152 3265

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Edith Ramirez, Chairwoman

Maureen K. Ohlhausen

Terrell McSweeny

________________________________________________

In the Matter of

TRANS-INDIA PRODUCTS, INC., a corporation,

d/b/a/ SHIKAI. DOCKET NO.

______________________________________________

COMPLAINT

The Federal Trade Commission, having reason to believe that Trans-India Products, Inc., 

has violated the provisions of the Federal Trade Commission Act, and it appearing to the 

Commission that this proceeding is in the public interest, alleges:

1. Respondent Trans-India Products, Inc., doing business as ShiKai, is a California 

corporation with its principal office or place of business at 3330-A Coffey Lane, Santa Rosa, 

California 95404, and a mailing address of Box 2866, Santa Rosa, California 95405.

2. Respondent has advertised, labeled, offered for sale, sold, and distributed products 

to consumers, including “All Natural Hand and Body Lotion” and “All Natural Moisturizing 

Shower Gel.” 

3. The acts and practices of Respondent alleged in this complaint have been in or 

affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission 

Act.

4. Respondent advertises the above products on the Internet. They retail for $6.39 to 

$6.59.

5. Respondent has disseminated or has caused to be disseminated advertisements for 

its Hand and Body Lotion and Moisturizing Shower Gel, including but not necessarily limited to 

the attached Exhibits A-C.

 

A. The packaging for the Hand and Body Lotion states that it is an “All Natural 

Hand and Body Lotion.”

Exhibit A, Internet webpage www.walgreens.com/store/c/shikai-all-natural-handand-body-lotion-starfruit (August 2015). 
2

B. Respondent’s catalogue states that the Hand and Body Lotion contains:

wonderful rich ingredients: lots of aloe vera, wheatgerm & apricot oils, shea 

butter, and borage oil too. And they’re all natural.

Exhibit B, Internet webpage www.shikai.com/home/catalogue.pdf at p. 10 

(August 2015). 

C. The packaging for the Moisturizing Shower Gel states that it is an “All Natural 

Moisturizing Shower Gel.” 

Exhibit C, Internet webpage www.vitacost.com/shikai-all-natural-moisturizingshowerhand-and-body-lotion-coconut-12-fl-oz (August 2015); Exhibit D, Internet 

webpage www.shikai.com/home/catalogue.pdf at p. 11 (August 2015).

Count I

False Claim

6. In connection with the advertising, labeling, promotion, offering for sale, or sale 

of its All Natural Hand and Body Lotion and All Natural Moisturizing Shower Gel, Respondent 

has represented, directly or indirectly, expressly or by implication, that these products are “all 

natural.”

7. In fact, All Natural Hand and Body Lotion and All Natural Moisturizing Shower 

Gel are not “all natural” because they contain or contained at least one synthetic ingredient. The 

All Natural Hand and Body Lotion contains or contained the synthetic ingredients Dimethicone,

Ethylhexyl Glycerin, and Phenoxyethanol. The All Natural Moisturizing Shower Gel contains or 

contained the synthetic ingredients Ethylhexyl Glycerin and Phenoxyethanol. Therefore, the “all 

natural” representations set forth in Paragraph 6 are false or misleading.

Violations of Section 5(a)

8. The acts and practices of Respondent as alleged in this complaint constitute unfair 

or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act.

THEREFORE, the Federal Trade Commission this _______ day of _______, 2016, has 

issued this Complaint against Respondent.

By the Commission.

Donald S. Clark

Secretary

SEAL: