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 #20-2020 -Compliance- Pure Romance, LLC
BBB NATIONAL PROGRAMS, INC.
The Direct Selling Self-Regulatory Council
Case Number: 20-2020 – Compliance– Pure Romance, LLC
COMPANY DESCRIPTION
Pure Romance LLC (“Pure Romance” or the “Company”) is a multi-level direct selling company that specializes in beauty products and bedroom accessories for women. According to the Company website, Pure Romance has 30,000 active consultants located in the United States, South Africa, Canada, Puerto Rico, New Zealand, and Australia.
BACKGROUND
In 2019, the Direct Selling Self-Regulatory Council (“DSSRC”), a national advertising self-regulation program administered by BBB National Programs, Inc, commenced a review pursuant to its ongoing independent monitoring of advertising and marketing claims in the direct selling industry regarding several core earnings claims being disseminated on the social media pages by Pure Romance consultants as well as on videos located on the Pure Romance website.
The representative earnings claims that were the subject of that review were as follows:
- Express and Implied Earnings Claims – Consultants’ Social Media Posts
- Pure Romance Consultant Facebook Post #1:
“Just a few things Pure Romance has done for me:
- “Quit my full time job”
- “extra spending money”(money bag emoji)
- Spend more time with my kids
- “pay off debt” (cash emoji)
-“turned me into a boss babe building an empire”(castle emoji)
- Pure Romance Consultant Facebook Post #2:
Depiction of a spread of bills of various denominations into several piles on a table (i.e., one spread of $100 bills, $50 bills and $20 bills marked “Pure Romance”; one spread of ten $20 bills marked “Tacos”; a $20 bill representing “Gas”; one $20 bill representing “Me” and two one-dollar bills representing “Babe”).
- Pure Romance Consultant Facebook Post #3:
- “Part time hours with Full time pay!!”
- Pure Romance Consultant Instagram Post #1:
- “Need to make an additional $200, $500, $800, $1100 or more a month...?”
- “Or maybe you want to #FireYourBoss Like I did! “
- Pure Romance Consultant Instagram Post #2:
- “Full time mommy, part time Pure Romance consultant making full time income!”
- Pure Romance Consultant Facebook Post #1:
- Express and Implied Earnings Claims – Video Testimonials on the Company Website
During the pendency of the 2019 DSSRC review, DSSRC identified the following four “success story” videos (“Real Stories – Meet women just like you who are living their BEST LIFE with Pure Romance”) on the Company website:
- Video #1 testimonial from a Pure Romance consultant: “Paid for wedding with no debt. It was a $10,000 wedding. I didn’t have to pay anything on a credit card…. Also within that year, we were able to come down with a small down
payment for our first home. We went from living in a trailer park into a single-family home that we actually owned, with a little backyard and three bedrooms and an office space and all of this stiff that we never had before. It was amazing
to know that my business was the sole reason why this was able to happen.”
- Video #2 testimonial from a Pure Romance consultant: “I wanted to be able to comfortably pay bills and on top of that be able to travel and afford things, nice things, go out to dinner…. I wanted to be able to live free… After
my first party, I quit my fulltime job. I have been fulltime with Pure Romance for three-and-a-half years.”
- Video #3 testimonial from a Pure Romance consultant: “[The Pure Romance consultant told me] If you ever need an extra $100 a month or an extra $1,000 a month, this could be a good fit for you…How am I going to feed my kids? I’m
used to a certain lifestyle, I just took on this new car payment that I really can’t afford. [I said] Let’s talk about it I need to make $464 a month. If you think I can do this, then I’m going to try it and that was it.”
- Video #4 testimonial from a Pure Romance consultant: “I went to Paris. I went to Fiji. I did the west side of America as well. I did California, Nevada, Arizona… Pure Romance has given me my life and the life I deserved, that I never knew I deserved until I found it.”
In its response to the concerns raised by DSSRC regarding the express and implied claims communicated by Pure Romance consultants on social media posts, the Company indicated to DSSRC that it was in the process of contacting the independent consultants whose social media posts were identified in the inquiry requesting that they remove the posts in question and to provide the consultants with compliance guidance regarding the issues with the posts identified by DSSRC.
In addition, Pure Romance indicated to DSSRC that it had recently taken a number of significant steps to increase compliance training and the scope of its monitoring of the social media posts of its consultants. The Company also updated its policy and procedures to include information on the type of claims that are appropriate for consultants’ marketing materials.
During the pendency of the matter, Pure Romance was very receptive to the initial recommendations made by the DSSRC and, in the spirit of voluntary self-regulation, removed the two Instagram posts at issue in the inquiry. With respect to the three Facebook posts identified by DSSRC in the inquiry, DSSRC determined that these social media posts would be reasonably interpreted by consumers as meaning that the typical Pure Romance Independent Consultant will earn either substantial or career-level income when no evidence was provided to support such a message. Accordingly, DSSRC recommended that the Facebook posts should be immediately removed.
Similarly, DSSRC determined that the four Success Story videos located on the Pure Romance website communicated various unqualified income representations regarding the earnings opportunity of a Pure Romance Independent Consultant. DSSRC determined those representations may be reasonably interpreted by consumers and potential salesforce members as meaning that the income earned by the Pure Romance consultants in the video could be typically expected by potential Pure Romance consultants. However, there was no support provided by the Company for such a take-away. Thus, DSSRC recommended that the videos be significantly modified or removed until such time that the Company possess reliable evidence to support the implied claims that the same level of income attested to in the Success Story videos can also be expected by the typical Pure Romance Independent Consultant.
In its Company Statement that was part of the DSSRC decision, Pure Romance stated that it agreed with DSSRC’s recommendations and has “… taken measures to address the concerns expressed by the DSSRC. Specifically, in some cases Pure Romance has requested that its independent Consultants remove social media posts. In other situations, however, Pure Romance has determined that social media posts issued by independent Consultants would be better addressed through disclosing the generally expected income results for its Independent Consultants.” In addition, Pure Romance informed DSSRC that it was in the process of evaluating current and future materials on its own website for modifications to ensure all materials include proper disclosures.”
COMPLIANCE INQUIRY
As part of its compliance process, DSSRC will independently review advertising that has been the subject of previous inquiries. In January 2020, DSSRC reviewed the Pure Romance website and found that the same four Success Story videos that were the subject of the 2019 inquiry had not been removed or modified as was recommended.
In February 2020 DSSRC contacted Pure Romance and asked the Company to provide an update on the actions it had taken to adhere with the recommendations made by DSSRC in its 2019 decision. DSSRC also inquired about a new video that appeared in the “Real Stories” section of the Pure Romance website[1] that included many atypical income claims for Pure Romance consultants which were similar to those that were the subject of the aforementioned 2019 DSSRC inquiry.
More specifically, the following income and company incentive claims were being disseminated in the new video:
- “I decided to buy a kit and I was just gonna do it for a little bit and then I was gonna get a real job and I’ve been getting paid to party for almost 12 years.”
- Images of large checks showing significant income received by Pure Romance consultants – e.g., “$1,710,000”; “$124,963”; “$106,497”; “$25,528,969”
- Right now, my override checks are more money than people actually make in an entire year in a month and to make six figures a year is funny because my goal is now to make six figures a month.”
- “In my first month I made $800, in my second month I made $2000, so I replaced my full-time income my first year with Pure Romance. It’s an awesome job.”
- You know we were taking some amazing vacations because of Pure Romance. Pure Romance spoils us. They take really good care of us. I have been on over 31 free vacations thanks to Pure Romance and literally I started to just take my
family on a vacation.”
- “The most amazing thing that I’ve been able to do with my Pure Romance income is actually being able to save it. My husband and I were purchasing a home and we’re actually having it built and customized the way we
want and it’s all because of Pure Romance.”
- “In my first month I made $800, in my second month I made $2000, so I replaced my full-time income my first year with Pure Romance. It’s an awesome job.”
- “If you want an extra $100 or an extra $1000 a month this could be a good fit for you.”
- “Living the dream is being able to pay your daughter’s student loans so when they graduate from college they don’t have that debt, they don’t have that worry.”
- “I want to be able to say that I, I can live the way that I would you know want to live when it’s time for me to retire and I want to be able to put my kids through college and not have to struggle with the day to day with those things.”
- “I can provide more for my family and I can give them things that I never in a million years thought that I’d be able to give them and to provide for them.”
- “When it comes to Pure Romance, there’s no glass ceiling, you can go as high as you want to.”
DSSRC expressed concern to the Company that in the context in which the above-stated claims were presented, it would be reasonable for consumers and/or potential salesforce members to interpret these income statements as pertaining to the annual amount of income that could be generally expected by the typical Pure Romance consultant.
Shortly following its receipt of DSSRC’s compliance inquiry, the Company contacted DSSRC to indicate that it had taken down the new video from the Pure Romance website. While DSSRC expressed its appreciation for the action taken by the Company to remove the new video, it also expressed its concern that the Success Stories videos that were the subject of the 2019 inquiry continued to be disseminated on the Pure Romance website. Moreover, DSSRC also called the Company’s attention to an additional sixteen social media posts (including YouTube videos) disseminated by Pure Romance consultants which communicated unsupported earnings claims (e.g., “limitless income,” “I have the financial freedom to do things I couldn’t do with my full time job!”; “Unlimited money making potential!!!!,” “Can you use an extra $1,000 per month working only 10 hours a month?” “Financial Freedom is real with Pure Romance. Part time hours with Full time pay!!,” etc.).
DSSRC was also concerned with a hypothetical earnings scenario presented on the Pure Romance website in the section titled “How much income will you earn.” More specifically, two boxes were depicted on the webpage, each with hypothetical earnings presented in two different scenarios. In the first box titled “1 Party” it explained that “The average party gets $600* in sales, which means you can earn: $180** with a 30% discount -or- $240 with a 40% discount.”
The accompanying disclosure stated: “The earning opportunity associated with owning a Pure Romance business is open-ended; however, it is impossible to guarantee that a particular level of income can be earned because of a number of factors, including your personal goals and amount of time and effort you choose to invest in your business. See our income disclosure statement here.”
A second disclosure stated: “**Based on a 30% Buying Discount with $600 in Retail Sales. Profits may vary.”
A second box titled “1 Week” stated that “if you did three parties a week (about four hours each), you could earn: $540 with a 30% discount— or — $720 with a 40% discount.”
COMPANY’S RESPONSE TO COMPLIANCE INQUIRY
Pure Romance advised DSSRC that it took a number of significant actions in response to the compliance inquiry. Immediately after being informed of the DSSRC’s concerns regarding the new video that appeared in the “Real Stories” section of the Pure Romance website, the Company promptly disabled the video and made several other modifications to the website.
The Company also advised DSSRC that the four Success Stories videos that were the subject of the 2019 inquiry had been removed from the website.
With respect to the social media posts that were identified by DSSRC in the compliance inquiry, Pure Romance noted that all of the posts were more than a year old and predated the Company’s current compliance protocol. Nevertheless, the Company attempted to contact each of the consultants who authored the posts and requested that they be removed. According to Pure Romance all of the posts were removed with the exception of two posts from inactive distributors and that it has contacted all of the applicable Consultants and facilitated removal of the social media posts.
COMPLIANCE DETERMINATION
DSSRC recognized the good faith actions taken by Pure Romance in the spirit of voluntary self-regulation. DSSRC confirmed that the Company disabled the new video that appeared on the Company website, took down the four Success Stories videos that were the subject of the 2019 inquiry, removed ten Facebook and Instagram posts, and took down three YouTube videos. Collectively, approximately thirty claims were removed or significantly modified by the Company.
Notwithstanding the significant actions taken by the Company, three Pure Romance posts – all of which were disseminated by consultants who are now inactive, still appear on Facebook and Instagram.
More specifically, those posts state:
- “Who L♡VES FREE product?; - Who L♡VES FREE money?; - Who HATES having a Boss?; - Who would L♡VE being able to make their OWN work schedule & have financial FREEDOM? *This opportunity is NOT a scheme! This is LEGIT! You get PAID to party! Who wouldnt L♡VE that?!*” [2]
“Only 700 starter packs left where you can get your investment back in CASH! Who's ready to pay those bills??? #debtfree #bossbabe” [3]
“I made over $200 with just three hours of working and having a good time and still have potential on making so much more!! Man I love my job, if I have some ladies out there that would like to know more about the business comment ME below.
Anyone who can refer a friend who would like to start earning an extra $1000 a month please tag them in this post!!”[4]
Pure Romance did not dispute that the three posts made unqualified reference to earnings that could not be generally expected by consumers and DSSRC acknowledged that the Company made a good faith attempt to contact these individuals who are no longer Pure Romance
Consultants to take the posts down but were unsuccessful.
When a direct selling company such as Pure Romance is made aware of an improper product or income claim that was made by an individual that was an active consultant when such claim was made but that has since become an inactive consultant of the company, DSSRC acknowledges that the direct selling company may not be able to require the former consultant to remove such claim.[5] In that instance, DSSRC nonetheless recommends that the direct selling company make a bona fide good faith effort to have the improper claim removed. DSSRC determined that actions similar to Pure Romance requesting the removal of claims communicated by active consultants would constitute a bona fide good faith attempt with respect to removing improper claims made by consultants that have since become inactive. If the social media platform where the subject post was made provides a mechanism for reporting trademark or copyright violations, DSSRC recommends that the direct selling company promptly utilize such mechanism and seek removal of the subject claims and posts, if possible. If the subject claim that came to the attention of the direct selling company occurred on a website or platform without a reporting mechanism, DSSRC recommends that in addition to contacting the former consultant in writing as described above, the Company contact the website or platform in writing and request removal of the subject claim or post.[6]
Accordingly, while expressing its appreciation for good faith efforts taken by Pure Romance to reach out to consultants who are no longer active to take down unauthorized posts, DSSRC also recommended that Pure Romance inquire with Facebook and Instagram to determine if the social media platforms where the subject posts were made provides a mechanism for reporting trademark or copyright violations, and, if such a mechanism exists for the platforms, DSSRC recommends that the direct selling company promptly utilize such mechanism if possible and further seek removal of the subject claims and posts.
Despite the significant actions taken by the Company to remove the subject social media posts, the Company was silent on the issue of the hypothetical earnings scenario that is presented on the Pure Romance website.
In its 2018 Business Guidance Concerning Multi-Level Marketing, the Federal Trade Commission (FTC) stated that “…a hypothetical earnings scenario – such as “if you recruit 30 people who each sell $1,000 of product each month, you will earn $1,500 a month” – may imply that the assumptions made (e.g., the number of people recruited, the amount sold by each recruit) are consistent with the actual experiences of typical participants. If the assumptions are not, the earnings scenario likely would be false or misleading to consumers.”[7]
Here, the side-by-side hypothetical scenarios presented by Pure Romance supposes that if a consultant hosts one party per week resulting in $600 in products sales, Company consultants earn $180 with a 30% buying discount on product or $240 with a 40% buying discount on product. The second hypothetical proposes that if consultants hosts three parties per week that they can thus earn $540 (with a 30% discount on product sales) and $720 (with a 40% discount on product sales). Although requested by DSSRC, the Company did not produce any sales information indicating that the average party hosted by a Pure Romance consultant results in $600 in product sales or how many parties per week are hosted by the typical Pure Romance consultant.
DSSRC determined that based upon the scenario presented by Pure Romance it would be reasonable for consumers or incoming salesforce members to take-away the message that the typical Company consultant can earn between $9,360 (with a 30% discount on product) and $12,480 (with a 40% discount on product) per year and, accordingly, that consultants can earn up to $37,440 per year if they host three parties per week (i.e., with a 40% discount on product). However, in the absence of any information regarding the amount of annual income that can be generally expected by Pure Romance consultants, the number of parties per year that are hosted by the typical Pure Romance consultant, and without any information on the amount of expenses incurred by the typical Pure Romance consultant, DSSRC determined that hypothetical scenario presented by Pure Romance on its website is unsupported and inaccurate and should be removed from the website in the context in which it is presented.
CONCLUSION
DSSRC determined that Pure Romance made a bona fide, good faith effort attempt to comply with DSSRC’s 2019 decision and has subsequently taken constructive steps to remove questionable claims brought to its attention and to strengthen the compliance oversight of its salesforce. However, DSSRC remains concerned with the hypothetical earnings scenario presented on the Company website and the message that Pure Romance consultants can typically host several weekly parties and earn significant income. Moreover, while recognizing the efforts taken by the Company to remove posts made by Pure Romance consultants who are no longer active consultants, DSSRC recommends that the Company inquire with Facebook and Instagram to determine if the social media platforms provide a mechanism for reporting trademark or copyright violations and, if possible, that it take additional steps to have the unauthorized posts removed. DSSRC reserves the right to make subsequent compliance inquiries of the Company and, depending upon the actions that the marketer has taken to comply with this compliance determination within a reasonable period of time, DSSRC will proceed with the enforcement mechanisms pursuant to the DSSRC Policies & Procedures.
COMPANY STATEMENT
“Pure Romance appreciates the DSSRC’s feedback, the opportunity to collaborate and cooperate with the DSSRC, and the DSSRC’s recognition of the company’s prompt, good-faith actions to fully address the issues identified by the DSSRC. As explained in a letter dated June 15, 2020, Pure Romance took actions resulting in the removal of all five videos and thirteen of the sixteen social media posts identified by DSSRC. Each of the three instances in which the content identified by the DSSRC remains online are social media posts made a year or more ago by individuals who are no longer active Pure Romance consultants, and who have been unresponsive to Pure Romance’s repeated outreach efforts to request removal of the content.
In response to DSSRC’s concerns with the hypothetical party earnings scenarios presented on the company’s website and the message that Pure Romance consultants can host several weekly parties and earn significant income, Pure Romance has updated the hypotheticals and revamped the prominently displayed typicality disclosure, including by incorporating median 2019 consultant earnings information a link to detailed consultant earnings data for 2019.
In addition, Pure Romance has invested substantial company resources, including retaining expert outside counsel, to broadly review and update its earnings disclosures and related consultant training materials. Notwithstanding the challenges associated with executing this effort in the midst of the coronavirus pandemic, these changes are now live.”
(DSSRC Case No: 20-2020. Copyright 2020. BBB National Programs, Inc.)
[1] https://www.pureromance.com/pws/homeoffice/tabs/join.
[2] https://www.facebook.com/partiesbytiffanylynn/posts/1038347966368890.
[3] https://www.instagram.com/p/BLHhuK9BHpM/.
[4] https://www.facebook.com/1661546603961578/photos/a.1664530883663150/1674155846033987/?type=3&theater
[5] See DSSRC Case No. 13; Young Living Essential Oils, LLC (closed HS 2/20/20).
[6] Id .
[7] See Section 13 FTC Guidance on Multilevel Marketing, fifth bullet point.
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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
DSSRC Administrative Closure #243
DSSRC Administrative Closure #242
DSSRC Administrative Closure #241
DSSRC Administrative Closure #240
DSSRC Administrative Closure #239
DSSRC Administrative Closure #238
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DSSRC Administrative Closure #236
DSSRC Administrative Closure #235
DSSRC Administrative Closure #234
DSSRC Administrative Closure #233
DSSRC Administrative Closure #232
DSSRC Administrative Closure #231
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
DSSRC Administrative Closure #228
DSSRC Administrative Closure #227
DSSRC Administrative Closure #226
DSSRC Administrative Closure #225
DSSRC Administrative Closure #224
DSSRC Administrative Closure #223
DSSRC Administrative Closure #222
DSSRC Administrative Closure #221
DSSRC Administrative Closure #220
DSSRC Administrative Closure #219
DSSRC Administrative Closure #218
DSSRC Administrative Closure #217
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
DSSRC Administrative Closure #209
DSSRC Administrative Closure #208
DSSRC Administrative Closure #207
DSSRC Administrative Closure #206
DSSRC Administrative Closure #205
DSSRC Administrative Closure #204
DSSRC Administrative Closure #203
DSSRC Administrative Closure #202
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
DSSRC Administrative Closure #199
DSSRC Administrative Closure #198
DSSRC Administrative Closure #197
DSSRC Administrative Closure #196
DSSRC Administrative Closure #195
DSSRC Administrative Closure #194
DSSRC Administrative Closure #193
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
DSSRC Administrative Closure #190
DSSRC Administrative Closure #189
DSSRC Administrative Closure #188
DSSRC Administrative Closure #187
DSSRC Administrative Closure #186
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
DSSRC Administrative Closure #176
DSSRC Administrative Closure #175
DSSRC Administrative Closure #174
DSSRC Administrative Closure #173
DSSRC Administrative Closure #172
DSSRC Administrative Closure #171
DSSRC Administrative Closure #170
DSSRC contacted a direct selling company regarding three social media posts disseminated by salesforce members that communicated the efficacy of the Company’s products to treat ADHD in children, COVID-19 and other health-related conditions. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #169
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding three social media posts that DSSRC was concerned conveyed, either through depictions or accompanying text, that the Company’s salesforce members can earn a significant income through the Company’s business opportunity.
DSSRC Administrative Closure #168
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four social media posts that DSSRC was concerned contained health-related product claims including statements that the Company’s products could prevent, treat, or cure COVID-19. DSSRC identified the subject social media posts that were made by Company salesforce members through its ongoing...
DSSRC Administrative Closure #167
DSSRC Administrative Closure #166
DSSRC Administrative Closure #165
DSSRC Administrative Closure #164
DSSRC Administrative Closure #163
DSSRC Administrative Closure #162
DSSRC Administrative Closure #161
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four Facebook posts that were disseminated by salesforce members of the Company. All four of the post conveyed strong health-related product claims including the message that the Company’s products were effective to treat serious health conditions such as COVID-19, ADHD, dementia, Alzheimer’s...
DSSRC Administrative Closure #160
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding social media posts that were disseminated by salesforce members. The subject claims and social media posts came to DSSRC’s attention through its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #159
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding four Facebook posts that were disseminated by Company salesforce members. All four of the posts made reference to prospective salesforce members being able to “replace lost income” through the Company’s business opportunity and one of the posts included an implied reference to achieving...
DSSRC Administrative Closure #158
DSSRC Administrative Closure #157
DSSRC Administrative Closure #156
DSSRC Administrative Closure #155
DSSRC Administrative Closure #154
DSSRC Administrative Closure #153
DSSRC Administrative Closure #152
DSSRC Administrative Closure #151
DSSRC Administrative Closure #150
DSSRC Administrative Closure #149
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding one Facebook post and two TikTok posts disseminated by salesforce members of the Company. DSSRC was concerned that the Facebook post conveyed disease treatment claims and that the TikTok posts contained strong health-related product performance claims including claims that the Company’s...
DSSRC Administrative Closure #148
DSSRC Administrative Closure #147
DSSRC Administrative Closure #146
DSSRC Administrative Closure #145
DSSRC Administrative Closure #144
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DSSRC Administrative Closure #142
DSSRC Administrative Closure #141
DSSRC Administrative Closure #140
DSSRC Administrative Closure #139
DSSRC Administrative Closure #138
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts disseminated by salesforce members. DSSRC was concerned that one of the posts conveyed claims that the Company’s products can protect against disease including express claims stating that the salesforce member is “COVID free” and the products being a “pandemic response.”...
DSSRC Administrative Closure #137
DSSRC Administrative Closure #136
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DSSRC Administrative Closure #118
DSSRC Administrative Closure #117
DSSRC Administrative Closure #116
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding six posts made on social media by Company salesforce members. DSSRC was concerned that the social media posts disseminated by these Company salesforce members included unsubstantiated product, health and wellness benefits including claims that the Company’s products can protect against...
DSSRC Administrative Closure #115
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts by Company salesforce members that referenced serious health-related conditions that purportedly could be addressed by use of the Company’s products.
DSSRC Administrative Closure #114
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) regarding two Facebook posts making claims about the Company’s products. The Facebook posts were disseminated by a Company salesforce member and a former salesforce member of the Company. The social media posts were identified during DSSRC’s monitoring of the...
DSSRC Administrative Closure #113
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts disseminated by Company salesforce members that were identified during DSSRC’s monitoring of the direct selling industry. DSSRC expressed its concern to the Company that all of the posts implied that the Company products are effective to treat a number of health-related...
DSSRC Administrative Closure #112
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts that were identified during DSSRC’s monitoring of the direct selling industry and disseminated by Company salesforce members.
DSSRC Administrative Closure #111
DSSRC Administrative Closure #110
DSSRC Administrative Closure #109
DSSRC Administrative Closure #108
The Direct Selling Self-Regulatory Council (“DSSRC”) commenced an inquiry with a direct selling company (“Company”) regarding three Facebook posts disseminated by Company salesforce members.
DSSRC Administrative Closure #107
DSSRC Administrative Closure #106
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) about three Facebook posts disseminated by salesforce members of the Company. Two of the posts in question implied that the Company’s nutritional products could help individuals that consume such products fight viruses including COVID-19. The other post made specific health-related product efficacy claims...
DSSRC Administrative Closure #105
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (the “Company”) about two Facebook posts disseminated by salesforce members of the Company. The posts in question implied that engaging in direct selling of the Company’s products could provide replacement income for those out of work due to COVID and/or a new career during the current public health crisis.
DSSRC Administrative Closure #104
DSSRC Administrative Closure #103
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (Company) regarding three Facebook posts disseminated by its salesforce members. The subject claims and social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #102
DSSRC Administrative Closure #101
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company (Company) regarding three coronavirus related hashtags that accompanied a post stating that the Company’s product can strengthen the immune system. Earlier this year, the Federal Trade Commission (FTC) stated that coronavirus related claims and hashtags when coupled with claims that a product can strengthen or boost the...
DSSRC Administrative Closure #100
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding two Facebook posts and one Instagram post disseminated by Company salesforce members. All three posts referenced the ability of the direct selling company’s product to prevent and eliminate the coronavirus.
DSSRC Administrative Closure #99
The Direct Selling Self-Regulatory Council (DSSRC) contacted a direct selling company regarding three Facebook post disseminated by its salesforce members. The subject claims and social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #98
DSSRC Administrative Closure #97
DSSRC Administrative Closure #96
The Direct Selling Self-Regulatory Council (“DSSRC”) contacted a direct selling company (“Company”) regarding three Facebook posts disseminated by salesforce members that included claims that the Company’s products can assist in treating a number of serious health-related conditions including, but not limited to, Alzheimer’s, Parkinson’s disease and Multiple Sclerosis.
DSSRC Administrative Closure #95
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DSSRC Administrative Closure #81
DSSRC Administrative Closure #80
DSSRC contacted a direct selling company regarding two Facebook posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the posts conveyed the unsupported health-related message that the Company’s direct selling products can protect...
DSSRC Administrative Closure #79
DSSRC contacted a direct selling company regarding three social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that the posts conveyed unsupported product, health and wellness benefits and the message that the Company’s...
DSSRC Administrative Closure #78
DSSRC Administrative Closure #77
DSSRC Administrative Closure #76
Social media advertising for a direct selling company that markets health and wellness products came to the attention of the Direct Selling Self-Regulatory Council (DSSRC) pursuant to its monitoring of the direct selling industry. DSSRC identified three Facebook posts that were disseminated by Company salesforce members as communicating egregious health-related claims. One post stated “build your immune...
DSSRC Administrative Closure #75
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DSSRC Administrative Closure #71
DSSRC Administrative Closure #70
DSSRC contacted a direct selling company about two Facebook posts disseminated by the company’s salesforce members that conveyed product performance stating and/or implying that the company’s products can help prevent or treat COVID-19. Both posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #69
DSSRC contacted a direct selling company about two YouTube videos disseminated by the company’s salesforce members that conveyed product performance claims while referencing the current global pandemic. Both videos came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #68
DSSRC contacted a direct selling company about two social media posts disseminated by the company’s salesforce members that conveyed product performance claims. Both social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #67
DSSRC contacted a direct selling company about certain social media posts disseminated by salesforce members regarding product efficacy claims that referenced “Corona Virus.” DSSRC also identified more general product claims regarding viruses that DSSRC was concerned could be reasonably interpreted could be reasonably interpreted as meaning that the company’s products are effective against the...
DSSRC Administrative Closure #66
DSSRC contacted a direct selling company about three social media posts disseminated by salesforce members regarding business opportunities during the pandemic. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #65
DSSRC contacted a direct selling company about three business opportunity posts disseminated by salesforce members. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace.
DSSRC Administrative Closure #64
DSSRC contacted a direct selling company about three social media post disseminated by salesforce members. The social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media posts conveyed unsubstantiated product health and wellness benefit claims related to the current COVID-19...
DSSRC Administrative Closure #63
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DSSRC Administrative Closure #53
DSSRC Administrative Closure #52
DSSRC contacted a direct selling company about four social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media posts conveyed unsubstantiated product, health and wellness benefits that the Company’s direct...
DSSRC Administrative Closure #51
DSSRC Administrative Closure #50
DSSRC Administrative Closure #49
DSSRC Administrative Closure #48
DSSRC contacted a direct selling company about a social media post disseminated by a salesforce member. The subject social media post came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concern that the social media post conveyed unsubstantiated product, health and wellness benefits that the Company’s direct selling...
DSSRC Administrative Closure #47
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DSSRC Administrative Closure #44
DSSRC Administrative Closure #43
DSSRC Administrative Closure #42
DSSRC contacted a direct selling company about two social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that two of the social media posts conveyed unsubstantiated product, health and wellness benefits that the Company’s...
DSSRC Administrative Closure #41
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DSSRC Administrative Closure #39
DSSRC contacted a direct selling company about thirty-five social media posts disseminated by its salesforce members. The subject social media posts came to DSSRC’s attention pursuant to its independent monitoring of advertising in the direct selling marketplace. Specifically, DSSRC expressed concerns that thirty-three of the social media posts...
DSSRC Administrative Closure #38
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DSSRC Administrative Closure #32
Social media posts disseminated by distributors for a multi-level company came to the attention of the Direct Selling Self-Regulatory Council (DSSRC) pursuant to its internal monitoring process. More specifically, one Instagram post...
DSSRC Administrative Closure #31
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DSSRC Administrative Closure #19
DSSRC Administrative Closure #18
In 2019, DSSRC contacted a direct selling company regarding several earnings claims on the direct selling company’s website as well as claims that were being disseminated by the company’s salesforce on social media.
DSSRC Administrative Closure #17
DSSRC contacted a direct selling company (the “Company”) about earnings claims disseminated on the Company’s website and on social media by salesforce members. Specifically, DSSRC identified a number of express and implied earnings claim that referenced financial freedom, exorbitant bonuses and vacations, luxury cars, the ability to pay off college loans and generous reward programs. The advertising also...
DSSRC Administrative Closure #16
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DSSRC Administrative Closure #11
In 2020, a direct selling company contacted DSSRC seeking guidance regarding company events at which top distributors are recognized. The direct selling company stated that it had previously presented some of its highest performing distributors with oversized checks at the event but, since the success of those top distributors was not typical, it was concerned that the oversized checks might convey an...
DSSRC Administrative Closure #10
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DSSRC Administrative Closure #3
DSSRC Administrative Closure #2
DSSRC opened an inquiry with a direct selling company regarding Instagram and Facebook posts made by the Company salesforce regarding claims of achieving “financial freedom,” a claim stating that potential recruits can “earn the income that want,” an unqualified claim of atypical earnings and an unqualified claim regarding company incentive trips.
DSSRC Administrative Closure #1
The Direct Selling Self-Regulatory Council (DSSRC) inquired with a direct selling company regarding twos social media posts disseminated by members of the Company salesforce. The first claim appeared on Instagram and stated that that the salesforce member was able to more than replace her salary from here previous, full-time job.