSA Code of Ethics in your business operations. The DSA Code of Ethics can be found at www.dsa.org.
GENERAL ETHICS. You must operate your Affiliate Business in an ethical, professional, and courteous manner. This means, among other things, the following:
- You must comply with the Contract and with applicable law.
- You must operate your Affiliate Business honestly.
- You should indicate to prospective customers and Affiliates who you are, why you have contacted them, and what Products you are selling.
- You may not make false or misleading claims about potential earnings under the Sales Compensation Plan or about the benefits of using the Company’s Products.
- You may not pressure any Affiliates or prospective Affiliates to operate in a financially irresponsible way.
- You must not encourage or recommend that Affiliates or prospective Affiliates incur debt in order to participate in the business.
- You must explain how to cancel a software subscription.
- You must not represent to prospective Affiliates that they are required to purchase Products or Product packages to become Affiliates. Prospective Affiliates must be informed that they can license Company software without promoting the software to other potential customers.
In addition, the Company noted that its website contains a prominent link to “Compliance & Legal” where, in addition to a video discussing ethical and legal compliance, there are two pages devoted to “Legal Compliance” and “Legal Compliance Examples.” The video states that affiliates are barred from making non-specific factual earnings claims and cannot make any claims stating that the software has been used to diagnose and/or treat any disease or medical condition.
The Company further stated that its “Legal Compliance” page contains a very specific write-up of what Limbic expects of its affiliates, specifically including the following text:
Limbic Arc is committed to strict compliance with all applicable laws, rules, and regulations. We support important regulatory and law-enforcement bodies who are charged with protecting the public against harm. Because we are a legitimate business, you can be confident in being a part of the Limbic Arc family.
The U.S. Federal Trade Commission (FTC) is charged with protecting consumers from deceptive and unfair business practices. They accomplish this by ensuring that consumers have access to accurate information and bringing administrative and legal actions against companies that deceive consumers. Limbic Arc supports the FTC in this important mission and is appreciative for the work they do to protect the American public.
Limbic Arc stays in the good graces of the FTC by doing two things: first, we don’t deceive consumers by making any false statements; and second, we make sure to disclose enough accurate information so that consumers can make an informed choice regarding our products. Our agreements with our affiliates require them to also follow these rules. It is pretty simple: Don’t lie and always disclose the truth. We at Limbic Arc are committed to doing these things and demand all those involved with our business do the same.
The U.S. Food and Drug Administration (FDA) regulates medical devices… Limbic Arc supports and sustains the FDA in its important work protecting Americans from those who would lead people away from established and approved treatments for medical issues. Instead we operate in the wellness space shared with nutritional supplements. The Limbic Arc software is not designed to treat or prevent any disease or medical condition. We at Limbic Arc make no such claims. If any of our users stated that Limbic Arc should be used to diagnose or treat medical conditions, it would violate our agreements and the offender’s account would be terminated and their position in the commission downline eliminated. If a person is sick or injured, they should seek competent professional medical assistance immediately. Don’t improperly use Limbic Arc software in attempts to practice medicine. We freely admit that Limbic Arc is not part of the currently accepted Western scientific and medical wisdom. No user should believe that our offerings are accepted or approved by the American Medical Association. Our technology is not taught in traditional medical schools. We are beyond the boundary of generally accepted scientific knowledge. We do not hide from this reality and we want to clearly disclose it.
The Company also stated that its “Legal Compliance Examples” page is largely adapted to specifically apply to Limbic Arc from the General Wellness: Policy for Low Risk Devices page found at https://www.fda.gov/media/90652/download. This page sets forth four rules and then gives both positive and negative examples of what affiliates may say/not say:
Rule Number 1: Do not make any diagnosis or treatment claims.
Rule Number 2: It is okay to make general wellness claims.
Rule Number 3: Only refer to chronic medical conditions in the context of prevention or management, not diagnosis or cure.
Rule Number 4: Do Not Make Specific Financial Promises
As a general matter, Limbic Arc stated that it recognizes that it needs to take more general remedial actions to police the claims its affiliates make in the marketplace. Limbic Arc noted that it is a young company, just recently expanding beyond its few founding employees and stretched thin in both manpower and budget. Nonetheless, Limbic Arc informed DSSRC that it has now committed one-half of a full-time employee as a resource to police the market for inappropriate earnings or health-related medical claims.
In addition, the Company informed DSSRC that it is implementing a monthly legal compliance conference call where affiliates may join senior company officers and the Company’s outside counsel to receive legal compliance training and ask questions. The Company noted that these trainings will be posted on the Company’s website going forward.Earnings Claims
In response to DSSRC’s concern regarding one of the Facebook posts, Limbic Arc expressed a belief that the language concerning “Physical health and Financial health” as well as “Passive income & a healthy future together amazing” is representative of non-specific claims and therefore is legally appropriate.
With respect to the Facebook post that stated “you could GROW a business to $2000+ per month” regarding Limbic Arc, Limbic Arc informed DSSRC that it reached out to the affiliate that disseminated the post by phone and email and that the affiliate never responded. As a result, the affiliate was terminated by Limbic Arc for cause and will not be allowed to continue to be an affiliate.
With respect to the statements on the Limbic Arc website: “Coupled with our powerful web app, your financial freedom is closer than you think!” and “Receive up to $20,000 per week from out ‘Non-Flushing Binary’ pay plan in the “Comp Plan Basics” section, the Company stated that it carefully considered the language in light of the FTC’s Business Guidance Concerning Multi-Level Marketing, particularly paragraph 13, and modified the language. Limbic Arc stated that it appreciated DSSRC’s feedback and that the Company was engaged in a comprehensive review of the Company’s website.
Product Claims
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.
Concerning the testimonial claims at issue, Limbic Arc indicated that it was engaging in a comprehensive audit of all of the company’s testimonials to ensure compliance with the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising. Limbic Arc informed the DSSRC that it will remove testimonials from the company website.
Analysis and Recommendation
Earnings Claims
DSSRC was concerned about social media posts made by a Company affiliate using the language “Physical health and Financial health” as well as “Passive income & a healthy future together amazing” in the context in which those claims appeared. Here, such claims were presented 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.”
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.
Accordingly, DSSRC determined that the claims presented in their advertised context on social media could be reasonably interpreted by consumers as meaning that they can expect to earn significant or substantial income from the Limbic Arc business opportunity. Therefore, DSSRC recommends that the Company make a bona fide effort to effectuate the removal of the post.
Limbic Arc did not contest or attempt to substantiate the claim made in an affiliate’s social media post, stating “Did you know that you could GROW a business to $2000+ per month and never talking about the money side of it.” While the post remains active as of the date of this decision, DSSRC acknowledged the Company’s good faith efforts to effectuate the removal of the post and the termination of the affiliate that had disseminated the post which DSSRC determined to be necessary and appropriate.
With respect to the earning claims made on the Company’s website, the Company informed DSSRC that the language had been modified and brought into compliance with FTC regulations. DSSRC, however, noted that the language identified in DSSRC’s opening letter remains unchanged. DSSRC remained concerned with the statements on the Company’s website that “Coupled with our powerful web app, your financial freedom is close than you think” and “receive up to $20,000 per week” that are presented in an unqualified context. Thus, DSSRC recommended that this language be removed or significantly modified.
Product Claims
DSSRC acknowledged and appreciated that the Company addressed the health-related claims made by its affiliates that were identified by DSSRC in this inquiry including health-related claims regarding COVIID-19 as well as the Company providing the affiliates responsible for the posts with further compliance training and guidance.
DSSRC identified testimonials found on one of the Company’s websites (limbicarc.com) that claimed that the Company's product was effective in the treatment of several health-related conditions, including fibromyalgia, chronic pain, asthma, and allergies as well as weight loss claims. During the course of this inquiry, the Company removed the testimonials from the website (limbicarc.com) and noted that it was engaging in a comprehensive audit to ensure that user testimonials were compliant with FTC regulations. However, DSSRC noted that at the time of decision, the same testimonials at issue were still available at another website operated by the Company (limbic-arc.com) and the video testimonials remained available on the Company’s YouTube page. The Company has agreed to remove the testimonials from the Company’s YouTube page.
DSSRC acknowledged the Company’s commitment to ensuring that all testimonials are accurate and made by genuine users of the Company’s products. Nonetheless, DSSRC remained concerned about the Company’s use of testimonials that depict atypical success. According to section 255.2 (b) of the FTC’s Guides Concerning the Use of Endorsements and Testimonials in Advertising, an advertisement containing an endorsement relating the experience of one or more consumers on a central or key attribute of the product or service also will likely be interpreted as representing that the endorser’s experience is representative of what consumers will generally achieve with the advertised product or service in actual, albeit variable, conditions of use. Therefore, an advertiser should possess and rely upon adequate substantiation for this representation. If the advertiser does not have substantiation that the endorser’s experience is representative of what consumers will generally achieve, the advertisement should clearly and conspicuously disclose the generally expected performance in the depicted circumstances. Accordingly, with respect to any testimonial that depicts atypical success, DSSRC recommended that such testimonial be removed or significantly modified to include a clear disclosure of generally expected results.
DSSRC, was additionally concerned with the testimonials at issue because certain testimonials communicate strong health-related claims such as treatment of chronic fibromyalgia, pain, clogged arteries. DSSRC determined that the requisite level of support for the subject claims is competent and reliable scientific evidence because the claims at issue are health-related claims that the Company’s products provide powerful health-related benefits. [1] This conclusion is also consistent with the Federal Trade Commission’s (FTC) position that advertisers must possess competent and reliable scientific evidence before making claims about pain relief, disease treatment, or health benefits. [2] In the absence of any such evidence submitted by the Company, DSSRC recommended that the Company remove any health-related or disease treatment claims from the testimonials it features on its websites or managed social media accounts and refrain from disseminating any similar claims.
Conclusion
DSSRC recommended that the Company make a bona fide effort to effectuate the removal of 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 the Company’s enforcement steps to terminate the 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 Company’s 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 pursuant to the Company’s commitment to DSSRC
Regarding the product claims at issue in this inquiry, DSSRC acknowledged and appreciated the Company addressing 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 the Company 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.
Company Statement
Limbic Arc is grateful for the work of the DSSRC to help police and clean up the direct sales industry and accepts the recommendations made by the DSSRC in full. Limbic Arc has implemented a regular review of social media posts made by affiliates and redoubled its efforts to educate them regarding appropriate health and earning claims. Limbic Arc is committed to being an additive and valuable member of the direct sales community and is fully committed to compliance with both the letter and the spirit of all laws and regulations protecting consumers.
(Case No. 43-2021 HJS, closed on 7/27/2022)
© 2020. BBB National Programs, Inc.
[1] Mommy’s Bliss Inc. (Cough Syrups and Probiotic Drops), Report #6257, NAD/CARU Case Reports (March 2019); Young Living Essential Oils, LLC (Case #13-2020).
[2] See FTC v. Tommie Copper, Inc. and Thomas Kallish; Stipulated Final Judgement and Order for Permanent Injunction and Other Equitable Relief; Civil Action No..7:15-cv-09304-VB; United States District Court for the Southern District of New York (2015).
DSSRC Administrative Closure #315
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") regarding four social media posts that communicated earnings claims and five posts that communicated health-related product claims. DSSRC expressed concern that the earnings claims conveyed that a typical salesforce member could achieve “financial freedom” and that typical Company salesforce members could earn...
DSSRC Administrative Closure #314
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets skin care and cosmetic products. The claims at issue consisted of two product performance claims and seven earnings claims that were disseminated on Facebook.
DSSRC Administrative Closure #313
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that markets nutritional supplements, bath and beauty care treatments, aromatherapy, home accents, and motivational products regarding seven product performance claims and four earnings claims that were disseminated by the Company's salesforce on Facebook and Youtube, including one claim that appeared on the...
DSSRC Administrative Closure #312
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that sells adult novelty products regarding nine Facebook posts that communicated earnings claims. DSSRC expressed concern about the posts conveyed claims regarding the potential income a typical salesforce member could earn from the Company's business opportunity, including the possibility of achieving...
DSSRC Administrative Closure #311
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that sells health supplements regarding two social media posts that communicated earnings claims, two posts that communicated health-related claims, and one claim on the Company website that communicated a parity claim regarding the effectiveness of the Company’s products. DSSRC expressed concern that the posts...
DSSRC Administrative Closure #310
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that sells personal protective equipment regarding fifteen social media posts that communicated earnings claims. Thirteen of the posts were communicated on Facebook, one appeared on Pinterest and the remaining blog post was created by a third party with no affiliation to the Company. DSSRC...
DSSRC Administrative Closure #309
The Direct Selling Self-Regulatory Council (DSSRC) contacted, a direct selling company (Company”) that sells wine and spirits, regarding three Facebook posts and one YouTube video that communicated earnings claims. DSSRC expressed concern about the posts conveyed claims regarding the potential income that a typical salesforce member could earn from the Company's business opportunity, including the...
DSSRC Administrative Closure #308
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that markets nutrition, personal care, home cleaning and cosmetic products regarding two references to “financial freedom.” One reference was made by an independent contractor and disseminated on his LinkedIn page and the second reference was made on the Company website. The website also featured a short...
DSSRC Administrative Closure #307
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") headquartered in Europe that markets magnetic jewelry products regarding 12 product performance claims (including hashtags) that were disseminated on Facebook. DSSRC was concerned that the claims at issue communicated the message that the Company’s products could prevent or treat health-related conditions...
DSSRC Administrative Closure #306
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") regarding five social media posts that communicated earnings claims and three posts that communicated health-related product claims. DSSRC expressed concern that the earnings claims conveyed that a typical salesforce member could achieve “financial freedom” and that typical Company salesforce members could earn...
DSSRC Administrative Closure #305
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that sells bath and body products regarding four social media posts that communicated earnings claims and two posts that communicated health related claims. DSSRC expressed concern about the posts conveyed claims regarding the potential income that a typical salesforce member could earn from the Company's...
DSSRC Administrative Closure #304
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets nutritional supplement and weight-loss products regarding health claims disseminated on social media by Company salesforce members. The claims at issue consisted of six health-related product claims that were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #303
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that markets dietary supplements and other personal care products regarding certain claims that appeared on social media platforms including Facebook, LinkedIn, YouTube and TikTok. The claims identified by DSSRC in the inquiry consisted of five earnings claims and two product claims. With respect to the...
DSSRC Administrative Closure #302
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that markets travel products regarding 15 earnings claims that were disseminated on social media by members of the Company's salesforce. DSSRC expressed its concern to the Company about the social media posts conveying claims regarding the potential income that a typical salesforce member could earn from the...
DSSRC Administrative Closure #301
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company ("Company") that markets health, fitness and beauty products regarding five earnings claims disseminated by members of the Company's salesforce on Facebook.
DSSRC Administrative Closure #300
The Direct Selling Self-Regulatory Council (DSSRC) reached out to a direct selling company ("Company") that sells home and personal fragrance products regarding seven earnings claims disseminated on social media by members of the Company's salesforce. DSSRC expressed concern about the posts conveying claims regarding the potential income that a typical salesforce member could earn from the Company's...
DSSRC Administrative Closure #299
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets health and wellness products regarding nine earnings and health claims disseminated on Facebook by Company salesforce members.
DSSRC Administrative Closure #298
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that sells health, wellness, and beauty products, regarding 11 product performance claims and two earnings claims that were disseminated by salesforce members on Facebook, Pinterest, Instagram and X.
DSSRC Administrative Closure #297
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that sells personal care and cleaning products regarding claims disseminated on social media by Company salesforce members. The claims at issue consisted of nine earnings claims that were disseminated on Facebook and Loom.
DSSRC Administrative Closure #294
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company that markets household good products regarding seven social media posts that were disseminated by a salesforce member on Facebook and YouTube.
DSSRC Administrative Closure #293
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company regarding seven earnings claims disseminated on social media by Company salesforce members.
DSSRC Administrative Closure #292
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company that sells meal kits and other food accessories regarding 13 earning claims that were disseminated on Facebook, LinkedIn, and TikTok by Company salesforce members.
DSSRC Administrative Closure #291
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) specializing in the clean air industry regarding ten earnings claims disseminated on social media by Company salesforce members.
DSSRC Administrative Closure #290
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two social media posts disseminated by Company salesforce members on Facebook.
DSSRC Administrative Closure #289
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding claims disseminated on social media by Company salesforce members.
DSSRC Administrative Closure #288
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding eight claims disseminated on social media by Company salesforce members.
DSSRC Administrative Closure #287
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding eleven earning claims disseminated on social media by Company salesforce members.
DSSRC Administrative Closure #286
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding ten earning claims disseminated on Facebook and Instagram and which included terms such as “financial freedom”, “unlimited earnings potential” and “debt free.”
DSSRC Administrative Closure #285
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding nine earnings claims and one product performance claim disseminated on Facebook by Company salesforce members.
DSSRC Administrative Closure #284
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding nine earnings claims disseminated on social media by Company salesforce members. The posts at issue originated from Facebook and Pinterest.
DSSRC Administrative Closure #281
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding seven product performance claims disseminated on Facebook by Company salesforce members.
DSSRC Administrative Closure #280
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding ten earnings claims disseminated on social media by Company salesforce members. The posts at issue originated from Facebook and YouTube.
DSSRC Administrative Closure #279
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding eight earning claims disseminated on Facebook by Company salesforce members.
DSSRC Administrative Closure #278
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding eight product performance claims and nine earnings claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook, TikTok, and YouTube.
DSSRC Administrative Closure #277
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding twelve earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #276
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding fourteen earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and Pinterest.
DSSRC Administrative Closure #275
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets home décor and fashion accessories regarding eight earning claims disseminated on social media by Company salesforce members. All of the claims at issue were disseminated on Facebook.
DSSRC Administrative Closure #274
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets beauty products regarding seven earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #273
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets CBD products regarding fifteen product performance claims disseminated on social media by Company salesforce members. More specifically, the claims at issue were disseminated on Facebook and Instagram.
DSSRC Administrative Closure #272
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding twelve earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and on the Company website.
DSSRC Administrative Closure #271
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding twelve product performance claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook, Vimeo, Pinterest, and Twitter.
DSSRC Administrative Closure #270
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets CBD products regarding eleven product performance claims and one earnings claim disseminated on social media by Company salesforce members. The claims at issue were disseminated on Twitter, TikTok, Facebook and Instagram. Although several of the social media posts were disseminated in 2019 or...
DSSRC Administrative Closure #269
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding six earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #268
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding eight product claims and four earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #267
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding ten product claims and four earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook, YouTube, and Twitter.
DSSRC Administrative Closure #266
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that specializes in hemp-based CBD oil products regarding eleven product claims and four earning claims that were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #265
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding nine earning claims disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook, YouTube, and Twitter.
DSSRC Administrative Closure #264
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets jewelry and other accessories regarding ten earnings claims that were disseminated on social media. All of the claims appeared on Facebook.
DSSRC Administrative Closure #263
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that markets clothing products regarding seven earnings claims that were disseminated on Facebook by Company salesforce members.
DSSRC Administrative Closure #262
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding fourteen product performance claims and one earnings claim disseminated on social media by Company salesforce members. The claims at issue were disseminated on Facebook and YouTube.
DSSRC Administrative Closure #261
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding ten earnings claims that were disseminated on social media by Company salesforce members. The claims at issue were all disseminated on Facebook.
DSSRC Administrative Closure #260
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct-selling company (“Company”) that markets dietary supplement products regarding six product performance claims that were disseminated on social media by the Company’s salesforce members and as well as weight-loss depictions and testimonials that appeared on the Company’s website. DSSRC expressed its concerns regarding the claims that the...
DSSRC Administrative Closure #259
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) that sells women’s beauty products regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The claims at issue originated from eleven social media posts disseminated on Facebook. The eleven Facebook posts included claims that salesforce members can generally...
DSSRC Administrative Closure #258
The Direct Selling Self-Regulatory Council (DSSRC) initiated an inquiry involving a direct selling company (“Company”) regarding four earnings claims disseminated by Company salesforce members on Facebook, LinkedIn, Pinterest, and YouTube. The inquiry pertained to the Company’s use of terms such as “a debt-free life,” “financial freedom,” and social media posts suggesting that the typical Company sales...
DSSRC Administrative Closure #257
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct-selling company (“Company”) that markets travel-related products regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members as well as an earnings claim made in the Company’s compensation plan on the Company’s website. The claims which were disseminated by Company salesforce members were...
DSSRC Administrative Closure #256
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding nine earnings claims that were disseminated on social media by the Company’s salesforce members on Facebook and the Company website.
DSSRC Administrative Closure #255
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims and one health-related product claim that were disseminated on social media by the Company’s salesforce members. The claims at issue were all disseminated on Facebook.
DSSRC Administrative Closure #254
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The claims at issue were disseminated on Facebook, Instagram, and YouTube. DSSRC contacted the Company and expressed concern that these social media posts could be reasonably interpreted by consumers as...
DSSRC Administrative Closure #253
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding earnings claims that were disseminated on social media by the Company’s salesforce members. All of the posts at issue were disseminated on Facebook. DSSRC contacted the Company and expressed concern that these social media posts could be reasonably interpreted by consumers as meaning that the typical...
DSSRC Administrative Closure #252
The Direct Selling Self-Regulatory Council (DSSRC) opened an inquiry with a direct selling company (the “Company”) regarding certain earnings claims disseminated on social media by the Company’s salesforce members. The claims at...
DSSRC Administrative Closure #251
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims and health-related claims that were disseminated on social media by the Company’s salesforce...
DSSRC Administrative Closure #250
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. All but one of the...
DSSRC Administrative Closure #249
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct-selling company (“Company”) that sells wellness products regarding certain product and earnings claims that were disseminated on social media by the Company’s...
DSSRC Administrative Closure #248
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The claims at issue included...
DSSRC Administrative Closure #247
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (“Company”) regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The claims at issue were all disseminated on Facebook. DSSRC contacted the Company and expressed concern that these social media posts could be reasonably interpreted by consumers as meaning that the...
DSSRC Administrative Closure #246
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct-selling company (“Company”) that sells cosmetic products regarding certain earnings claims that were disseminated on social media by the Company’s salesforce members. The posts were identified as part of DSSRC’s ongoing monitoring process, which found thirteen posts on Facebook, YouTube, and Twitter.
DSSRC Administrative Closure #245
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct-selling company (“Company”) that sells several brands of weight-loss and nutritional wellness products regarding certain earnings claims and health-related product claims that were disseminated on social media by the Company’s salesforce members. The posts were identified as part of DSSRC’s ongoing monitoring process, which found three...
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DSSRC Administrative Closure #230
The Direct Selling Self-Regulatory Council (DSSRC) initiated an inquiry involving a direct selling company (“Company”) regarding six earnings claims disseminated by Company salesforce members on Facebook, Twitter and YouTube. The claims identified by DSSRC included, but were not limited to, “earn 4 to 5 figures income,” “you decide your income,” “I paid off my entire family’s medical bills,” “I just paid...
DSSRC Administrative Closure #229
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DSSRC Administrative Closure #216
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a company (“Company”) regarding eighteen social media posts disseminated on Facebook and YouTube that were identified pursuant to its monitoring of the direct selling industry. Fifteen of the social media posts made health-related claims regarding skin conditions such as, but not limited to, eczema and psoriasis. DSSRC was also concerned that...
DSSRC Administrative Closure #215
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding four social media posts disseminated on Facebook that were identified pursuant to its monitoring of the direct selling industry. Three of the posts included references to the ability for Company salesforce members to earn full time income. In addition, the remaining post referenced the COVID-19...
DSSRC Administrative Closure #214
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding four social media posts disseminated on Facebook and one YouTube video that were identified pursuant to its monitoring of the direct selling industry. DSSRC expressed its concern to the Company that all five posts communicated atypical earnings claims regarding the amount of income that could be...
DSSRC Administrative Closure #213
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding five social media posts disseminated on Facebook and one YouTube video that were identified pursuant to its monitoring of the direct selling industry. The Facebook posts included references to the efficacy of the Company’s products to treat several health-related conditions including arthritis and...
DSSRC Administrative Closure #212
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a company (“Company”) regarding thirteen social media posts disseminated on Facebook that were identified pursuant to its monitoring of the direct selling industry. The posts included references to, among other things, the Company’s “unlimited income potential” and how salesforce members can earn “$1,000 a month,” become “financially...
DSSRC Administrative Closure #211
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three social media posts disseminated on YouTube, Facebook, and TikTok. DSSRC was concerned that these posts may be reasonably interpreted as communicating that by partaking in the Company’s business opportunity, salesforce members would earn a substantial income. The posts were identified by DSSRC...
DSSRC Administrative Closure #210
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DSSRC Administrative Closure #201
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding five social media posts that DSSRC was concerned were communicating inappropriate earnings claims. The posts included references such as “replace another income,” “full-time opportunity,” “travel for free,” “what would you do with an extra $500 a month?”, and “looking for a new career or...
DSSRC Administrative Closure #200
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DSSRC Administrative Closure #192
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding three social media posts disseminated by company salesforce members that communicated health-related product claims. In addition, DSSRC also inquired regarding certain earnings claims that appeared on the Company’s website as well as earnings claims disseminated by salesforce members on social...
DSSRC Administrative Closure #191
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DSSRC Administrative Closure #185
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding one social media post disseminated by a company salesforce member. Some of the language in the post made an atypical representation regarding the level of income that a salesforce member could expect to earn from the Company’s business opportunity. The post was identified by DSSRC pursuant to...
DSSRC Administrative Closure #184
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding six social media posts. The inquiry involved a number of health-related posts which included claims that the Company’s products can treat Alzheimer’s disease and cancer and prevent diabetes and strokes. The posts were identified by DSSRC pursuant to its ongoing, independent monitoring of the...
DSSRC Administrative Closure #183
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding nine social media posts. DSSRC was concerned that these posts made both explicit and implied claims that typical salesforce members of the Company could generally expect to earn significant, full-time, or career replacement income through participating in the Company’s business opportunity. The...
DSSRC Administrative Closure #182
DSSRC Administrative Closure #181
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding one social media post that was disseminated by a salesforce member of the Company. DSSRC was concerned that the post communicated that a typical salesforce member will earn a significant amount of income from the Company’s business opportunity.
DSSRC Administrative Closure #180
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DSSRC Administrative Closure #178
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four social media posts that conveyed the message that the Company's products can treat several serious health-related conditions including diabetes and autism. DSSRC was also concerned that some of the social media posts communicated the message that salesforce members can generally expect to...
DSSRC Administrative Closure #177
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DSSRC Administrative Closure #170
DSSRC contacted a direct selling company regarding three social media posts disseminated by salesforce members that communicated the efficacy of the Company’s products to treat ADHD in children, COVID-19 and other health-related conditions. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #169
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding three social media posts that DSSRC was concerned conveyed, either through depictions or accompanying text, that the Company’s salesforce members can earn a significant income through the Company’s business opportunity.
DSSRC Administrative Closure #168
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four social media posts that DSSRC was concerned contained health-related product claims including statements that the Company’s products could prevent, treat, or cure COVID-19. DSSRC identified the subject social media posts that were made by Company salesforce members through its ongoing...
DSSRC Administrative Closure #167
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DSSRC Administrative Closure #161
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four Facebook posts that were disseminated by salesforce members of the Company. All four of the post conveyed strong health-related product claims including the message that the Company’s products were effective to treat serious health conditions such as COVID-19, ADHD, dementia, Alzheimer’s...
DSSRC Administrative Closure #160
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding social media posts that were disseminated by salesforce members. The subject claims and social media posts came to DSSRC’s attention through its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #159
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four Facebook posts that were disseminated by Company salesforce members. All four of the posts made reference to prospective salesforce members being able to “replace lost income” through the Company’s business opportunity and one of the posts included an implied reference to achieving...
DSSRC Administrative Closure #158
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DSSRC Administrative Closure #149
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding one Facebook post and two TikTok posts disseminated by salesforce members of the Company. DSSRC was concerned that the Facebook post conveyed disease treatment claims and that the TikTok posts contained strong health-related product performance claims including claims that the Company’s...
DSSRC Administrative Closure #148
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DSSRC Administrative Closure #138
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts disseminated by salesforce members. DSSRC was concerned that one of the posts conveyed claims that the Company’s products can protect against disease including express claims stating that the salesforce member is “COVID free” and the products being a “pandemic response.”...
DSSRC Administrative Closure #137
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DSSRC Administrative Closure #124
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DSSRC Administrative Closure #120
DSSRC Administrative Closure #119
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DSSRC Administrative Closure #116
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding six posts made on social media by Company salesforce members. DSSRC was concerned that the social media posts disseminated by these Company salesforce members included unsubstantiated product, health and wellness benefits including claims that the Company’s products can protect against...
DSSRC Administrative Closure #115
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts by Company salesforce members that referenced serious health-related conditions that purportedly could be addressed by use of the Company’s products.
DSSRC Administrative Closure #114
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts making claims about the Company’s products. The Facebook posts were disseminated by a Company salesforce member and a former salesforce member of the Company. The social media posts were identified during DSSRC’s monitoring of the...
DSSRC Administrative Closure #113
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts disseminated by Company salesforce members that were identified during DSSRC’s monitoring of the direct selling industry. DSSRC expressed its concern to the Company that all of the posts implied that the Company products are effective to treat a number of health-related...
DSSRC Administrative Closure #112
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts that were identified during DSSRC’s monitoring of the direct selling industry and disseminated by Company salesforce members.
DSSRC Administrative Closure #111
DSSRC Administrative Closure #110
DSSRC Administrative Closure #109
DSSRC Administrative Closure #108
The Direct Selling Self-Regulatory Council (“DSSRC”) commenced an inquiry with a direct selling company (“Company”) regarding three Facebook posts disseminated by Company salesforce members.
DSSRC Administrative Closure #107
DSSRC Administrative Closure #106
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) about three Facebook posts disseminated by salesforce members of the Company. Two of the posts in question implied that the Company’s nutritional products could help individuals that consume such products fight viruses including COVID-19. The other post made specific health-related product efficacy claims...
DSSRC Administrative Closure #105
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) about two Facebook posts disseminated by salesforce members of the Company. The posts in question implied that engaging in direct selling of the Company’s products could provide replacement income for those out of work due to COVID and/or a new career during the current public health crisis.
DSSRC Administrative Closure #104
DSSRC Administrative Closure #103
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (Company) regarding three Facebook posts disseminated by its salesforce members. The subject claims and social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #102
DSSRC Administrative Closure #101
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (Company) regarding three coronavirus related hashtags that accompanied a post stating that the Company’s product can strengthen the immune system. Earlier this year, the Federal Trade Commission (FTC) stated that coronavirus related claims and hashtags when coupled with claims that a product can strengthen or boost the...
DSSRC Administrative Closure #100
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding two Facebook posts and one Instagram post disseminated by Company salesforce members. All three posts referenced the ability of the direct selling company’s product to prevent and eliminate the coronavirus.
DSSRC Administrative Closure #99
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company regarding three Facebook post disseminated by its salesforce members. The subject claims and social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #98
DSSRC Administrative Closure #97
DSSRC Administrative Closure #96
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts disseminated by salesforce members that included claims that the Company’s products can assist in treating a number of serious health-related conditions including, but not limited to, Alzheimer’s, Parkinson’s disease and Multiple Sclerosis.
DSSRC Administrative Closure #95
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DSSRC Administrative Closure #81
DSSRC Administrative Closure #80
DSSRC contacted a direct selling company regarding two Facebook posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the posts conveyed the unsupported health-related message that the Company’s direct selling products can protect...
DSSRC Administrative Closure #79
DSSRC contacted a direct selling company regarding three social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that the posts conveyed unsupported product, health and wellness benefits and the message that the Company’s...
DSSRC Administrative Closure #78
DSSRC Administrative Closure #77
DSSRC Administrative Closure #76
Social media advertising for a direct selling company that markets health and wellness products came to the attention of the Direct Selling Self-Regulatory Council (DSSRC) pursuant to its monitoring of the direct selling industry. DSSRC identified three Facebook posts that were disseminated by Company salesforce members as communicating egregious health-related claims. One post stated “build your immune...
DSSRC Administrative Closure #75
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DSSRC Administrative Closure #71
DSSRC Administrative Closure #70
DSSRC contacted a direct selling company about two Facebook posts disseminated by the company’s salesforce members that conveyed product performance stating and/or implying that the company’s products can help prevent or treat COVID-19. Both posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #69
DSSRC contacted a direct selling company about two YouTube videos disseminated by the company’s salesforce members that conveyed product performance claims while referencing the current global pandemic. Both videos came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #68
DSSRC contacted a direct selling company about two social media posts disseminated by the company’s salesforce members that conveyed product performance claims. Both social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #67
DSSRC contacted a direct selling company about certain social media posts disseminated by salesforce members regarding product efficacy claims that referenced “Corona Virus.” DSSRC also identified more general product claims regarding viruses that DSSRC was concerned could be reasonably interpreted could be reasonably interpreted as meaning that the company’s products are effective against the...
DSSRC Administrative Closure #66
DSSRC contacted a direct selling company about three social media posts disseminated by salesforce members regarding business opportunities during the pandemic. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #65
DSSRC contacted a direct selling company about three business opportunity posts disseminated by salesforce members. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #64
DSSRC contacted a direct selling company about three social media post disseminated by salesforce members. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media posts conveyed unsubstantiated product health and wellness benefit claims related to the current COVID-19...
DSSRC Administrative Closure #63
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DSSRC Administrative Closure #52
DSSRC contacted a direct selling company about four social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media posts conveyed unsubstantiated product, health and wellness benefits that the Company’s direct...
DSSRC Administrative Closure #51
DSSRC Administrative Closure #50
DSSRC Administrative Closure #49
DSSRC Administrative Closure #48
DSSRC contacted a direct selling company about a social media post disseminated by a salesforce member. The subject social media post came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media post conveyed unsubstantiated product, health and wellness benefits that the Company’s direct selling...
DSSRC Administrative Closure #47
DSSRC Administrative Closure #46
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DSSRC Administrative Closure #44
DSSRC Administrative Closure #43
DSSRC Administrative Closure #42
DSSRC contacted a direct selling company about two social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that two of the social media posts conveyed unsubstantiated product, health and wellness benefits that the Company’s...
DSSRC Administrative Closure #41
DSSRC Administrative Closure #40
DSSRC Administrative Closure #39
DSSRC contacted a direct selling company about thirty-five social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that thirty-three of the social media posts...
DSSRC Administrative Closure #38
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DSSRC Administrative Closure #32
Social media posts disseminated by distributors for a multi-level company came to the attention of the Direct Selling Self-Regulatory Council (DSSRC) pursuant to its internal monitoring process. More specifically, one Instagram post...
DSSRC Administrative Closure #31
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DSSRC Administrative Closure #19
DSSRC Administrative Closure #18
In 2019, DSSRC contacted a direct selling company regarding several earnings claims on the direct selling company’s website as well as claims that were being disseminated by the company’s salesforce on social media.
DSSRC Administrative Closure #17
DSSRC contacted a direct selling company (the “Company”) about earnings claims disseminated on the Company’s website and on social media by salesforce members. Specifically, DSSRC identified a number of express and implied earnings claim that referenced financial freedom, exorbitant bonuses and vacations, luxury cars, the ability to pay off college loans and generous reward programs. The advertising also...
DSSRC Administrative Closure #16
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DSSRC Administrative Closure #11
In 2020, a direct selling company contacted DSSRC seeking guidance regarding company events at which top distributors are recognized. The direct selling company stated that it had previously presented some of its highest performing distributors with oversized checks at the event but, since the success of those top distributors was not typical, it was concerned that the oversized checks might convey an...
DSSRC Administrative Closure #10
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DSSRC Administrative Closure #3
DSSRC Administrative Closure #2
DSSRC opened an inquiry with a direct selling company regarding Instagram and Facebook posts made by the Company salesforce regarding claims of achieving “financial freedom,” a claim stating that potential recruits can “earn the income that want,” an unqualified claim of atypical earnings and an unqualified claim regarding company incentive trips.
DSSRC Administrative Closure #1
The Direct Selling Self-Regulatory Council (DSSRC) inquired with a direct selling company regarding twos social media posts disseminated by members of the Company salesforce. The first claim appeared on Instagram and stated that that the salesforce member was able to more than replace her salary from here previous, full-time job.