DSSRC Case Decisions and Administratively Resolved Inquiry Summaries
Case Decisions
Case #153-2024: Monitoring Inquiry – Trades of Hope LLC
Trades of Hope LLC (“Trades of Hope” or the “Company”) is a multi-level direct selling company that specializes in the sale of an assortment of goods including jewelry, personal accessories, home decor, and coffee. According to its website, Trades of Hope purchases its products from local artisans around the globe, including from Vietnam, Thailand, Cambodia, Uganda, Kenya, Peru,...
Case #152-2024: Administrative Closure – ibuumerang, Ltd
ibuumerang, Ltd (“ibuumerang” or the “Company”) is a direct selling company that offers discount travel for its members. The Company is headquartered in Houston, Texas and was founded in 2019.
Case #151-2024: Administrative Closure – Ruby Ribbon
Ruby Ribbon ("Company") is a multi-level direct selling company located in Burlingame, CA that was founded in 2011 and sells shapewear, athleisure, and intimates.
Case #150-2024: Administrative Closure – Vida Divina Worldwide, Inc.
Vida Divina Worldwide, Inc. (“Vida Divina” or the “Company”) is a direct selling company that markets health and wellness products, including beverages and nutritional supplements. The Company is headquartered in Ontario, Canada and was founded in 2016.
Case #149-2024: Administrative Closure – Innov8tive Nutrition
Innov8tive Nutrition ("Company") is a multi-level direct selling company that sells nutritional supplements and self-care products.
Case #148-2024: Monitoring Inquiry – LiveGood, Inc. USA
LiveGood Inc. USA (“LiveGood” or the “Company”) is a direct selling company that sells a variety of multivitamins and supplements with a focus on sleep aids, inflammation management, muscle recovery and weight management. The Company is headquartered in Jupiter, Florida and was founded in 2022.
Case #147-2024: Monitoring Inquiry – PaperPie f/k/a Usborne Books & More
PaperPie f/k/a Usborne Books & More (“PaperPie” or the “Company”) is a direct selling company that was founded in 1989 and based in Tulsa, Oklahoma.1 The Company distributes children’s books and educational products.
Case #146-2023: Administrative Closure – Enzacta USA
Enzacta USA (“Enzacta or the “Company”) is a direct selling company that sells nutritional and wellness products. The Company is headquartered in Cheyenne, Wyoming and was founded in 2003.
Case #145-2023: Administrative Closure – Tranont
Tranont (or the “Company”) is a multi-level direct selling company based in Utah. Founded in 2013, the Company sells health and wellness products, including a line of CBD products.
Case #144-2023: NGO Inquiry – Modere USA, Inc.
Modere USA, Inc. (“Modere” or the “Company”) is a direct selling company founded in 2012 and based in Newport Beach, California that markets health, beauty, and wellness products.
Case #143-2023: Administrative Closure – Traveling Vineyards
Traveling Vineyards (or the “Company”) was a direct selling company based in Ipswich, Massachusetts. The Company was established in 2010 and sells boutique wines.
Case #142-2023: Administrative Closure – Globallee, Inc.
Globallee, Inc. (“Globallee” or the “Company”) is a direct selling company located in Irving, Texas, founded in 2019. The Company sells various health and wellness supplements and has offices in Japan, Canada, Australia, and the United States.
Case #141-2023: Administrative Closure – Red Aspen, LLC
Red Aspen, LLC, (“Red Aspen” or the “Company”) is a direct selling company that markets beauty and cosmetic products. The Company is headquartered in Meridian, Idaho and was founded in 2017.
Case #140-2023: Administrative Closure – Younique, LLC
Younique, LLC (or the “Company”) is a direct-selling company based in Utah that sells beauty products.
Case #139-2023: NGO Inquiry – Elomir, Inc.
Elomir, Inc. (“Elomir” or the “Company”) sells nutritional supplements including its flagship product, Axis Klärity. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #138-2023: Monitoring Inquiry – Thrive Life, LLC
Thrive Life, LLC is a direct selling company that manufactures and markets freeze-dried and rehydrated foods. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #137-2023: Administrative Closure – Herbalife International of America, Inc.
Herbalife International of America, Inc., (“Herbalife” or the “Company”) is a direct selling company that sells nutritional and wellness products. The Company is headquartered in Los Angeles, California and was founded in 1980.
Case #136-2023: Administrative Closure – Grace & Heart
Grace & Heart (or the “Company”) was a direct selling company based in California. The Company was established in 2015 and sold fashion jewelry.
Case #135-2023: Administrative Closure – Global Domains International
Global Domains International is a direct-selling company based in California that sells domain names via an affiliate network. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims disseminated by direct selling companies and their salesforce members.
Case #134-2023: Compliance Inquiry – B-Epic Worldwide, LLC
B-Epic Worldwide LLC is a Utah-based multi-level marketing company that sells health and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising in the direct selling marketplace.
Case #133-2023: Government Referral – Sweet Minerals, LLC
Sweet Minerals, LLC (“Sweet Minerals” or the “Company”) is a direct selling company based in Pasadena, Maryland. The company was founded in 2011 and markets makeup, personal care, skin care, and cosmetic products.
Case #132-2023: Administrative Closure – jBloom Designs
jBloom Designs (“jBloom” or the “Company”) is a multi-level marketing company that sells custom jewelry. The Company is headquartered in St. Peters, MO and founded in 2013.
Case #131-2023: Compliance Inquiry – Seint Beauty
Case #130-2023: Monitoring Inquiry – Healy World
Healy World, Inc. (“Healy World” or the “Company”) is a direct selling company based in Mainz, Germany with its domestic headquarters in Orlando, Florida.
Case #129-2023: Monitoring Inquiry – Zinzino, LLC
Zinzino, LLC (“Zinzino” or the “Company”) is a direct selling company founded in 2005 that offers nutritional supplements to consumers. The Company is headquartered in Frölunda, Sweden and has a subsidiary in Jupiter, Florida.
Case #128-2023: Compliance Report – The Juice Plus+ Company, LLC
The Juice Plus+ Company, LLC (“JuicePlus” or the “Company”) is a direct selling company founded in 1970 and based in Collierville, Tennessee. The Company markets fruit and vegetable juice extract supplements.
Case #127-2023: Administrative Closure – Traci Lynn Jewelry
Traci Lynn Jewelry (or the “Company”) was a direct selling company based in Florida. The Company was established in 1989 and sold affordable fashion jewelry.
Case #126-2023: Monitoring Inquiry – Zallevo, LLC
Zallevo, LLC (“Zallevo” or the “Company”) is a direct selling company founded in 2020 and based in St. George, Utah. The Company markets health and wellness products focusing on weight loss and anxiety/stress reduction.
Case #125-2023: Monitoring Inquiry – Pink Zebra
Pink Zebra At Home (or the “Company”) is a direct selling company founded in 2011 and based in Sugar Land, Texas. The Company markets home fragrance and décor products including a wide range of items such as scented wax melts, candles, reed diffusers, room sprays, and other related accessories.
Case #124-2023: Government Referral – Tori Belle Cosmetics
Tori Belle Cosmetics (“Tori Belle” or the “Company”) is a direct-selling company founded in 2019 and based in Woodinville, Washington. The Company markets beauty and cosmetic products.
Case #123-2023: Administrative Closure – Seint Beauty
Seint Beauty (“Seint” or the “Company”), formerly Maskcara Beauty, is a multi-level marketing company founded in 2013 and based in St. George, Utah. The Company markets consumer and personal care products with a focus on cosmetics and cosmetic accessories.
Case #122-2023: Government Referral – iCoinPro
iCoinPro (or the “Company”) is a multi-level direct selling company that markets education, information, and training for cryptocurrency services. The Company was founded in 2017 and is located in Carson City, Nevada.
Case #120-2023: Monitoring Inquiry – Pure Haven, LLC
Pure Haven, LLC (“Pure Haven” or the “Company”) is a direct-selling company founded in 2009 and based in Rhode Island. The Company markets household products and personal care products to consumers including a line of skin care products.
Case #119-2023: Government Referral – Wayal Health Sciences USA, Inc.
Wayal Health Sciences USA, Inc., (“Wayal Health” or the “Company”) is a multi-level direct selling company founded in 2016. The Company is headquartered in Salt Lake City, Utah and markets health and wellness nutritional supplements.
Case #118-2023: Administrative Closure – Daxen, Inc.
Unicity International, Inc. (“Unicity” or the “Company”) is a multi-level marketing company headquartered in Orem, Utah and founded in 1986. The Company markets nutritional and personal care products and operates in approximately 30 countries, including the United States, Australia, Brazil, Brunei Darussalam, Canada, Colombia, Hong Kong, Indonesia, Japan, Malaysia, New Zealand,...
Case #117-2023: Administrative Closure – Unicity International, Inc.
Unicity International, Inc. (“Unicity” or the “Company”) is a multi-level marketing company headquartered in Orem, Utah and founded in 1986. The Company markets nutritional and personal care products and operates in approximately 30 countries, including the United States, Australia, Brazil, Brunei Darussalam, Canada, Colombia, Hong Kong, Indonesia, Japan, Malaysia, New...
Case #116-2023: Administrative Closure – GelMoment, Inc.
GelMoment, Inc. (“GelMoment” or the “Company”) is a direct-selling company founded in 2014 and based in Montreal, Canada. The Company markets gel nail polish and other beauty products.
Case #115-2023: NGO Inquiry – The Juice Plus+ Company, LLC
The Juice Plus+ Company, LLC is a direct selling company founded in 1970 and based in Collierville, Tennessee. The Company markets fruit and vegetable juice extract supplements. An NGO identified to DSSRC certain earnings and product performance claims disseminated by salesforce members and the Company.
Case #114-2023: Administrative Closure – Reliv International, Inc.
Reliv International, Inc. is a direct-selling company founded in 1988, and based in Chesterfield, Missouri. The Company markets proprietary nutritional supplements. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of the direct selling marketplace.
Case #113-2023: Administrative Closure – Vic Beauty, LLC
Vic Beauty, LLC was a direct sales cosmetic and personal care company based in Los Angeles, California. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #112-2023: Compliance Inquiry – Magnetude Jewelry
Magnetude Jewelry (or the “Company”) is a multi-level direct selling company based in Maryland that sells bio-magnetic interchangeable fashion jewelry to consumers. According to the Company’s website, the Company’s independent representatives earn money through commission on product sales or recruiting other salesforce members.
Case #111-2023: Administrative Closure – Shaklee Corporation
Shaklee Corporation (“Shaklee” or the “Company”) is a direct-selling company founded in 1956 and based in Pleasanton, CA. The Company markets natural nutritional supplements, beauty products, and household products.
Case #110-2023: Administrative Closure – Prime My Body
Prime My Body LLC (“Prime My Body” or the “Company”) is a direct-selling company based in Carrollton, Texas. The company was founded in 2013 and sells CBD oils and other nutritional products.
Case #109-2023: Administrative Closure – Direct Cellars
Case #108-2023: Administrative Closure – Save the Day Seasonings
Case #107-2023: Administrative Closure – BeneYOU LLC (a/k/a Avisae)
BeneYOU LLC (a/k/a Avisae) (“BeneYOU” or the “Company”) is a direct selling company headquartered in Lindon, Utah, that acquired the Avisae brand in 2018. The company markets personal care and wellness products.
Case #106-2023: Monitoring Inquiry – Magneceutical Health, LLC
Magneceutical Health, LLC (“Magneceutical Health” or the “Company”) is a company headquartered in Clearwater, FL that markets a medical device called the Magnesphere, which is a magnetic resonance therapy system designed to help reduce the symptoms associated with chronic stress.
Case #105-2023: Monitoring Inquiry – Peach Underneath, Inc.
Peach Underneath, Inc. (“Peach Underneath” or “the Company”) was a multilevel marketing company headquartered in Waltham, Massachusetts that marketed premium, athletic-inspired clothing and intimate apparel.
Case #104-2023: Government Referral – Karatbars International
Karatbars International is a multi-level direct selling company founded in 2011 that markets small gold bars and gift items in gold bullion. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #103-2023: Monitoring Inquiry – Essential Bodywear, LLC
Essential Bodywear, LLC is a direct selling company founded in 2003 and headquartered in Commerce, Michigan. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #102-2023: Compliance Inquiry – Innov8tive Nutrition, Inc.
Innov8tive Nutrition is a direct selling company that was founded in 2016 and is headquartered in Seattle, Washington. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #101-2023: Monitoring Inquiry – NeVetica International, Inc.
NeVetica International, Inc. is a direct selling company headquartered in Louisville, Kentucky and founded in 2016. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #100-2022: Monitoring Inquiry – Youngevity International, Inc.
Youngevity International, Inc. is a direct selling company that sells health, nutrition, and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #99-2023: Government Referral – Perfectly Posh, LLC
Perfectly Posh, LLC is a direct selling company based in Salt Lake City, Utah that markets personal care and beauty products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #98-2022: Monitoring Inquiry – Ruby Ribbon, Inc.
Ruby Ribbon, Inc. is a multi-level marketing company that markets women’s apparel, handbags, and other accessories. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #97-2022: Administrative Closure – Unicity International, Inc.
Unicity International, Inc. is a multi-level marketing company that markets nutritional and personal care products and operates in approximately 30 countries. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #96-2022: Government Referral – ViSalus, Inc.
ViSalus, Inc. is a multilevel marketing company that markets weight management nutritional products, dietary supplements, and energy drinks. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #95-2022: Monitoring Inquiry – PartyLite Worldwide, LLC
PartyLite Worldwide, LLC is a multi-level marketing company that markets candles, home décor, and home fragrance products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #94-2022: Administrative Closure – Tealightful Treasures, Inc.
Tealightful Treasures, Inc. is a retail company with a direct-to-consumer website that markets several varieties of loose-leaf tea products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #93-2022: Administrative Closure – Ardyss International, LLC
Ardyss International LLC is a multi-level marketing company that markets reshaping apparel, nutrition, personal care, and home care products.This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #92-2022: Administrative Closure – Sunrider International
Sunrider International is a multi-level marketing company that markets herbal food and beverages, nutritional supplements, and skin care and personal care products.This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #91-2022: Monitoring Inquiry – Kannaway, LLC
Kannaway, LLC is a direct selling company headquartered in Poway, CA that sells CBD and wellness products to consumers. This inquiry was commenced by DSSRC pursuant to its ongoing independent...
Case #90-2022: Monitoring Inquiry – Zilis LLC
Zilis LLC is a multi-level direct-selling company headquartered in Argyle, Texas that sells wellness products to consumers.
Case #89-2022: Monitoring Inquiry – My Lala Leggings, Inc.
My Lala Leggings, Inc. is a multi-level marketing company headquartered in Palmdale, CA that sells women’s clothing, specializing in leggings.
Case #88-2022: Monitoring Inquiry – B-Epic Worldwide, LLC
B-Epic Worldwide, LLC is a multi-level direct-selling company located in Layton, Utah that markets health, detox, and fitness products.
Case #87-2022: Monitoring Inquiry – MWR Life, LLC
MWR Life, LLC is a multi-level direct selling company headquartered in Fort Lauderdale, Florida that offers discounts on travel services such as flights, hotels, resorts, cruises, vacation rentals, car rentals, excursions, theme parks, and trains. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling...
Case #86-2022: Monitoring Inquiry – Visi
Visi is a direct-selling company headquartered in Pleasant Grove, Utah specializing in a variety of health-related products, including protein, essential oils, and extracts. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring process, which monitors advertising and marketing claims made in the direct selling industry.
Case #85-2022: Monitoring Inquiry – Reliv International, Inc.
Reliv International, Inc. is a multilevel direct-selling company located in Chesterfield, Missouri that markets and distributes nutritional supplements and personal care products. This...
Case #84-2022: Monitoring Inquiry – Navan Global
Navan Global was a multilevel marketing company located in Franklin, Tennessee, manufacturing and distributing health and CBD-related products. This inquiry was commenced by DSSRC pursuant to its...
Case #83-2022: Government Referral – Root Wellness LLC, a/k/a Root Brands
Root Wellness LLC is a direct-selling company founded in 2019 and located in Brentwood, Tennessee. The Company markets health and wellness products, most notably its Clean Slate, Restore, and Zero-In products. In February 2021, DSSRC initiated an inquiry regarding the dissemination of health-related claims by Root Wellness and its salesforce members and opened a...
Case #82-2022: Administrative Closure – LurraLife Global
LurraLife Global was a multi-level direct-selling company that marketed health and wellness products, including detoxification tea, to consumers. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #81-2022: Administrative Closure – QuiAri, LLC
QuiAri, LLC is a multi-level direct-selling company in Brandon, Florida, that markets health and wellness products. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring advertising and marketing claims in the direct selling industry.
Case #80-2022: Government Referral – Fifth Avenue Collection, Inc.
Fifth Avenue Collection is a multi-level direct-selling company that sells fashion jewelry products headquartered in Moose Jaw, Saskatchewan. The Direct Selling Self-Regulatory Council (DSSRC) commenced this inquiry pursuant to its ongoing, independent monitoring of advertising and marketing claims in the direct selling industry.
Case #79-2022 – Government Referral – Vyvo, Inc.
Vyvo, Inc. is a multi-level direct selling company that markets a smart watch, DNA and genetics testing, and nutritional supplements. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising in the direct selling marketplace and concerns earnings claims disseminated by the Company and its salesforce members.
Case #78-2022 – Monitoring Inquiry – H20 At Home
H2O At Home is a multilevel marketing company headquartered in King of Prussia, Pennsylvania that offers consumers a line of non-toxic cleaning solutions. This inquiry was commenced by DSSRC...
Case #77-2022 – Compliance Inquiry – Root Wellness LLC
The Direct Selling Self-Regulatory Council (DSSRC) opened a compliance inquiry against Root Wellness after health-related product claims similar to those addressed in a 2021 inquiry appeared in the social media posts of Root Wellness salesforce members. In addition, during its inquiry DSSRC identified more than 30 other related issues.
Case #76-2022 – Monitoring Inquiry – Sanki Global LLC
This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. Sanki Global LLC is a multi-level direct selling company headquartered in Japan, with U.S. offices located in Henderson, Nevada.
Case #75-2022 – Monitoring Inquiry – Tranont
This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. Tranont is a multi-level direct selling company based in Utah. Founded in 2013, the Company sells health and wellness products, including a line of CBD products.
Case #74-2022 – Monitoring Inquiry – Opulence Global
Opulence Global is a multi-level direct selling company that sells skincare, personal care, and health & wellness products. This inquiry concerns product and earnings claims disseminated by salesforce members on social media regarding the Fountain of Life product, an antioxidant that includes a Picea Abies extract as one of its primary...
Case #73-2022 – Monitoring Inquiry – Financial Education Services
Financial Education Services is a multi-level direct selling company that markets credit repair services to consumers. This inquiry concerns earnings claims disseminated by company salesforce members on social media.
Case #72-2022 – Monitoring Inquiry – Stella & DOT, LLC
Stella & DOT, LLC is a multi-level direct selling company that sells jewelry, bags, accessories, and women’s clothing. The Direct Selling Self-Regulatory Council (DSSRC) began this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry. This inquiry concerns earnings claims disseminated by Stella & DOT and its...
Case #71-2022 – Monitoring Inquiry – Lifebrook, LLC
Lifebrook was a multilevel marketing company headquartered in Vermillion, South Dakota that sells juices, supplements, and other products containing Aronia. The Direct Selling Self-Regulatory Council (DSSRC) began this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #70-2022 – Monitoring Inquiry – My Lala Leggings, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #69-2022 – Monitoring Inquiry – Max International, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #68-2022 – Monitoring Inquiry – Daxen, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #67-2022 – Monitoring Inquiry – WorldVentures Marketing, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #66-2022 – Monitoring Inquiry – Tastefully Simple
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #65-2022 – Government Referral – FutureNet, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs.
Case #64-2022 – Compliance Report – Young Living Essential Oils, LLC
Young Living Essential Oils, LLC (“Young Living” or the “Company”) is a global multi-level direct selling company that sells essential oils and other personal care and wellness products.
Case #63-2022 – Monitoring Inquiry – Innov8tive Nutrition
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #62-2022 – Monitoring Inquiry – MWC Living, LLC d/b/a BE (Better Experience)
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs and commenced this inquiry pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #61-2022 – Compliance Report – Mary Kay, Inc.
Mary Kay, Inc.’s (“Mary Kay” or the “Company) business model is that of a direct sales company, which means Mary Kay products are sold by Mary Kay independent sales force members, person to person, away from fixed retail locations. The Company is headquartered in Dallas, Texas. Mary Kay was founded in 1963 and has an estimated three million independent beauty consultants selling Mary Kay®...
Case #60-2022 – Monitoring Inquiry – Morinda, Inc., Corporation
Morinda, Inc. is a multi-level direct-selling company that markets a noni juice blend (Tahitian Noni) and various dietary supplements, personal care products, and essential oils. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #59-2022 – Government Referral – BE Rules, a/k/a BE Factor, f/k/a Melius
BE Rules, a/k/a BE Factor, f/k/a Melius (“BE” or the “Company”) is a multi-level direct selling company that markets forex and cryptocurrency trading package subscriptions. BE Rules is based in Dubai, United Arab Emirates and also maintains offices in India and the United Kingdom.[1] The Company maintains a Facebook page[2], an Instagram page[3], a company...
Case #58-2022 – Monitoring Inquiry – Surge365
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #57-2022 – Compliance Report – Le-Vel Brands, LLC
Le-Vel Brands, LLC (“Le-Vel” or the “Company) is a multi-level direct selling company headquartered in Frisco, Texas that was founded in 2012. The Company sells health and wellness products including dietary supplements containing vitamins, minerals, plant extracts, antioxidants, enzymes, probiotics, and amino acids.
Case #56-2022 – Monitoring Inquiry – Immunotec
Case #55-2021 – Monitoring Inquiry – Wildtree, Inc.
Wildtree, Inc. is a spice and seasoning company headquartered in Lincoln, Rhode Island that specializes in healthy meal solutions for families. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #54-2021: Government Referral – Dot Dot Smile
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #53-2021: Monitoring Inquiry – Jeunesse Global
The Direct Selling Self-Regulatory Council (DSSRC) opened a monitoring inquiry with Jeunesse Global over concerns about earnings claims disseminated by salesforce members for the company. DSSRC appreciated Jeunesse’s good faith actions to remove the challenged claims on social media sites, but DSSRC recommended Jeunesse continue its communication with salesforce members to ensure that...
Case #52-2021: Monitoring Inquiry – Daxen, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #51-2021: Compliance Report – dōTERRA International, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. In 2019, DSSRC commenced an inquiry regarding several core health-related and income claims being disseminated on the social media pages of certain distributors of dōTERRA. More specifically, the inquiry included both...
Case #50-2021: Monitoring Inquiry – Chalk Couture
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #49-2021: Monitoring Inquiry – Lifebrook, LLC
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #48-2021: Government Referral – Q Sciences
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #47-2021: –Monitoring Inquiry– Root Wellness, LLC
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #46-2021: –Monitoring Inquiry– SwissJust USA
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #45-2021 – Monitoring Inquiry – Globallee, Inc.
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #44-2021 – Government Referral – ByDzyne
Case #43-2021 – Monitoring Inquiry – Limbic Arc, LLC
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs, Inc. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #42-2021 –Monitoring Inquiry– Max International, LLC
Case #41-2021 – Government Referral – Alliance in Motion Global, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #40-2021 – NGO Inquiry –Mary Kay, Inc.
Case #39-2021: –Monitoring Inquiry– Enagic, USA, Inc.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #38-2021: –Monitoring Inquiry– Zinzino, LLC.
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #37-2021: –Monitoring Inquiry– Aihu, Inc.
The Direct Selling Self-Regulatory Council (DSSRC) is a national advertising self-regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #36-2021: – Government Referral – Bulavita
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self- regulation program administered by BBB National Programs. This inquiry was commenced by DSSRC pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry.
Case #35-2021: – Government Referral – UWell Life, Inc.
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Administratively Resolved Inquiry Summaries
Case #40-2021 – NGO Inquiry –Mary Kay, Inc.
BBB NATIONAL PROGRAMS, INC.
The Direct Selling Self-Regulatory Council
Case Number: 40-2021 – NGO Inquiry –Mary Kay, Inc.
Company Description
The Mary Kay Inc. (“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® products in more than 35 markets worldwide.
Basis of Inquiry
The Direct Selling Self-Regulatory Council (“DSSRC”) is a national advertising self-regulation program administered by BBB National Programs, Inc. Pursuant to section D(II) of DSSRC’s Policies & Procedures, DSSRC may commence an inquiry regarding the marketing disseminated by a direct selling company and/or its salesforce where the subject claims were referred to DSSRC by the Administrator of the Direct Selling Association’s Code of Ethics, through media reports, or identified by other parties. Here, a nonprofit, non-governmental organization (“NGO”) dedicated to protecting consumers[1] identified certain earnings claims for Mary Kay. Specifically, the NGO brought to DSSRC’s attention certain earnings claims being disseminated on the social media pages of certain independent consultants and on webpages and social media accounts controlled by Mary Kay. It alleged that many of the representations at issue include both express and implied claims that the Mary Kay business opportunity will help individuals earn a significant amount of income and/or enjoy a lavish lifestyle. In the NGO’s initial written submission to DSSRC, it identified approximately 200 examples of such posts or videos.
The representative earnings claims that were the subject of this inquiry include the following:
- “Kimberly Galindo, Fresno, CA: ‘To pick just one photo & caption for this entry from the last 16 years has been quite the challenge! Do I pick taking my children to see their momma’s face in Times Square? Or spoiling my hubby with a cruise to the Bahamas? A Pink Cadillac Pickup Party? While all of those moments have been monumental – there was nothing quite like FINALLY purchasing our BRAND-NEW home. I will always remember the JOY & gratitude I felt that day.’”
- “Michelle Willis, Sandy, UT: ‘My Mary Kay moment was when my husband opened up his Christmas present in 2018 to find this picture frame. This is my granddaughter holding the title to his truck that I secretly paid off with my Mary Kay business. When the picture fell away there was the title to his dream truck. His free and clear. I also placed a copy of the truck key in a Mary Kay “you hold the key bag” and included that with the title.’”
- “Victoria Jackson, Jackson, TN: ‘My Mary Kay moment was summer of 2019! With the profits I had earned from my Mary Kay business, I was able to take two boys and parents on a once-in-a-lifetime vacation. Their first Caribbean cruise! As a single mom working an entry level job, I never imagined being able to do anything like this for my boys. Watching their eyes light up at ship, enjoying all the desserts they could eat, and seeing new places around the world meant all the world to me. All because one woman believed I could do it!’”
- “There’s nothing quite like driving a Pink Cadillac! 💗 – Learn more about the Mary Kay opportunity and the amazing things you can accomplish at our bio link”
- “What could an extra $200 a month do for you fam? An extra $500? An extra $1000? Bonus points if anyone can guess my highest monthly paycheck for team building!” (Accompanied by an image of a blank Mary Kay check)
- “Freedom, flexibility and financial stability! What more can a girl ask for! Building a Million dollar team of women/men…”
- “You found a way made a way to change your life drastically during a Pandemic & you did just that!... she was let go at the beginning of the Pandemic so now her and Tyler don’t have to worry [;]…she can love and cuddle that baby so much and not worry about finances since she will have built a successful business & have residual income…”
- “How much money can I expect to earn as an Independent Business Consultant?
Many Independent Beauty Consultants operate their business on a part-time basis with the goal of meeting short-term financial goals – such as purchasing holiday gifts for their families or paying for a family vacation, school clothes or tuition for their children. Meanwhile, others decide to build their Mary Kay business to the point at which it becomes possible for them to quit their jobs and pursue their Mary Kay business full time.”
The NGO maintained that Mary Kay and its independent consultants have been using – and continue to use – atypical, unsupported, and unqualified income claims to market the Mary Kay business opportunity. The NGO contended that Mary Kay’s marketing materials include claims of participants achieving financial freedom, earning replacement income, buying their dream homes, quitting their jobs, making six figures per year, retiring their spouses, and earning the iconic Mary Kay Pink Cadillac, among other things. According to the NGO, the vast majority of Mary Kay independent consultants are making little to no money in the venture, and most don’t ever earn a “free” car.
To illustrate its position, the NGO pointed to the FAQs published on the Mary Kay website, on which it contended Mary Kay tells consumers that the Company business opportunity allows women to quit their jobs and pay for family vacations and for children’s school tuitions.
The NGO noted that none of the posts that it identified to DSSRC include any disclosure of what a typical Mary Kay distributor earns with the company which it maintained deprives recruits of information that might help them make an educated decision regarding whether to sign up with the Company.[2]
While acknowledging that Mary Kay reconciled a number of the posts that were brought to its attention prior to the NGO’s submission to the DSSRC, the NGO claimed dozens of claims and posts remained unchanged and accessible by consumers including posts that were within the Company's immediate supervision (i.e., its own website and Mary Kay-controlled social media platforms). According to its website, the last audit done by the NGO on the claims and posts identified was May 2021.
The NGO also noted that a number of Mary Kay independent consultants attempted to address DSSRC’s concerns by making the posts “private” rather than completely removing the posts from publication. However, the NGO contended that such an action is inadequate because anyone who is invited to view the video/post or is within the private group can still access it, show it to friends, show it at large meetings or conferences, etc., and that it is just as simple to remove the deceptive claim as it is to make it private.
Company’s Position
The Company advised DSSRC that it is committed to consumer protection and takes improper earnings representations very seriously. The Company stated that it strongly discourages sales force members from communicating any express or implied income claims.
1. Salesforce Member Posts
The Company maintained that at the time of the writing of this report all blog posts disseminated by sales force members that were at issue with the exception of one post (“Make-Up with Marni”) had been deleted through the Company’s efforts. Mary Kay stated that it has contacted the salesforce member responsible for the remaining blog post and will take disciplinary action against the salesforce member should such salesforce member be unresponsive to the Company’s request to address the post.
The Company informed DSSRC that at the time of the authoring of this report, all Facebook posts disseminated by Mary Kay independent sales force members that were identified by the NGO have been deleted with the exception of one post from January 2021 that was disseminated by a sales force member located outside of the United States. The Company indicated to DSSRC that it is in the process of contacting the individual to have the post removed.
All Instagram posts from the NGO’s database that were disseminated by independent sales force members pertaining to Mary Kay’s iconic Pink Cadillac program were deleted by the time of the authoring of this report. Four additional posts were identified by the DSSRC during the pendency of this inquiry, and Mary Kay advised DSSRC that it is in the process of contacting its independent sales force members regarding these posts.
Regarding earning the use of a Pink Cadillac, the Company explained that Mary Kay independent sales force members earn the use of a Pink Cadillac by meeting and exceeding goals set within their Mary Kay businesses. The Company understood the DSSRC’s concerns that it would be reasonable for consumers to interpret unqualified claims and depictions about Mary Kay’s Pink Cadillac program as implying that the typical Mary Kay sales force member attains eligibility to participate in the Company’s Pink Cadillac program. Given this understanding, the Company committed to exploring the development of disclosure language to include on corporate pages and/ or for sales force members to utilize in social media posts referencing Mary Kay’s Pink Cadillac program.
Mary Kay noted that the NGO did not identify any Twitter posts in its original submission. During the pendency of DSSRC’s inquiry, two Twitter posts disseminated by independent sales force members were brought to the Company’s attention. Mary Kay informed DSSRC that it is in the process of contacting both sales force members regarding these two additional Twitter posts to have the posts removed.
The Company stated that as of the authoring of this report, all YouTube videos identified by the NGO as being disseminated by Mary Kay independent sales force members have been disabled.
2. Company Posts
Mary Kay agreed to modify the claim stating “[w]hether it’s potentially earning a little extra income or making a full-time commitment, the Mary Kay opportunity offers the freedom, flexibility and, of course, the fun that you’ve been looking for” to remove any express or implied references to financial freedom and the opportunity to earn full-time income” from the Mary Kay blog.[3]
Mary Kay stated that all Company managed Facebook, Pinterest, and Twitter posts that were originally brought to its attention by the NGO have been removed.[4]
Mary Kay maintained that as of the authoring of this report, all Company Instagram posts identified by the NGO have been removed with the exception of one post which features a short video of a woman enjoying the perks from a Company-sponsored cruise for eligible sales force members that was posted in early 2019. Mary Kay originally informed DSSRC that the video was taken down but after learning that the post had not been disabled, expressed its commitment to DSSRC that the post would be expeditiously removed.
Mary Kay disabled all but one of the YouTube posts that originated from the Company. With respect to the remaining video, Mary Kay explained that it is working with an outside production company to edit and to remove the reference to “financial independence” in the video. The video was created with the intended audience of individuals interested in corporate positions at Mary Kay Inc. It was not intended to market the Mary Kay opportunity to potential independent sales force members. Lastly, the DSSRC expressed its concerns regarding problematic income statements on the “Sell Mary Kay” tab of the Company website. The Company advised DSSRC that it is committed to consumer protection and that although it believed the net impression of the materials identified did not misrepresent the potential of the Mary Kay opportunity, the Company would remove or modify the identified content to avoid any ambiguity or possible misunderstanding.
Analysis and Recommendations
Mary Kay was responsive in addressing the posts that were brought to its attention by DSSRC during the inquiry.[5] Of the approximately 200 posts originally identified by the NGO at the commencement of the inquiry, Mary Kay either removed or worked with independent sales force members to remove or restricted access to 189 of the posts to the general public.[6] DSSRC determined that these actions were necessary and appropriate.
1. Salesforce Member Posts
The NGO called DSSRC’s attention to six blog posts that were made by Mary Kay sales force members, all of which included unqualified representations regarding earnings and Company incentives. Mary Kay disabled five of the six posts.
The remaining blog post, entitled “Make-Up with Marni,” discussed how the sales force member got started with Mary Kay and how she was able to “pick up her Pink Cadillac.”
DSSRC remained concerned that Company incentives such as a car bonus or incentive trip reward would not be generally expected or achievable by the typical Mary Kay sales force member and, as such, DSSRC recommended that Mary Kay work with the sales force member responsible for the blog post to either remove reference to the Pink Cadillac or include a disclosure regarding the number of independent Mary Kay consultants who have received or who are eligible to receive the Mary Kay car incentive.
With respect to posting on various social media platforms, all but one of 34 Facebook posts that were disseminated by Mary Kay sales force members were disabled during the inquiry. More specifically, 31 of the consultants’ Facebook posts can no longer be accessed by the general public and two were designated as password-protected or private. The two posts now marked as “private” appear to remain accessible to members in that particular Facebook group and one password-protected post has a pre-filled password that connects to the original post when the “continue” box is clicked. This post communicates a claim of career level income (i.e., “*Income*: Profits depend on your effort. Are you looking for a side hustle or a whole new career? You decide!”). DSSRC concluded that this post should be completely removed from Facebook.
As noted in the Federal Trade Commission’s (“FTC”) 2018 Business Guidance Concerning Multi-Level Marketing “Business opportunities may claim that participants, while not necessarily becoming wealthy, can achieve career-level income. They may represent through words or images that participants can earn thousands of dollars a month, quit their jobs, ‘fire their bosses,’ or become stay-at-home parents. If participants generally do not achieve such results, these representations likely would be false or misleading to current or prospective participants.”[7]
With respect to the two Facebook posts designated as “private,” Mary Kay committed to DSSRC that it would take the necessary steps to have the posts disabled in their entirety so that the original content could not be viewed by any users of the platform.[8] Accordingly, while it may not have been the intention to perpetuate continued dissemination of these posts, DSSRC requested that the Company take such actions to assure that these posts be completely disabled so that they are no longer available to even a limited or exclusive group of individuals.
Mary Kay also worked with its independent sales force to disable almost all of the 47 Instagram posts that originated from sales force members and which were identified by the NGO at the commencement of the DSSRC inquiry.[9] The remaining 5 Instagram independent sales force member posts which had not yet been disabled at the time of this report and which were of concern to DSSRC all involved unqualified descriptions of Company incentives – four of which included unqualified reference to the Company’s Pink Cadillac program.
In addition to guidance provided by the FTC in 2018 regarding the promotion of company incentives made by sales force members, DSSRC has stated in past decisions that for purposes of a DSSRC inquiry, an earnings claim is any claim, express or implied, that conveys that sales force members may earn or have earned company-sponsored incentives, including representations that suggest the ability to make lifestyle purchases – such as homes, vehicles, vacations – that are related to income earned from direct selling.[10]
DSSRC remained concerned that incentives such as a car bonus reward would not be generally expected or achievable by the typical Mary Kay consultant and, as such, a disclosure of general expectations regarding the Company incentive would be necessary.
It is DSSRC recommended that the Company qualify such posts with the inclusion of material information such as consultant eligibility for the car program and the number or percent of Mary Kay salesforce members that have achieved this incentive. DSSRC further recommended that the Company disable any existing, unqualified social media posts that feature Mary Kay’s Pink Cadillac program until such time that appropriate qualifying information can be included in the posts.[11]
Additionally, the NGO called DSSRC’s attention to 32 YouTube videos which originated from Mary Kay independent sales force members that included unsupported earnings claims. During the pendency of the inquiry, the Company informed DSSRC that it had worked with sales force members and restricted access to 30 of the YouTube videos from the general public.
DSSRC recognized the efforts of Mary Kay to address DSSRC’s concerns and disable almost all of the videos at issue. Nonetheless, seven of the YouTube videos that were disseminated by Mary Kay independent consultants were marked “private” or were password protected. DSSRC remained concerned that such posts which included atypical and unqualified earnings representations about the Company’s business opportunity could be easily shared or socialized with select invitees. As DSSRC noted in a recent matter involving videos that were designated as “private” by a direct selling company, “[w]hile the videos are no longer available on the internet to a general audience of consumers, DSSRC cautioned the Company that because these videos included claims that were unrepresentative and not appropriately qualified, these videos should not be disseminated to even a limited audience in the context in which they were originally communicated on the Company’s public YouTube channel.”[12]
With respect to these private or password protected videos, DSSRC recommended that Mary Kay take appropriate steps to assure that posts or videos cannot be shared or redistributed in their original context with even a limited audience. Most social media platforms such as YouTube and Facebook provide options for content creators to simply delete an existing post as opposed to making it password protected or private and thus still accessible for select individuals.
At the time of this recommendation, two YouTube videos that were disseminated by Mary Kay independent beauty consultants remain completely accessible to the general public.[13] In the first video, a Mary Kay consultant makes an unqualified reference to driving a Mary Kay Pink Cadillac and also states that Mary Kay sales force members can choose to either work part time and “put a few hundreds of dollars in their pocket a month” or, conversely be “all in” if they want more choices with time and more choices with finances.” As noted in the above section of this decision which addressed Mary Kay’s Instagram posts, DSSRC is concerned that incentives such as a car bonus or incentive trip reward would not be generally expected or achievable by the typical Mary Kay consultant and, as such, a disclosure of consumers’ general expectations regarding the Mary Kay Pink Cadillac program would be necessary. Moreover, DSSRC determined that the reference to being “all in” on the Mary Kay business opportunity when coupled with income potential could be reasonably interpreted by consumers and potential recruits as meaning that that the typical Mary Kay salesforce member can typically expect to earn “full-time” or significant income – i.e., an amount of income that allows financial and time freedom.
The second unaddressed YouTube which originated from a Mary Kay independent sales force member features the Company’s Pink Cadillac program and includes statements that “[t]he money resides right here at Mary Kay” and references “freedom and flexibility” in the Mary Kay business opportunity. Again, the video includes no disclosures regarding eligibility for the car program or information about the number of Mary Kay consultants who have participated in the car program. DSSRC determined that reference to money and time and flexibility could be interpreted as meaning that the typical independent consultant will earn significant income. Accordingly, DSSRC recommended that Mary Kay either discontinue the two remaining consultant YouTube videos or significantly modify the videos to remove unqualified references to the Pink Cadillac program and time and financial freedom. Lastly, the fact the consultant videos were disseminated by sales force members and not Mary Kay itself had no bearing on DSSRC’s determination that videos should be modified or discontinued.[14]
During the pendency of this inquiry, the NGO identified two Twitter posts disseminated by Company sales force members which included claims that Mary Kay consultants can achieve financial freedom and earn full time income. According to section 6 of the DSSRC Guidance on Earnings Claims for the Direct Selling Industry while DSSRC will evaluate any claim based upon the context in which the claim appears and the potential net impression of such claim to the audience, some words and phrases commonly used in earnings claims can carry a particularly high risk of being misleading to consumers. Such words and phrases include claims such as “financial freedom,” “full-time income,” “replacement income,” “residual income,” and “career-level income.” Accordingly, DSSRC determined that here, the unqualified claim of Mary Kay independent sales force members receiving financial independence and supporting their families through a Mary Kay business reasonably communicated that the typical Mary Kay consultant could earn significant, income through the Company’s business opportunity. Accordingly, DSSRC recommended that Mary Kay request that the independent sales force members responsible for the claims disable the two Twitter posts.
2. Company Posts
Mary Kay removed all 25 of the Company Facebook posts that were brought to its attention by DSSRC at the commencement of the inquiry and all 5 Company Twitter posts. In addition, the only Instagram post disseminated by the Company that was not addressed by Mary Kay at the time of this recommendation, and which is still available to the general public, featured a short video of a Company incentive trip to the Bahamas in 2019. DSSRC remained concerned that this incentive trip would not be generally expected or achievable by the typical Mary Kay consultant and recommended that the post as presented in its current, unqualified context should be discontinued or modified until such time that the appropriate, material information is included in the post.
With respect to the 13 Company YouTube videos that were provided to DSSRC by the NGO, Mary Kay restricted public access to 12 of the videos by making them private. While DSSRC appreciated the efforts of Mary Kay to address DSSRC concerns and remove almost all of the Company YouTube videos from being accessed by the general public, DSSRC remained concerned that the private videos which included atypical and unqualified earnings representations about the Company’s business opportunity could be easily shared or socialized with select invitees. As DSSRC noted in a recent matter involving videos that were designated as “private” by the direct selling company, “[w]hile the videos are no longer available to on the internet to a general audience of consumers, DSSRC cautioned the Company that because these videos included claims that were unrepresentative and not appropriately qualified, these videos should not be disseminated to even a limited audience in the context in which they were originally communicated on the Company’s public YouTube channel.”[15]
The one Company YouTube video that remains publicly accessible, is a 2019 video that includes a representation stating that Mary Kay empowers sales force members to “live the life they choose…giving them the tools to live the life they choose, support their families [and] achieve financial and personal independence.” During the pendency of the inquiry, Mary Kay advised DSSRC that the video was created with the intended audience of individuals interested in corporate positions at Mary Kay Inc. It was not intended to market the Mary Kay opportunity to independent sales force members. As noted earlier in the section of this decision pertaining to social media posts disseminated by Company salesforce members, earnings claims such as “financial freedom,” “full-time income,” “replacement income,” “residual income,” and “career-level income can carry a particularly high risk of being misleading to consumers.
While DSSRC recognizes that the Company did not intend for this human resources video to be disseminated to a broad (i.e., non-corporate) audience, the video remains accessible on YouTube to the general public and, as such, DSSRC remained concerned that it would not be unreasonable for potential Mary Kay independent sales force members to interpret the claims in the video to mean that the typical Mary Kay independent salesforce member can earn significant, life changing income from the Mary Kay business opportunity As such, DSSRC recommended that Mary Kay either modify the video to remove this portion or disable the video in its entirety.
As it pertained to the Mary Kay website and other online materials over which the Company exercised editorial control, while DSSRC recognized that Mary Kay made several changes to its website during the pendency of the inquiry, DSSRC remained concerned with several existing statements regarding potential salesforce income.
For example, the FAQ section of the “Sell Mary Kay” tab of the Company website[16], states: “How much money can I expect to earn as an Independent Business Consultant? - The earning opportunity associated with a Mary Kay business is open-ended.” It is further stated that “…the amount of money you can make as a Mary Kay Independent Beauty Consultant will depend on many factors, including your personal business goals and the amount of time and effort you choose to invest in your business.” It is a long-standing principle of advertising that an advertiser has the burden to support any reasonable interpretation of its claims[17] and DSSRC determined that the reference to “open-ended income” that is predicated on the effort of the salesforce member reasonably communicates the message that the earnings potential for Mary Kay salesforce members is unlimited if the salesforce members is prepared to dedicate the necessary time and effort and that this message is inconsistent with the results achieved by the typical Company sales force member.
Similarly, in the “Blog” section of the Mary Kay website[18], the Company states that “Whether it’s potentially earning a little extra income or making a full-time commitment, the Mary Kay opportunity offers the freedom, flexibility and, of course, the fun that you’ve been looking for.” Another Company controlled webpage[19] states: “You’ve got dreams. Whether it’s the potential to earn a little extra cash or making a full-time commitment, the Mary Kay opportunity offers the freedom, flexibility and, of course, the fun that you’ve been looking for.”
DSSRC recommended that Mary Kay immediately remove these and any other any implied or express references to full-time income and financial and time freedom or language that could reasonably imply unlimited income potential from the Company webpages.
Conclusion
DSSRC expressed its appreciation to Mary Kay for its responsiveness and good faith efforts to address DSSRC’s concerns in this inquiry. Of the approximately 200 posts that were originally identified by the NGO, Mary Kay either removed or restricted public access to 189 of the posts that were originally brought to its attention. DSSRC determined that these actions were necessary and appropriate.
Notwithstanding the Company’s efforts to restrict the access of several DSSRC posts and videos to the general public, DSSRC recommended that posts and videos which were password-protected or designated as “private” also be removed in their entirety so that they are no longer available to an even limited or exclusive group of individuals in the context in which they were originally presented.
Several of the remaining posts and claims at issue referenced Company rewards including incentive trips and Mary Kay’s Pink Cadillac program. DSSRC remained concerned that Company incentives such as a car bonus or incentive trip reward would not be generally expected or achievable by the typical Mary Kay sales force member and, as such, it is recommended that Mary Kay either remove reference to the Pink Cadillac and trip incentives or include a disclosure regarding the number of Company consultants who have received or who are eligible to receive such incentive rewards.
Finally, as outlined above, the Company’s marketing materials still include unqualified statements regarding the significant income that Mary Kay sales force members can earn, including references to open-ended income, financial and time independence and full-time income opportunities. Accordingly, DSSRC recommended that Mary Kay immediately remove any remaining implied or express references to full-time income and financial and time freedom or language that could reasonably imply unlimited income potential from Company webpages.
Company Statement
“Mary Kay takes consumer protection very seriously. The Company devotes significant time and resources to proactively monitor, review, and address the concerns outlined within the NGO’s original submission to the DSSRC. To avoid any ambiguity or possible misunderstanding regarding the income potential of the Mary Kay opportunity, the Company commits that all the corporate assets and social media posts identified will be appropriately remedied or removed. In addition, publications by independent sales force members identified have also been removed. Further, those independent sales force members have been appropriately contacted, educated, and where necessary, addressed. The Company is also committed to ensuring that proper disclosures regarding the Pink Cadillac program are available for individuals interested in learning more about the Mary Kay opportunity.”
Case No. #40-2021 PCM (closed on 7/16/2021)
© 2021. BBB National Programs, Inc.
[1] Tina.org
[2] According to the NGO, Mary Kay’s income disclosure statement for Canadian consultants (which it publishes pursuant to Canadian law states that a typical Mary Kay distributor “does not earn any commissions or bonuses” and that pursuant to a chart that is included in the Canadian income disclosure statement, 83 percent of consultants earned nothing in annual commissions in 2019, while 15 percent earned $206 in annual commissions on average, and less than one half of one percent (0.050 percent) earned, on average, $124,072. It also noted that as for the oft-touted Mary Kay car program, consultants do not become eligible to participate in the Mary Kay Pink Cadillac program until they have reached the Independent Sales Director level, which, according to the Canadian income disclosure statement, only happens for less than two percent of consultants.
[3] See https://blog.marykay.com/en/understanding-the-mary-kay-opportunity
[4] During the pendency of the inquiry, a second Pinterest post came to the attention of DSSRC which included a reference to salesforce members obtaining “financial freedom” as a result of participating in the Mary Kay business opportunity. Although the post remains active, The Company advised DSSRC that it is in the process of having the post disabled.
[5] While the DSSRC expressed its appreciation to Mary Kay for its good faith efforts to address the specific posts at issue in this inquiry, it also noted that the posts identified were illustrative of the type of core messages that have been communicated by the Company on various online platforms. DSSRC was encouraged by Mary Kay’s responsiveness to the concerns at issues in this inquiry and its commitment to monitor similar posts which may continue to be disseminated on social media and to continue to train its salesforce members regarding untruthful and inaccurate earning claims.
[6] During the pendency of the inquiry, the NGO submitted additional posts to DSSRC that Mary Kay addressed or was in the process of addressing.
[7] See https://www.ftc.gov/tips-advice/business-center/guidance/business-guidance-concerning-multi-level-marketing
[8] Mary Kay noted that while going through the list of posts that were disseminated by Company consultants, it appeared that there was a technological issue with Facebook that hindered total deletion of some of those older posts. Facebook subsequently released intermittent information to Mary Kay during the pendency of the inquiry confirming that several posts had been removed, not hidden, not searchable, etc. Notwithstanding this update, the Company reiterated its commitment to have the remaining posts that were labeled private or which were password protected removed in their entirety.
[9] DSSRC determined that one of the Instagram posts that was submitted by the NGO did not include any problematic earnings claims.
[10] See Case #24-2020 -NGO Inquiry- Le-Vel Brands LLC and Case# 12-2020 - Aloette Cosmetics
[11] DSSRC recognized that Mary Kay was in the process of communicating with its salesforce members to reconcile several posts that remained accessible to the general public and continued to make modifications to language on the Company controlled webpages. However, as the Company contemplates replacement or additional qualifying language for such statements or posts, it cannot be ignored that the claims nevertheless remain active and may be relied on by consumers. As such, DSSRC recommends that Mary Kay remove such posts or claims until such representations are removed or modified accordingly.
[12] See Case #27-2020 -Monitoring Inquiry- LurraLife, LLC, footnote #4.
[13] These YouTube videos were not part of the NGO’s original submission.
[14] Section 255 (2)(b) of the FTC’s Guide on the Use of Endorsements and Testimonials in Advertising (the “FTC Guides”) states that “[a]n advertisement containing an endorsement relating the experience of one or more consumers on a central or key attribute of the product or service also will likely be interpreted as representing that the endorser’s experience is representative of what consumers will generally achieve with the advertised product or service in actual, albeit variable, conditions of use. Therefore, an advertiser should possess and rely upon adequate substantiation for this representation. If the advertiser does not have substantiation that the endorser’s experience is representative of what consumers will generally achieve, the advertisement should clearly and conspicuously disclose the generally expected performance in the depicted circumstances, and the advertiser must possess and rely on adequate substantiation for that representation.
[15] See Case #27-2020 -Monitoring Inquiry- LurraLife, LLC, footnote #4.
[17] Colgate-Palmolive Company (Colgate Optic White Toothpaste), Report #5490, NAD/CARU Case Reports (July 2012); Hisamitsu America, Inc. (Salonpas Pain Relief Patch Large), Report #6918, NAD/CARU Case Reports (February 2021).
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...
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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...
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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...
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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.”...
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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.
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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.
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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.
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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
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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.