DSSRC Case Decisions and Administratively Resolved Inquiry Summaries
Case Decisions
Case #156-2024: Administrative Closure – Cabi, LLC
Cabi, LLC ("Company") is a multi-level direct selling company, headquartered in Carson, CA and founded in 2002, that sells clothing and personal accessories.
Case #155-2024: Administrative Closure – Touchstone Crystal, Inc.
Touchstone Crystal, Inc. (“Touchstone Crystal” or the "Company") is a multi-level direct selling company that sells jewelry and accessories.
Case #154-2024: Administrative Closure – Unicity International
Unicity International ("Company") is a multi-level direct selling company headquartered in Provo, UT and founded in 1986 that sells nutritional supplements and self-care products.
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.
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Administratively Resolved Inquiry Summaries
Case #47-2021: –Monitoring Inquiry– Root Wellness, LLC
BBB NATIONAL PROGRAMS, INC.
The Direct Selling Self-Regulatory Council
Case Number 47-2021: –Monitoring Inquiry– Root Wellness, LLC
Company Description
Root Wellness, LLC (“Root Wellness” or the “Company”), a direct selling company located in Brentwood, Tennessee, founded in 2019, offers health and wellness nutritional supplement products.
Basis of Inquiry
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.
DSSRC identified the following representative product performance claims being disseminated on the Company website and by Company salesforce members on social media. DSSRC was concerned that the representative claims below communicate that Root Wellness products can protect against serious health-related conditions.
- “ROOT Testimonial Tuesday
Fatty Liver, Psoriasis, Childhood ADHD, Chronic Fatigue”
- “…for over 10 years I have suffered with what is medically diagnosed as medium/aggressive Psoriasis…mainly on my legs…last year it took a severe twist…it became infected and I had Cellulitis which could have lead to possible amputation...I think you will find the photographs will outline where I was...it was a very worrying time and as I am sure you can appreciate I genuinely did not know what my future help. I was put on a course of Methotrexate and I have to say it saved the day and I started to improve. But the scars and scaly skin remained…AS most people who suffer with Psoriasis will tell you its not just the typical scarring you live with it’s the Psychological scars…living in Sunny Cyprus I was not able to wear shorts and sunbathe…as people do not understand this dreadful disease…creams ointments…constant visits to Dermatologists…all with different interpretations of how to address the issue !! Expensive applications and even a trip to the dead sea in Israel…as this is supposed to offer a healing mineral…so after all these years and realizing I was actually dealing with an auto immune problem so started using Keto diets…vitamins and minerals which have helped but still the scarring remained and had to lean on steroid ointments to keep under control…so a life of steroid and methotrexate was now a reality…then I was introduced to you lovely people…Clean Slate. WOW…Following the instructions 2 x 10 drops per day for 3 weeks and I think you will see the changes. No itching, scratching…no ointments apart from moisturizing…I have stopped taking methotrexate and at last I can see light at the end of this dreadful 10 year tunnel...”
- Images of psoriasis healing over 8 weeks time
- “Our Autism Journey - Non-verbal no longer! Hi! My son Michael turned 14 in January 2021. He had been completely non verbal since he was about 15 months old. Stephanie reached out to me and invited me to a zoom call, to discuss a heavy metals detox product (Clean Slate). I was impressed by everything I heard on the call, so I gave it a try. Within 10 days my son was sleeping through the night (something he had never done). He was taking naps during the day too, on some days. By the end of the 3rd week, he started mumbling consonants : the first ones I noticed were g, b and m. With some practice, he could say his name, (Michael), Koko, come, go, about half of the letters of the alphabet. With colours, numbers and letters of the alphabet, it was obvious that he had been learning things all these years, but just couldn't express himself. We are about 3 months in with Clean Slate now, his skin is clear (he had some recurring patches), he is calm and confident and is gaining new words. We are so happy about the progress he is making and sooooo excited for the future!!!”
- “Once you’re on your Maximum then you’re going to notice it
And then you will see the results in the blood results too…
Fibromyalgia Rheuma Arthritis Psoriasis Eczema Darmon Disorders and Still a lot more can be treated with it”
- “My favorite ‘side effects’ of this product: Morning fog has been lifted, Belly bloat has been blasted, AND long time stubborn nail fungus? Dissolving, as if by magic! These two products truly support the quest for an EMPOWERED lifestyle!!! – Olenka C.” https://therootbrands.com/reviews
- “My favorite ‘side effects’ of this product: Morning fog has been lifted, Belly bloat has been blasted, AND long time stubborn nail fungus? Dissolving, as if by magic! These two products truly support the quest for an EMPOWERED lifestyle!!! – Olenka C.” https://therootbrands.com/reviews
- “My 79 year old husband was showing signs of dementia and had given up playing the trumpet, his difficulty in speaking clearly and finding the right words had become more pronounced. He started both products in March and is back to daily trumpet practice. His speech is slowly improving and while he still has difficulties, he is holding longer conversations. He had avoided speaking except to family and close friends so this is a great sign. Also, he is back to his Painting and his Astrological pursuits. I take both products and tell my friends 82 is the new 62 but truly feel my energy and focus is like being back in my fifties. – Joy H. https://therootbrands.com/reviews
- “I was introduced to Clean Slate several months ago and I am noticing some of my autoimmune symptoms are subsiding, my skin is amazing and those pesky sugar cravings are gone. I am pleasantly surprised and can’t wait to see what happens in another 3 months!” https://therootbrands.com/reviews
Company’s Position
According to the Company website, Root Wellness offers three products:
- Clean Slate: Clean Slate is a zeolite-based proprietary patent-pending formulation that supports the removal of toxins from cells, body, and brain tissue. According to the Company, Clean Slate assists in the reduction of negative inflammation and supports the absorption of nutrients by the removal of toxins which may block nutrient binding.
- Zero-In: Made with turmeric, pine bark, velvet bean seed, and vitamin D, Zero-In helps support increased attention span and concentration levels through a natural, proprietary brain formula and aids healthy brain function and focus while improving the delivery of oxygen to cells.
- Restore: Restore is described on the Company website as a weight-loss aid that contains “everything your body needs to run full of energy all day long.” The product also purportedly provides antioxidant and anti-inflammatory benefits and supports bone health, healthy blood pressure, and the immune system.
Published Articles and Studies on Product Ingredients
The Company provided several published articles to DSSRC, which it maintained demonstrated a direct correlation between the ingredients contained in Root Wellness products with the improvement of certain health-related conditions. A summary of the documentation provided by Root Wellness is provided below:
In an article entitled Biological and therapeutic effects of ortho-silicic acid and some ortho-silicic acid-releasing compounds: New perspectives for therapy,[1] the authors concluded that ortho-silicic acid might be a prominent therapeutic agent in humans. Some potential therapeutic and biological effects on bone formation and bone density, Alzheimer disease, immunodeficiency, skin, hair, and nail condition, as well as on tumor growth. The article noted that the most important sources that release ortho-silicic acid as a bioavailable form of silicon are colloidal silicic acid, silica gel, and zeolites.
The article explained that although all these compounds are characterized by substantial water insolubility, they release small, but significant, equilibrium concentration of ortho-silicic acid in contact with water and physiological fluids. Even though certain pharmacological effects of these compounds might be attributed to specific structural characteristics that result in profound adsorption and absorption properties, the compounds all exhibited similar pharmacological profiles readily comparable to ortho-silicic acid effects. The authors stated that the most unusual ortho-silicic acid-releasing agents are certain types of zeolites and that numerous biological activities of some types of zeolites documented might be attributable to the ortho-silicic acid-releasing property.
In conclusion, the article determined that the therapeutic perspectives of both ortho-silicic acid and ortho-silicic acid -releasing derivatives provide additional insights into biological mechanisms of action and require larger studies on both animals and humans.
A 2003 study provided by the Company entitled Anticancer And Antioxidative Effects Of Micronized Zeolite Clinoptilolite[2] evaluated micronized zeolite on various tumor cell cultures and tumor bearing animals. Root Wellness maintained that according to the results of the study, dosages of between 0.05-0.5 mg/ml of micronized zeolite led to the improvement of the overall health status, prolongation of life and a decrease of tumor size in some cases. The test administrators concluded that the data confirmed that malignant and normal cells respond differently to the antioxidant effects of micronized zeolite, which means that micronized zeolite could have antioxidative and anti-tumor effects at the same time.
Another study submitted by the Company, Antiviral Properties Of Clinoptilolite,[3] concluded that concentrations of 0.5 and 5mg/ml of micronized zeolite induced a very low antiviral effect or the antiviral was not observed at all, while, conversely, concentrations of 12, 25, and 50mg/ml of micronized zeolite induced a significant inhibitory effect upon viral proliferation. The preliminary results of the study indicated an antiviral property of clinoptilolite at higher concentrations that open a possibility of therapeutical application of micronized zeolite either locally (skin) against herpes virus infections or orally in cases of adenovirus or enterovirus infections.
Root Wellness also maintained that its submission of a published article, “A Critical Review On Zeolite Clinoptilolite Safety And Medical Applications In Vivo”[4] supported the health effects and safety in medical applications of different clinoptilolite-based materials. The authors concluded that clinoptilolite-based materials may be regarded as safe for in-vivo consumption. A variety of highly positive effects on human animal health were documented for clinoptilolite based materials. The study noted that due to clinoptilolite’s ion exchange and adsorption properties and consequent detoxifying effects it is proven useful for the elimination of a variety of contaminants from the body.
In “Neuroprotective Actions of Clinoptilolite and Ethylenediaminetetraacetic Acid Against Lead-induced Toxicity in Mice Mus musculus,”[5] the study administrators investigated the occurrence of oxidative stress in developing animals due to lead (Pb(2+))[6] neurotoxicity in the brain regions of mice. Root Wellness maintained that the results of study indicated the neuroprotective potential of clinoptilolite and ethylenediaminetetraacetic acid against Pb(2+) toxicity.
In another study[7] on mice provided by Root Wellness, surface chemistries were evaluated for heavy metal capture from biological fluids, various facets of the materials’ biocompatibility, and the suitability of these materials as potential therapeutics. Of the materials tested, thiol-functionalized self-assembled monolayers on mesoporous supports (SAMMS) proved most capable of removing selected heavy metals from biological solutions (i.e., blood, urine, etc.). Consequentially, thiol-functionalized SAMMS was further analyzed to assess the material’s performance under a number of different biologically relevant conditions (i.e., variable pH and ionic strength) to gauge any potentially negative effects resulting from interaction with the sorbent, such as cellular toxicity or the removal of essential minerals. Additionally, cellular uptake studies demonstrated no cell membrane permeation by the silica-based materials generally highlighting their ability to remain cellularly inert and thus non-toxic. As a result, the authors concluded that organic ligand-functionalized nano porous silica materials could be valuable for detoxification therapeutics and potentially other biomedical applications as needed.
The Company maintained that the bioavailability of silicon was supported by a published review entitled “Biological and therapeutic effects of ortho-silicic acid and some ortho-silicic Acid-releasing compounds: New perspectives for therapy.”[8] According to the article, zeolite is among the most important sources that release ortho-silicic acid as a bioavailable form of silicon and that the most unusual ortho-silicic acid-releasing agents are certain types of zeolites, a class of aluminosilicates with well described ion(cation)-exchange properties.
As further support for its position that clinoptilolite treatment might affect cancer growth, Root Wellness provided DSSRC with an evaluation of clinoptilolite treatment of mice and dogs suffering from a variety of tumor types, which led to improvement in the overall health status, prolongation of lifespan, and decrease in tumor size.[9] In this study, local application of clinoptilolite to skin cancers of dogs effectively reduced tumor formation and growth. In addition, toxicology studies on mice and rats demonstrated that the treatment did not have negative effects.
Heavy Metal Testing
Root Wellness provided DSSRC with the results from seven individuals who used a 24-hour home urine test kit to screen or detect for the presence of 22 different heavy metals in the body. The tests were conducted between September 2018 and May 2020. The results indicated that presence of several heavy metals decreased after using the test product.
Heart Rate Variability Study
The Company provided DSSRC with a single case study evaluating the effects of the Company’s Clean Slate and Zero-In on the regulation of the body using a Nilas-MV heart rate variability monitoring system. The study measured the influence on vegetative nervous system and stress index; the balancing of the processes in the body - in particular, the neurotransmitter systems; the improvement of the sleep cycle; and the promotion of a longer and healthier life and influences on metabolism. Root Wellness maintained that the study supported its position that it's two products lead to less tension, improved cardiovascular function, better brain function, a better overall feeling, an improvement of the psycho-emotional condition and to a more restful sleep.
The study was conducted by clipping two electrodes near the subject’s wrist and a 5-minute measurement to get 300 heartbeat intervals. After the initial test, the subject was administered 10 drops of the Clean Slate product and two caps of Zero-One. After the initial baseline measurement, a heartrate variability test was performed 45 minutes after ingestion. To see how long the effect of Root Wellness’ Clean Slate and Zero-In products are effective in the body, further measurements were then taken. According to Root Wellness, after administration of the products, the results showed a healthy heart rate variability index and all physiological systems increased by more than 50% after 45 minutes.
ROFES Study
The ROFES method is based on a measurement of the biological point on the inside of the left wrist bypassing an electrical microcurrent pulse through all organs. The device is attached to the left hand in such a way that the active electrode of the device rests on the biologically active point on the left wrist. The computer program then compares the measured values received with the normal values corresponding to the organism of a healthy person according to his age.
The ROFES tests the functional state of 17 important organs and systems and shows how stress, physical strain, wrong nutrition, harmful habits, weather changes, environmental problems, etc., affect the body. According to Root Wellness, the test is a reliable indicator of how each individual organ reacts to and adapts to these stresses and that the test data indicated a significant decrease in the markers meaning that the test subject had a high level of health and energy resource after being administered the Company’s Clean Slate and Zero-In products.
Case Disposition
Root Wellness engaged with DSSRC at the beginning of the self-regulatory inquiry by participating in telephone calls and providing DSSRC with studies, which it contended supported the claims at issue. However, the Company failed to respond to DSSRC’s follow-up correspondence requesting additional information about the materials that were originally provided by the Company. Notwithstanding, during the pendency of the inquiry, it appeared that Root Wellness removed the review page on the Company website from which three of the testimonial claims at issue appeared (i.e., https://therootbrands.com/reviews).[10] DSSRC determined that the apparent removal of the review page from the Company website was necessary and appropriate and, accordingly, the continuing basis for the self-regulatory inquiry was limited to the remaining social media posts.
DSSRC determined that the social media posts at issue include claims that Root Wellness products can treat a number of serious health related conditions including, but not limited to, psoriasis, attention-deficit/hyperactivity disorder, chronic fatigue, fatty liver disease (Hepatic Steatosis), fibromyalgia, and rheumatoid arthritis.
DSSRC disagreed with Root Wellness’ contention that because the Company did not authorize the claims disseminated in the social media posts it was not responsible for the representations made by its independent salesforce members (i.e., Root Ambassadors). As DSSRC has noted in past inquiries, for purposes of a self-regulatory inquiry, the fact that a social media post from a direct selling company’s independent salesforce members was not authorized by the company does not absolve the company from any responsibility regarding the post.[11] DSSRC received no indication from Root Wellness that it made any effort to contact the independent salesforce members who disseminated the posts or took any enforcement measures to reconcile the matter. As noted in his October 15, 2020, remarks to the Direct Selling Association, FTC Commissioner Noah Philips stated that “claims made by salesforce members are attributable to direct selling companies themselves.”
As to the health-related claims at issue, it is well established that health-related claims should be supported by competent and reliable scientific evidence.[12] The FTC generally defines competent and reliable scientific evidence as: “test, analyses, research, studies, or other evidence based on the expertise of professionals in the relevant area that has been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted in the profession to yield accurate and reliable results.”[13]
While the Company provided a number of studies which it maintained demonstrated that some individual ingredients contained in Root Wellness’ Clean Slate and Zero-In products could be beneficial at removing certain heavy metals and toxins from the body, DSSRC concluded that the studies did not provide the necessary evidence to show that using the Company’s products as directed would result in relieving or diminishing the specific health-related conditions[14] referenced in the social media posts at issue. For example, a number of studies provided by Root Wellness did not indicate that the resulting data was statistically significant and there was no confirmation that dosages of the ingredients evaluated in the studies correlated with the presence of the ingredient as found in the Root Wellness products. More specifically, even had DSSRC determined (which it did not) that the studies provided by Root Wellness met the competent and reliable scientific evidentiary threshold that is necessary for health-related claims, it would nevertheless be inappropriate to extrapolate the resulting test data that, for example, reported diminished toxin levels in individual urine samples to mean that product can be beneficial to people suffering from health conditions such as psoriasis, attention-deficit/hyperactivity disorder, chronic fatigue, fatty liver disease (Hepatic Steatosis), fibromyalgia, and rheumatoid arthritis.
When a direct selling company and/or its salesforce members disseminate claims that its product is effective at protecting consumers from specific health-related conditions, it is imperative that the company provide reliable and competent testing indicating that the products are efficacious against those stated conditions.
Moreover, Root Wellness did not respond to DSSRC’s request for additional information regarding its testing data, including questions about the statistical significance of the resulting data, the use of animals in the individual ingredient studies, and the small sample sizes and testing methodology used in the heavy metal, heart rate variability, and ROFES studies.
As such, in the absence of reliable and competent evidence indicating that the products perform as claimed, DSSRC recommended that the Company take immediate action to have the remaining social media posts containing the health-related claims at issue in this inquiry disabled.
Conclusion
During the pendency of the inquiry, it appeared that Root Wellness removed the review page on the Company website from which three of the testimonial claims at issue appeared. DSSRC determined that the removal of such review posts was necessary and appropriate. In addition, DSSRC also concluded that the evidence provided by Root Wellness was not of sufficient reliability to support the remaining claims that were disseminated on social media by Company salesforce members that its products can protect consumers against the specific health related conditions communicated in the posts. Accordingly, DSSRC determined that Root Wellness should take immediate action to disable those posts at issue which remain publicly accessible by consumers
Company Statement
“We at ROOT are diligently working to track clinical outcomes with scientific data to support the ROOT brand products. We recognize consumer claims can create perception issues which lead to regulatory compliance concerns and this isn’t the image our company and brand portray as we understand the compliance landscape. We have taken the review page down from our website as an immediate move to assure we are focusing on a proper consumer facing approach to claim compliance. In addition, we are working with our community members who have made their personal experience claims on social media to correct any improper claims found on third party sites.”
(Case No. 46-2021 PCM, closed on 09/16/21)
© 2021. BBB National Programs
[1] Jurkić, L.M., Cepanec, I., Pavelić, S.K. et al. Biological and therapeutic effects of ortho-silicic acid and some ortho-silicic acid-releasing compounds: New perspectives for therapy. Nutr Metab (Lond) 10, 2 (2013).
[2] Zarkovic N, Zarkovic K, Kralj M, Borovic S, Sabolovic S, Blazi MP, Cipak A, Pavelic K. Anticancer and antioxidative effects of micronized zeolite clinoptilolite. Anticancer Res. 2003 Mar-Apr;23(2B):1589-95. PMID: 12820427.
[3] Grce, Magdalena & Pavelić, Krešimir. (2005). Antiviral properties of clinoptilolite. Microporous and Mesoporous Materials - MICROPOROUS MESOPOROUS MAT. 79. 165-169. 10.1016/j.micromeso.2004.10.039.
[4] Kraljević Pavelić S, Simović Medica J, Gumbarević D, Filošević A, Pržulj N, Pavelić K. Critical Review on Zeolite Clinoptilolite Safety and Medical Applications in vivo. Front Pharmacol. 2018;9:1350. Published 2018 Nov 27. doi:10.3389/fphar.2018.01350
[5] Basha MP, Begum S, Mir BA. Neuroprotective Actions of Clinoptilolite and Ethylenediaminetetraacetic Acid Against Lead-induced Toxicity in Mice Mus musculus. Toxicology International. 2013 Sep;20(3):201-207. DOI: 10.4103/0971-6580.121666.
[6] Pb+2 is the more oxidative state of lead, the densest of the common metals excepting gold and mercury. It has a metallic luster when freshly cut but quickly acquires a dull color when exposed to moist air.
[7] Yantasee W., R.D. Rutledge, W. Chouyyok, V. Sukwarotwat, G. Orr, C.L. Warner, and M.G. Warner, et al. 2010. "Functionalized Nanoporous Silica for Removal of Heavy Metals from Biological Systems; Adsorption and Application." <i>ACS Applied Materials & Interfaces</i> 2, no. 10:2749-2758. PNNL-SA-73483. doi:10.1021/am100616b
[8] Jurkić LM, Cepanec I, Pavelić SK, Pavelić K. Biological and therapeutic effects of ortho-silicic acid and some ortho-silicic acid-releasing compounds: New perspectives for therapy. Nutr Metab (Lond). 2013 Jan 8;10(1):2. doi: 10.1186/1743-7075-10-2. PMID: 23298332; PMCID: PMC3546016.
[9] Pavelić K, Hadzija M, Bedrica L, Pavelić J, Dikić I, Katić M, Kralj M, Bosnar MH, Kapitanović S, Poljak-Blazi M, Krizanac S, Stojković R, Jurin M, Subotić B, Colić M. Natural zeolite clinoptilolite: new adjuvant in anticancer therapy. J Mol Med (Berl). 2001;78(12):708-20. doi: 10.1007/s001090000176. PMID: 11434724.
[10] Although the Root Wellness review page is no longer publicly accessible, the link now takes users to a log-in page. DSSRC was unable to ascertain if logging in to the page would take users to the reviews containing the testimonial claims that were the subject of the DSSRC inquiry. Should those consumer reviews continue to be disseminated behind a log-in wall, DSSRC recommended that the Company take the appropriate action to have those reviews disabled, as they reference a number of health-related benefits from using Root Wellness products that have not been supported by competent and reliable scientific evidence.
[11] Pursuant to Section (I)(D) of the DSSRC Policy & Procedures, a company shall voluntarily not raise the independent contractor status of salespersons distributing their products or services under its trademark or trade name as a defense against non-compliance with DSSRC standards, provided, however, that such action shall not be construed to be a waiver of a company’s right to raise such defense under any other circumstance.
[12] VGH Solutions Inc. (Dr. Ho’s Circulation Promoter ), Report #6404, NAD/CARU Case Reports (September 2020); Molekule Inc. (Molekule MH1 Air Purifier), Report #6314, NAD/CARU Case Reports (October 2019); Triumph Pharmaceuticals Inc. (SmartMouth Dry Mouth Products), Report #6190, NAD/CARU Case Reports (June 2018); Good Health Naturally, LLC (Serranol Supplements), Report # 5441, NAD/CARU Case Reports (March 2012); Nature’s Cure, Inc. (2 -Part Acne Treatment), Report #4797, NAD/CARU Case Reports (February 2008).
[13] FTC Guide, Dietary Supplements: An Advertising Guide for Industry, www.business.ftc.gov/documents/bus09-dietary-supplements-advertising-guide-industry;
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...
DSSRC Administrative Closure #244
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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
DSSRC Administrative Closure #179
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 #127
DSSRC Administrative Closure #126
DSSRC Administrative Closure #125
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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
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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.