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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 1 of 21 Page ID #:1 

ALDEN F. ABBOTT 

General Counsel 

JANET M. EVANS 

DC Bar No. 358467; jevans@ftc.gov 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Mail Drop CC-10528 

Washington, D.C. 20580 

Tel: (202) 326-2125; Fax: (202) 326-3259 

ROBERT QUIGLEY (Local Counsel) 

CA Bar No. 302879; rquigley@ftc.gov 

Federal Trade Commission 

10990 Wilshire Blvd., Suite 400 

Los Angeles, California 90024 

Tel: (310) 824-4300; Fax: (310) 824-4380 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FEDERAL TRADE COMMISSION, ) 

) 

Plaintiff, ) 

) 

v. ) 

) 

NOBETES CORPORATION, a/k/a SIDE ) 

EFFECTS SOLUTIONS CORPORATION, ) 

a corporation, ) 

) 

MARVIN SILVER, individually and as an ) 

officer and director of Nobetes Corporation, ) 

and ) 

) 

JEFFREY FLEITMAN, individually and as ) 

an officer and director of Nobetes ) 

Corporation, ) 

) 

Defendants. ) 

Case No. 2:18-cv-10068

COMPLAINT FOR 

PERMANENT INJUNCTION 

AND OTHER EQUITABLE 

RELIEF 

Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges: 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 2 of 21 Page ID #:2 

1. The FTC brings this action under Section 13(b) of the Federal Trade 

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), to obtain permanent injunctive 

relief, rescission or reformation of contracts, restitution, the refund of monies paid, 

disgorgement of ill-gotten monies, and other equitable relief for Defendants’ acts 

or practices in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) 

and 52, in connection with the advertising and labeling, offering for sale, sale, or 

distribution of Nobetes, a purported diabetes treatment. 

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 

§§ 1331, 1337(a), and 1345, and 15 U.S.C. §§ 45(a) and 53(b). 

3. Venue is proper in this district under 28 U.S.C. § 1391(b)(1), (b)(2), 

(c)(1), (c)(2), and (d), and 15 U.S.C. § 53(b). 

PLAINTIFF 

4. The FTC is an independent agency of the United States Government 

created by statute. 15 U.S.C. §§ 41-58. The FTC enforces Section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 

affecting commerce. The FTC also enforces Section 12 of the FTC Act, 15 U.S.C. 

§ 52, which prohibits false advertisements for food, drugs, devices, services, or 

cosmetics in or affecting commerce. 

5. The FTC is authorized to initiate federal district court proceedings, by 

its own attorneys, to enjoin violations of the FTC Act and to secure such equitable 

relief as may be appropriate in each case, including rescission or reformation of 

contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten 

monies. 15 U.S.C. §§ 53(b) and 56(a)(2)(A). 

DEFENDANTS 

6. Defendant Nobetes Corporation (“Nobetes”), a/k/a Side Effects 

Solution Corporation (“SES”), is a California corporation with its principal office 

or place of business at 424 S. Beverly Drive, Beverly Hills, CA 90212. Nobetes 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 3 of 21 Page ID #:3 

transacts or has transacted business in this district and throughout the United 

States. 

7. Defendant Marvin Silver (“Silver”) is an officer and director of 

Nobetes. Individually or in concert with others, he controlled or had the authority 

to control the acts and practices of Nobetes, including the acts and practices 

alleged in this complaint. Among other responsibilities, Defendant Silver 

participated in product development, and the development, review, and approval of 

ad content and substantiation of advertising claims. His principal office or place of 

business is the same as that of Nobetes. Defendant Silver resides in this district 

and, in connection with the matters alleged herein, transacts or has transacted 

business in this district and throughout the United States. 

8. Defendant Jeffrey Fleitman (“Fleitman”) is an officer and director of 

Nobetes. Individually or in concert with others, he controlled or had the authority 

to control the acts and practices of Nobetes, including the acts and practices 

alleged in this complaint. Among other responsibilities, Defendant Silver 

participated in product development, and the development, review, and approval of 

ad content and substantiation of advertising claims. His principal office or place of 

business is the same as that of Nobetes. Defendant Fleitman resides in this district 

and, in connection with the matters alleged herein, transacts or has transacted 

business in this district and throughout the United States. 

COMMERCE 

9. At all times material to this Complaint, Defendants have maintained a 

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44. 

BACKGROUND INFORMATION ON DIABETES 

10. Diabetes occurs when a person’s blood glucose, also known as blood 

sugar, is too high. Type 1 and type 2 diabetes are the most common forms of this 

disease. Type 1 diabetes occurs when the immune system destroys the insulin-

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 4 of 21 Page ID #:4 

producing beta cells in the pancreas. Insulin performs the critical job of moving 

glucose from the bloodstream to the body’s cells. With beta cells destroyed, 

glucose builds up in the blood stream. In type 2 diabetes, the body does not make 

or use insulin well. It is caused by many factors, including genetics and lifestyle. 

It typically starts with insulin resistance, where the body needs higher levels of 

insulin to move glucose from the blood stream into the cells. Initially, the pancreas 

increases insulin production to meet demand; over time, however, the pancreas 

cannot make enough insulin, and blood glucose levels rise. As of 2015, 30.3 

million people in the United States (9.4 percent of the population) had diabetes. 

11. Hyperglycemia, that is, having too much glucose in the blood, can 

cause long-term health problems. These include heart disease, stroke, kidney 

disease, eye problems, dental disease, nerve damage, and foot problems. For 

example, hyperglycemia can damage the blood vessels and the nerves that control 

the heart and blood vessels. In adults with diabetes, the most common causes of 

death are heart disease and stroke. Diabetes is also the leading cause of kidney 

disease. Hyperglycemia can damage the blood vessels in the kidneys; as a result, 

the kidneys cannot filter waste efficiently, and waste builds up in the body. About 

one in four diabetic adults has kidney disease. Hyperglycemia can also damage 

nerves in other parts of the body, resulting in vision problems including blindness, 

and adverse changes to digestion, bowel, and bladder function. Diabetes can also 

reduce blood flow in the feet impairing healing of sores, and sometimes requiring 

amputation. Many of the injuries caused by hyperglycemia develop slowly and 

can go undetected until problems become severe. 

12. Blood sugar control is fundamental to diabetes management. For 

diabetics, the target pre-meal blood glucose range is 80 – 130 mg/dL; two hours 

after meals, the glucose level should be less than 180 mg/dL, as measured by a 

blood glucose monitor. Another important measure of blood glucose is 

Hemoglobin A1C (“A1C”), which reveals the average of a person’s blood glucose 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 5 of 21 Page ID #:5 

levels over the past three months, showing how well diabetes is controlled. The 

A1C test result is reported as a percentage. A reasonable A1C goal for many 

diabetic adults is less than seven percent. Studies have shown that people with 

diabetes can reduce the risk of long-term diabetes complications by keeping A1C 

levels below seven percent. 

13. Diabetes can be treated, but it cannot be cured. Type 1 diabetics need 

lifelong insulin therapy to control their blood sugar; must balance insulin intake 

with eating and physical activity; and must continually monitor their glucose 

levels. Some type 2 diabetics can control their blood sugar by losing weight, 

making healthy food choices, and exercising. However, many type 2 diabetics also 

require a diabetes drug treatment, such as insulin. Type 2 diabetes is a progressive 

disease; over time, patients may need multiple medications to control blood sugar. 

DEFENDANTS’ BUSINESS ACTIVITIES 

14. Defendants developed, advertised, labeled, offered for sale, sold, and 

distributed Nobetes, a purported diabetes treatment. Nobetes is a 2,277 mg pill 

containing thirty-six separate ingredients, including vitamins, minerals, and plant 

extracts. 

15. Each bottle of Nobetes contains 30 tablets. Between 2015 and 2018, 

the price of a bottle of Nobetes ranged from $29.95 to $39.95, plus shipping and 

handling, for new customers; and from $15.00, plus shipping and handling, to as 

much as $50.60, for repeat customers. Defendants also have advertised “trial” 

units for $6.95, which they state covers the cost of shipping and handling. 

DEFENDANTS’ ADVERTISING AND MARKETING 

16. To induce consumers to purchase their products, Defendants 

disseminated or caused to be disseminated advertisements and promotional 

materials on television, radio, YouTube, www.nobetes.com (which automatically 

redirects to https://naturalnobetes.myshipify.com), and a Facebook page, including 

but not limited to the attached Exhibits A through C (transcripts) and A1 through 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 6 of 21 Page ID #:6 

C1 (videos). Portions of Exhibits A and B appeared on the Nobetes Facebook page 

between January 2015 and September 2016. Clips from Exhibits A, B, and C 

appeared on the Nobetes website between January 2015 and March 2017. Exhibit 

B appeared on DirectTV and other cable stations between February 2016 and 

September 2016. Exhibit C appeared on DirectTV and other cable stations 

between February 2017 and July 2017. Exhibit C was disseminated after the staffs 

of the FTC and the U.S. Food and Drug Administration sent a Warning Letter on 

September 15, 2016 to Mr. Silver and Side Effects Solutions Corporation d/b/a 

Nobetes Corporation, advising them that “it is unlawful under the FTC Act, 15 

U.S.C. § 41 et seq., to advertise that a product can prevent, treat, or cure human 

disease unless you possess competent and reliable scientific evidence, including, 

when appropriate, well-controlled human clinical studies, substantiating that the 

claims are true at the time they are made.” 

17. Defendants’ advertising and promotional materials have contained the 

following representations or statements, among others: 

A. One-minute video 

* * * 

ANNOUNCER: Did you know that diabetes is the leading cause of 

new blindness, kidney failure and 60 percent of all non-traumatic lower limb 

amputations? Are you waiting for one of these to occur before you take 

action? . . . Attack the problem now and naturally with Nobetes. 

* * * 

KYRSTEN M.: I’m a type 1 diabetic, meaning I’m insulindependent. 

ON SCREEN: Levels 285 [red bar falls from 285 to 115] 115 

Blood sugar levels after only 1 day 

Individual results will vary. 

[phone number] 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 7 of 21 Page ID #:7 

KYRSTEN M.: When I started taking Nobetes, my blood sugar levels 

were up to 285. After only one day of taking Nobetes, my blood sugar 

dropped to 115. Now, I know it seems unbelievable and, quite frankly, 

when I looked down at my glucometer, I was surprised at what I was seeing 

as well. And to anyone who’s skeptical about Nobetes, I would tell you . . . 

[i]t works. 

ON SCREEN: Bob C. actual customer 

Levels 549 [red bar falls from 549 to 84] 84 

Blood sugar levels 

Individual results will vary. 

[phone number] 

BOB C.: My blood sugar was at 549 and in a short period of time, 

I’ve dropped down to 84 to 88 and a half, and I have the blood tests to prove 

it. 

ON SCREEN: 2 Free Bottles 

These statements have not been evaluated by the Food and Drug 

Administration. This product is not intended to diagnose, treat, cure, or 

prevent any disease. 

ANNOUNCER: Get two bottles free. Just pay processing and handling. 

Nobetes, it could change your life forever. To order, call [phone number]. 

– Exhibits A (transcript) and A1 (video), captured 

6/7/2017 

B. First thirty-minute video: 

ANNOUNCER: Is your diabetes out of control? . . . Are your 

numbers ranging from 150 to 550 or more? . . . Are your blood sugar 

numbers dangerously high? . . . You need to try the all-natural dietary 

supplement called Nobetes. . . . Just listen to what other diabetics are saying. 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 8 of 21 Page ID #:8 

KRYSTEN M.: I’m a Type 1 diabetic, meaning I’m insulindependent. . . . When I started taking Nobetes, my blood sugar levels were 

up to 285. After only one day of taking Nobetes, my blood sugar dropped to 

115. 

ON SCREEN: Levels 285 (gradual down arrow) 115 Blood sugar 

levels 

* * * 

ON SCREEN: JD H. Type 2 Diabetic Actual Nobetes customer 

J.D. H.: I used to be a 240. Now it’s at 161. 

ON SCREEN: Levels 240 (gradual down arrow) 161 Blood sugar 

levels 

* * * 

EDDIE J.: Nobetes took me from 280 to 130 within a week. 

ON SCREEN: Levels 280 (gradual down arrow) 130 Blood sugar 

levels 

* * * 

EDDIE J.: And I’m – I was totally impressed because I thought the 

only thing that would cure this situation would be some type of medication 

recommended by a doctor. . . . 

* * * 

EDDIE J.: Don’t get me wrong, my doctor has looked at it, and he 

has endorsed it 100 percent. 

* * * 

GUADALUPE D.: I’m a Type 1 diabetic. . . . And I notice right when 

I took Nobetes the numbers dropped . . . my numbers were 400, 300. Then it 

went – it went down to 200, and now it’s 125 . . . 

* * * 

ON SCREEN: Lance T. Type 2 Diabetic 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 9 of 21 Page ID #:9 

Actual Nobetes customer 

LANCE T.: I’m so grateful for Nobetes . . . . my sugar levels were 

[sic] 227 to 85 in less than ten days. 

ON SCREEN: Levels 227 (gradual down arrow) 85 Blood sugar 

levels 

LANCE T.: At nighttime, I had tingling in my arms and dry mouth 

and even blurry vision. This has all gone away just by taking a pill. 

Nobetes is a natural product. . . . I brought it to the doctor, and he says, if it 

works, use it. And it works for me. I got off my other medications. . . . 

* * * 

LORRAINE B.: It worked. The first pill I took, I could feel a 

difference. I went from 549 to 112 in 24 hours with Nobetes. 

* * * 

ANNOUNCER: Give Nobetes a try and see what this miracle product 

can do for you. . . . Get your bottle free. 

* * * 

ON SCREEN: Free Bottle 

Processing & Handling 

$6.95 

* * * 

ANNOUNCER: Just pay $6.95 processing and handling. Go to 

nobetes.com or call [phone number] right now. 

* * * 

TONY V.: . . . Nobetes is . . . really affordable, and it costs nothing to 

try it. 

* * * 

GUADALUPE D.: Before Nobetes, I was taking insulin for 30 

milligrams in the morning and 30 milligrams in the afternoon. . . . So, now, 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 10 of 21 Page ID #:10 

I’m taking insulin only in the morning, 30 milligrams. 

* * * 

HENRY H.: I’ve been taking Nobetes now for about two years . . . . 

[F]or the first three months, I did it three pills a day, and my blood sugar 

went from a 9.2 down to a 6.5. 

ON SCREEN: Levels 9 (gradual red arrow) 6.5 A1C levels 

HENRY H.: . . . And my doctor recommended it to many of her 

patients, and they’re having success with it. 

* * * 

JOHN R.: . . . I was having problems. My A1Cs were running into 

the high 7s, and I had to do something. . . . Nothing else was working for 

me, and I did not want to do injections, so I tried this product. I dropped my 

A1C from the high 7s to the low 6s. 

ON SCREEN: Levels 7 (gradual red arrow) 6 A1C levels 

JOHN R.: I suggested it to a few friends. . . . The same thing 

happened with them. I suggested it to my mother, who was on two 

injections per day. . . . She started taking it. And then within a month, she 

was down to one injection a day. 

* * * 

TONY V.: You know, I’ve tried a lot of product over the years and 

. . . without no prevail [sic], they didn’t work like Nobetes. . . . Give it a try, 

eat right, exercise, and wean yourself from medication. 

* * * 

BOB C.: . . . [T]his works. This is proven [to] work, and I’ve got the 

blood test to prove it. Nobetes did the job, and its doing the job, and it’s got 

me under control. 

* * * 

DAVID D.: I have my CDL license to drive a truck. . . . That’s my 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 11 of 21 Page ID #:11 

livelihood, and I need to keep my blood sugars a lot lower than, you know, 

what they’ve been. . . . And I’ve been running about 260 to 300, right in that 

range, and Nobetes in a very short time has got my numbers down to where 

they should be, 120. 

ON SCREEN: Levels 300 (gradual red arrow) 120 Blood sugar levels 

* * * 

HENRY H.: . . . everyone that I’ve . . . recommended it to, it’s helped 

them . . . . And the doctor that I go to has recommended it to her patients, 

and she’s told me it’s helped many of them . . . keeping their blood sugars in 

control and in check. 

* * * 

BOB C.: My blood sugar was at 549, and I counseled with my doctor, 

and he told me that he was going to give me the insulin. . . I told him there’s 

no way that I will take insulin through an injectable needle. I said to him, I 

was going to try this new supplement called Nobetes . . . . I was at 549. I’m 

down to 88 and a half. I feel great. I have no side effects, no tingling, no 

sharp pains. My vision’s fine. And before that, I did have sharp pains in my 

feet and my fingers, and now everything is fine. 

* * * 

TONY V.: And I heard about Nobetes . . . . So I called them up, 

ordered it, and almost immediately I start feeling more energy. . . . My 

thought process was not cloudy. You know, I felt – and then when I started 

testing the sugar levels, they dropped significantly. 

– Exhibits B (transcript) and B1 (video), 

captured 8/11/17 

C. Second thirty-minute video 

ANNOUNCER: Is your diabetes out of control? Are your blood 

sugar numbers dangerously high? . . . You need to try the all-natural dietary 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 12 of 21 Page ID #:12 

supplement called Nobetes. Just listen to what other diabetics are saying. 

ON SCREEN: Mitch Darnell, MS, OSM.CTRC 

[Mr. Darnell is standing in front of two diplomas] 

* * * 

MITCH DARNELL: I’m all about natural products that help 

empower your body to heal without any side effects. . . . I was introduced to 

Nobetes. . . . It’s an all-natural dietary supplement that helps control blood 

sugar within normal levels, with the added benefit it leaves you feeling 

better and really contributes to your overall greater health. Nobetes has 35 

supplements in it that can fill the nutrient shortages that diabetes causes. If 

you were to go out and try to buy all of these supplements at $3 to $4 a 

piece, it could cost you $150 or more. Diabetics, this is the miracle product 

you’ve been waiting for, Nobetes. 

* * * 

ANNOUNCER: Give Nobetes a try and see what this miracle product 

can do for you. 

ON SCREEN: Free 

Bottle 

Processing & Handling 

$6.95 

[phone number] 

nobetes.com 

ANNOUNCER: Get your bottle free. Just pay 6.95 processing and 

handling. Go to Nobetes.com or call [phone number] right now. That’s 

[phone number] right now. 

ON SCREEN: Free 

Bottle 

Processing & Handling 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 13 of 21 Page ID #:13 

$6.95 

Includes continuity order, cancel anytime 

30 day money back guarantee 

less S&H 

[phone number] 

nobetes.com 

ANNOUNCER: Go to Nobetes.com or call [phone number] right 

now. 

* * * 

DARYL A.: I’m a truck driver and I actually am a real Nobetes user. 

. . . I take one Nobetes in the morning and I take one Nobetes in the evening, 

about 12 hours apart, and that alone keeps my blood sugar at a normal level. 

. . . 

* * * 

ANNOUNCER: The following are actual Nobetes customers that 

wanted to get the word out and share with you their experience with the 

Nobetes supplement and how it has helped them in their fight against 

diabetes. These are not paid actors. . . . 

* * * 

KRYSTEN M.: When I first began taking Nobetes . . . the stress in 

general just had me up and down with my blood sugar level. So I was 

constantly feeling sick. I started taking Nobetes and my blood sugar levels 

stabilized [at] a normal range. And I just felt great. 

* * * 

BOB C.: Well, when you take meds, you know, there’s always that 

question, is it going to work . . . this works. . . . I’ve got the blood tests to 

prove it. . . . Nobetes did the job and . . . it’s got me under control. . . 

* * * 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 14 of 21 Page ID #:14 

TONY V.: . . . the cost of Nobetes is really affordable and it costs 

nothing to try it. . . . 

* * * 

GUADALUPE D.: Before Nobetes I was taking insulin for 30 

milligrams in the morning and 30 milligrams in the afternoon. . . . So now 

I’m taking insulin only in the morning, 30 milligrams. I’m not taking it at 

nighttime. 

* * * 

TONY V.: . . . Nobetes, you know, it saved – it have [sic] saved me 

from, you know, the high cost of medication. 

* * * 

MITCH DARNELL: [standing in front of diplomas] It’s important to 

take care of yourself, control your blood sugar within normal levels and live 

a healthy, vibrant life, and I believe Nobetes can help you do that. 

ANNOUNCER: Is your diabetes out of control? Are your blood 

sugar numbers dangerously high? . . . Now, you may be able to reverse this. 

You need to try the all-natural dietary supplement called Nobetes. 

* * * 

HENRY H.: . . . And the doctor that I go to has recommended it to 

her patients and she’s told me it’s helped many of them keeping their blood 

sugars in control and in check. 

* * * 

TONY V.: And I heard about Nobetes . . . [s]o I called them up, 

ordered it, and almost immediately I start feeling more energy. My thought 

process was not cloudy. 

* * * 

ROSE A.: . . . And with Nobetes . . . my blood sugars have been in 

normal range for the last two years. . . . I recommend the product to anybody 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 15 of 21 Page ID #:15 

that has diabetes and they can’t get it under control. 

* * * 

JD H.: . . . I don’t want to go blind. I don’t want to go get – go into a 

coma. I don’t want to have a stroke. I want to be around for my kids. . . . . 

Nobetes is changing my life. 

* * * 

EDDIE J.: Nobetes is really terrific for me. I’ve gone to quite a few 

doctors using different types of medications and the fluctuation was just 

drastic. It was just a disaster. And when I did take the Nobetes . . . it 

worked for me. 

* * * 

TONY V.: . . . I strongly urge you to try the product. It's free and you 

won’t regret it. 

* * * 

ROBERT B.: . . . I still eat the same old crap I always did. But once I 

eat all that crap, my sugar will go up. But when I take my Nobetes after 

dinner, by evening, I’m right back where I was when I started. 

* * * 

JOHN S.: . . . My sugar level has been kept at a normal range. 

* * * 

VIRGINIA: . . . [I]f you’re like me and you’re having trouble keeping 

your sugar numbers down . . . I’ve used lots of different products that never 

worked and so I became very discouraged until I got the Nobetes. And 

something is finally working and it’s wonderful. 

* * * 

EDDIE J.: . . . when my numbers were running 280, 270, it was 

pretty scary. To know that they’re down now . . . I love the Nobetes. 

* * * 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 16 of 21 Page ID #:16 

MITCH DARNELL: [standing in front of diplomas] Diabetics, this 

is the miracle product you’ve been waiting for, Nobetes. 

– Exhibits C (transcript) and C1 (video), 

Television and YouTube ad, captured 6/7/2017 

18. According to the instructions in the advertising, consumers can order 

Nobetes by visiting the nobetes.com website, or by calling the number presented 

on the screen. Consumers who visit the website for the purpose of ordering the 

free trial, however, encounter a message directing them that they must telephone 

the company to do so. 

19. In many instances, when consumers call to ask about the product, 

Defendants’ inbound telemarketer makes additional claims for the product. In one 

instance, for example, the telemarketer stated that the “promotion we have today, 

sir, is a natural supplement that will help you regulate the sugar levels in your 

blood.” He then advised that “this product has to be taken one, two, or three times 

a day, depending on how high are your sugar levels right now,” and then asked for 

the caller’s sugar level: “Are you in the 200’s, 300’s?” When the caller responded 

that he was calling for his father, whose numbers were in the “200’s,” the 

telemarketer recommended that his father take Nobetes twice a day, thirty minutes 

before lunch and then an hour after dinner or before going to bed. The 

telemarketer listed many of the product’s ingredients and stated that “altogether, 

these will help . . .with high sugar levels.” 

20. In many instances, when consumers call to ask about the product, the 

Defendants’ inbound telemarketer states that the current promotion is a trial offer 

whereby the consumer will pay $6.95 for shipping and handling for one 30-pill 

bottle of Nobetes. The telemarketer then asks whether the caller would like to pay 

with a “Visa or Master Card?” After receiving the billing information, the 

telemarketer advises the consumer that if the product works, “then you can call us 

back . . . to reorder another bottle.” 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 17 of 21 Page ID #:17 

21. Shortly thereafter, Defendants bill $6.95 to the consumer’s card and 

ship them a 30-pill bottle of Nobetes. 

22. In many instances, one month after Defendants charge the consumer 

for the trial offer, they automatically ship a second 30-pill bottle of product to the 

consumer, and charge $50.60 to the consumer’s credit card. Every month 

thereafter, Defendants ship another 30-pill bottle of product, and charge the 

consumer’s card an additional $50.60, until the consumer takes affirmative action 

to cancel the order and request a refund. 

23. In many instances, Defendants do not advise the trial order callers that 

Defendants will enroll them in a continuity program, and use the consumer’s 

billing information for continuity shipments; do not advise callers how much they 

will be charged for continuity shipments or when such charges will be assessed; 

and do not state what the consumer needs to do to avoid such a charge. At no time 

during the call do Defendants seek or obtain the express, informed consent of the 

consumer to charges for continuity shipments. 

DEFENDANTS’ VIOLATIONS OF THE FTC ACT 

24. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or 

deceptive acts or practices in or affecting commerce.” 

25. Misrepresentations or deceptive omissions of material fact constitute 

deceptive acts or practices prohibited by Section 5(a) of the FTC Act. An act or 

practice is unfair under Section 5 if it causes or is likely to cause substantial injury 

to consumers which is not reasonably avoidable by consumers themselves and not 

outweighed by countervailing benefits to consumers or to competition. 15 U.S.C. 

§ 45(n). 

26. Section 12(a) of the FTC Act, 15 U.S.C. § 52(a), prohibits the 

dissemination of any false advertisement in or affecting commerce for the purpose 

of inducing, or which is likely to induce, the purchase of food, drugs, devices, 

services, or cosmetics. For the purposes of Section 12 of the FTC Act, Nobetes is 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 18 of 21 Page ID #:18 

a “food” or “drug” as “food” and “drug” are defined in Sections 15(b) and (c) of 

the FTC Act, 15 U.S.C. § 55(b) and (c). 

COUNT I: FALSE OR UNSUBSTANTIATED DIABETES CLAIMS 

27. Through the means described in Paragraphs 17 and 19, Defendants 

have represented, directly or indirectly, expressly or by implication, that: 

A. Nobetes treats diabetes; 

B. Nobetes reduces high blood sugar; 

C. Nobetes reduces or eliminates the need for blood sugar 

medications such as insulin; 

D. Nobetes keeps blood sugar within normal levels; and 

E. Nobetes benefits diabetics by replenishing nutrient deficiencies 

caused by diabetes. 

28. The representations set forth in Paragraph 27 are false or misleading, 

or were not substantiated, at the time the representations were made. 

29. Therefore, the making of the representations as set forth in Paragraph 

27 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

COUNT II: FALSE CLAIM REGARDING ENDORSER DARNELL 

30. Through the means described in Paragraph 17, Defendants have 

represented, directly or indirectly, expressly or by implication, that endorser Mitch 

Darnell is a qualified scientific or medical expert in blood sugar regulation and 

diabetes treatment. 

31. In truth and in fact, endorser Mitch Darnell is not a qualified scientific 

or medical expert in blood sugar regulation or diabetes treatment. Mr. Darnell is 

an actor. 

32. Therefore, the making of the representations as set forth in Paragraph 

30 of this Complaint constitutes a deceptive act or practice and the making of false 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 19 of 21 Page ID #:19 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

COUNT III: FAILURE TO DISCLOSE 

MATERIAL CONNECTIONS WITH ENDORSERS 

33. Through the means described in Paragraph 17, Defendants have 

represented, expressly or by implication, that the endorsers appearing in 

advertising recommend Nobetes. 

34. Defendants have failed to disclose that Defendants provided many of 

the endorsers with free product. 

35. This additional information would be material to consumers in their 

evaluation of the endorsements in connection with their purchase or use of 

Nobetes. 

36. Defendants’ failure to disclose the material information described in 

Paragraph 34, in light of the representation made in Paragraph 33, constitutes a 

deceptive act or practice and the making of false advertisements, in or affecting 

commerce, in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) 

and 52. 

COUNT IV: FAILURE TO DISCLOSE 

MATERIAL TERMS OF OFFER 

37. Through the means described in Paragraphs 17 and 20, Defendants 

have represented, directly or indirectly, expressly or by implication, that consumers 

can obtain a “free trial” of Nobetes by paying $6.95 for shipping and handling. 

38. In truth and in fact, in numerous instances in which Defendants have 

made the representation set forth in Paragraph 37, Defendants have failed to 

disclose, or disclose adequately, to consumers, material terms and conditions of 

their offer, including: 

A. That Defendants will automatically enroll consumers in a 

negative option continuity plan with additional charges; 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 20 of 21 Page ID #:20 

B. The cost of the continuity plan, and the frequency and duration 

of the recurring charges; and 

C. The date and the means by which consumers must cancel to 

avoid additional charges. 

39. Defendants’ failure to disclose, or to disclose adequately, the material 

information described in Paragraph 38, in light of the representation made in 

Paragraph 37, constitutes a deceptive act or practice in violation of Section 5(a) of 

the FTC Act, 15 U.S.C. § 45(a). 

COUNT V: UNFAIRLY CHARGING CONSUMERS WITHOUT 

AUTHORIZATION 

40. In numerous instances, Defendants have caused charges to be 

submitted for payment to the credit cards of consumers without the express 

informed consent of consumers. 

41. Defendants’ practices caused or are likely to have caused substantial 

injury to consumers that consumers could not reasonably avoid themselves and that 

is not outweighed by countervailing benefits to consumers or competition. 

42. Therefore, Defendants’ practices as described in Paragraphs 17, 20, 

22, and 23, above, constitute unfair acts or practices in violation of Section 5 of the 

FTC Act, 15 U.S.C. §§ 45(a) and 45(n). 

CONSUMER INJURY 

43. Consumers are likely to have suffered substantial injury as a result of 

Defendants’ violations of the FTC Act. In addition, Defendants have been unjustly 

enriched as a result of their unlawful acts or practices. Absent injunctive relief by 

this Court, Defendants are likely to continue to injure consumers, reap unjust 

enrichment, and harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 

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Case 2:18-cv-10068 Document 1 Filed 12/03/18 Page 21 of 21 Page ID #:21 

ALDEN F. ABBOTT 

General Counsel 

____________________________ 

Janet Evans 

U.S.C. § 53(b), and the Court’s own equitable powers, requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC 

Act by Defendants; 

B. Award such relief as the Court finds necessary to redress injury to 

consumers resulting from Defendants’ violations of the FTC Act, including but not 

limited to, rescission or reformation of contracts, restitution, the refund of monies 

paid, and the disgorgement of ill-gotten monies; and, 

C. Award Plaintiff the costs of bringing this action, as well as such other 

and additional relief as the Court may determine to be just and proper. 

Respectfully submitted, 

Dated: ____________________ December 3, 2018

DC Bar No. 358467; jevans@ftc.gov 

600 Pennsylvania Ave., N.W. 

Mail Drop CC-10528 

Washington, D.C. 20580 

Tel: (202) 326-2125 

Fax: (202) 326-3259 

Robert Quigley (Local Counsel) 

CA Bar No. 302879; rquigley@ftc.gov 

10990 Wilshire Boulevard, Suite 400 

Los Angeles, California 90024 

Tel: (310) 824-4300 

Fax: (310) 824-4380 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

-21-
Case 2:18-cv-10068 Document 1-1 Filed 12/03/18 Page 1 of 3 Page ID #:22 

Exhibit A 
2017.06.07 YouTube - nobetes SD.mp4 

NoBetes 6/7/2017 

Case 2:18-cv-10068 Document 1-1 Filed 12/03/18 Page 2 of 3 Page ID #:23 

OFFICIAL TRANSCRIPT PROCEEDING 

FEDERAL TRADE COMMISSION 

MATTER NO. 1723119 

TITLE NOBETES 

DATE RECORDED: JUNE 7, 2017

TRANSCRIBED: NOVEMBER 20, 2017

REVISED: FEBRUARY 23, 2018 

PAGES 1 THROUGH 7 

NOBETES COMMERCIAL 

2017.06.07 YouTube - nobetes SD.mp4 

For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 

2

1 FEDERAL TRADE COMMISSION 

2 I N D E X 

3

4 RECORDING: PAGE: 

5 Nobetes commercial 4 

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3

1 FEDERAL TRADE COMMISSION 

2

3 In the Matter of: ) 

4 Nobetes ) Matter No. 1723119 

5 ) 

6 ------------------------------) 

7 June 7, 2017 

8

9

10

11 The following transcript was produced from a 

12 digital file provided to For The Record, Inc. on 

13 November 9, 2017. 

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4

1 P R O C E E D I N G S 

2 - - - - -

3 NOBETES COMMERCIAL 

4 ON SCREEN: Are you a diabetic with blood 

5 sugar levels from 200 to 550 or more! 

6 ANNOUNCER: Did you know that diabetes is 

7 the leading cause of new blindness, kidney failure and 

8 60 percent of all non-traumatic lower limb 

9 amputations? Are you waiting for one of these to 

10 occur before you take action? 

11 ON SCREEN: Diabetes is the leading cause of 

12 new blindness, kidney failure, and 60% of all non13 traumatic lower limb amputations! 

14 ON SCREEN: Natural Supplement 

15 ANNOUNCER: Attack the problem now and 

16 naturally with Nobetes. 

17 ON SCREEN: Insulin dependent diabetic 

18 Kyrsten M. 

19 actual customer 

20 1-800-616-1560 

21 KYRSTEN M.: I’m a type 1 diabetic, meaning 

22 I’m insulin-dependent. 

23 ON SCREEN: Levels 285 [red bar falls from 

24 285 to 115] 115 

25 Blood sugar levels 

Complaint Exhibit A

22
7

2017.06.07 YouTube - nobetes SD.mp4 

NoBetes 6/7/2017 

Case 2:18-cv-10068 Document 1-1 Filed 12/03/18 Page 3 of 3 Page ID #:24 

5

 after only 1 day

 Individual results will vary.

1-800-616-1560

KYRSTEN M.: When I started taking Nobetes,

my blood sugar levels were up to 285. After only one

day of taking Nobetes, my blood sugar dropped to 115. 

Now, I know it seems unbelievable and, quite frankly,

when I looked down at my glucometer, I was surprised

at what I was seeing as well. And to anyone who’s

skeptical about Nobetes, I would tell you that it’s a

natural product. It works.

 ON SCREEN: Bob C. 

 actual customer

 Levels 549 [red bar falls from 549 to 84] 84

 Blood sugar levels

 Individual results will vary.

1-800-616-1560

BOB C.: My blood sugar was at 549 and in a

short period of time, I’ve dropped down to 84 to 88

and a half, and I have the blood tests to prove it.

 ON SCREEN: 2 Free Bottles

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure, or prevent any

disease.

6

1-800-616-1560

ANNOUNCER: Get two bottles free. Just pay

processing and handling. Nobetes, it could change

your life forever.

 ON SCREEN: 2 Free Bottles

1-800-616-1560

ANNOUNCER: To order, call 1-800-616-1560.

(The recording was concluded.)

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1 CERTIFICATE OF TRANSCRIPTIONIST

 I, Elizabeth M. Farrell, do hereby certify

that the foregoing proceedings and/or conversations

were transcribed by me via CD, videotape, audiotape or

digital recording, and reduced to typewriting under my

supervision; that I had no role in the recording of

this material; and that it has been transcribed to the

best of my ability given the quality and clarity of

the recording media.

 I further certify that I am neither counsel

for, related to, nor employed by any of the parties to

the action in which these proceedings were

transcribed; and further, that I am not a relative or

employee of any attorney or counsel employed by the

parties hereto, nor financially or otherwise

interested in the outcome of the action.

DATE: 2/23/2018

ELIZABETH M. FARRELL, CERT

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Complaint Exhibit A

 23
Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 1 of 13 Page ID #:25 

Exhibit B 
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 2 of 13 Page ID #:26 

OFFICIAL TRANSCRIPT PROCEEDING 

FEDERAL TRADE COMMISSION 

MATTER NO. 1723119 

TITLE NOBETES CORPORATION 

DATE RECORDED: DATE UNKNOWN 

TRANSCRIBED: DECEMBER 15, 2017

REVISED: FEBRUARY 23, 2018 

PAGES 1 THROUGH 45 

INFOMERCIAL: No Betes..saves lives 

For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 

2

1 FEDERAL TRADE COMMISSION 

2 I N D E X 

3

4 RECORDING: PAGE: 

5 Infomercial: No Betes..saves lives 4 

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3

1 FEDERAL TRADE COMMISSION 

2

3 In the Matter of: ) 

4 Nobetes Corporation ) Matter No. 1723119 

5 ) 

6 ------------------------------) 

7 Date Unknown 

8

9

10

11 The following transcript was produced from a 

12 digital file provided to For The Record, Inc. on 

13 December 11, 2017. 

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4

1 P R O C E E D I N G S 

2 - - - - -

3 INFOMERCIAL: NO BETES..SAVES LIVES 

4 RECORDING: The following is a paid program 

5 brought to you by Nobetes. 

6 On Screen: The following program 

7 is brought to you by NOBETES 

8 ANNOUNCER: Is your diabetes out of control? 

9 On Screen: Is your diabetes out of control? 

10 ANNOUNCER: Are your numbers ranging from 

11 150 to 550 or more? 

12 On Screen: Are your numbers ranging from 

13 150 to 500 or more? 

14 ANNOUNCER: Are your blood sugar numbers 

15 dangerously high? 

16 On Screen: Are your blood sugar numbers 

17 dangerously high? 

18 BREAKING HEALTH NEWS! 

19 ANNOUNCER: Here’s some breaking health 

20 news. 

21 On Screen: Natural Dietary Supplement 

22 ANNOUNCER: You need to try the all-natural 

23 dietary supplement called Nobetes. Just listen to 

24 what other diabetics are saying. 

25 KRYSTEN M.: I’m a Type 1 diabetic, meaning 

Complaint Exhibit B

24
INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 3 of 13 Page ID #:27 

5

I’m insulin-dependent.

 On Screen: Krysten M. Type 1 Diabetic

 Actual Nobetes customer

 KRYSTEN M.: When I started taking Nobetes,

my blood sugar levels were up to 285.

 On Screen: Levels 285 (gradual down arrow)

115 Blood sugar levels

 KRYSTEN M.: After only one day of taking

Nobetes, my blood sugar dropped to 115.

 Now, I know it seems unbelievable. And,

quite frankly, when I looked down at my glucometer, I

was surprised at what I was seeing as well.

 On Screen: Individual Results will vary

 KRYSTEN M.: And to anyone who’s skeptical

about Nobetes, I would tell you that it’s a natural

product, it works, and you have nothing to lose. Give

Nobetes a try.

J.D. H.: I just tested myself on camera.

On Screen: JD H. Type 2 Diabetic

Actual Nobetes customer

J.D. H.: I used to be a 240. Now it’s at

161.

 On Screen: Levels 240 (gradual down arrow)

161 Blood sugar levels

J.D. H.: This is less than a week. I’ve

6

lost eight pounds. I’ve improved my relationship at

home. Nobetes is something you should definitely 

look into if you’re a Type 2 diabetic. Nobetes, I’m

here -- I’m here to stay.

 On Screen: Individual results will vary

J.D. H.: How about you? If you’re a

diabetic, Nobetes is what you should be on.

 On Screen: Eddie J. Type 2 Diabetic

 Actual Nobetes customer

 EDDIE J.: Nobetes took me from 280 to 130

within a week.

 On Screen: Levels 280 (gradual down arrow)

130 Blood sugar levels

 EDDIE J.: I’ve maintained this 130 or lower

with Nobetes on a regular basis, taking it daily and,

of course, consistently. And if you have diabetes,

I’ve got to let you know, you got to give it a try.

It can’t hurt you.

 On Screen: Individual results will vary

 EDDIE J.: It’s not a medication. It’s --

it’s strictly a supplement. And I’m -- I was totally

impressed because 

I thought the only thing that would cure this

situation would be some type of medication recommended

by a doctor.

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7

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease

 EDDIE J.: Don’t get me wrong, my doctor has

looked at it, and he has endorsed it 100 percent.

 GUADALUPE D.: I’m a Type 1 diabetic.

 On Screen: Guadalupe D. Type 1 Diabetic

 Actual Nobetes customer

 GUADALUPE D.: And I start taking Nobetes. 

And I notice right when I took Nobetes the numbers

dropped down shortly.

 On Screen: Individual results will vary

 GUADALUPE D.: So it was -- my numbers were

400, 300.

 On Screen: Levels 400 (gradual down arrow)

125 Blood sugar levels

 GUADALUPE D.: Then it went -- it went down

to 200, and now it’s 125. Excellent.

 On Screen: Bob C. Type 2 Diabetic

 Actual Nobetes customer

 BOB C.: I went down from 549 on blood sugar

count to 88 and a half with using Nobetes, an allnatural supplement.

 On Screen: Levels 549 (gradual down arrow)

8

88 Blood sugar levels

 BOB C.: I can tell you it’s worked better

than any prescribed medicine that I’ve taken.

 On Screen: Individual results will vary

 BOB C.: I can tell you that the results are

great. I have no tingling in my hands, feet, or

joints. And I can tell you I feel 100 percent better. 

Nobetes is the supplement for me.

 LANCE T.: I’m so grateful for Nobetes.

 On Screen: Lance T. Type 2 Diabetic

 Actual Nobetes customer

 LANCE T.: Nobetes from -- my sugar levels

were 227 to 85 in less than ten days.

 On Screen: Levels 227 (gradual down arrow)

85 Blood sugar levels

 LANCE T.: At nighttime, I had tingling in

my arms and dry mouth and even blurry vision. This

has all gone away just by taking a pill. Nobetes is a

natural product.

 On Screen: Individual results will vary

 LANCE T.: I brought it to the doctor, and

he says, if it works, use it. And it works for me. I

got off my other medications, and it’s a great natural

product. You have to try it.

 On Screen: David D. Type 2 Diabetic

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Complaint Exhibit B

 25
INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 4 of 13 Page ID #:28 

9

 Actual Nobetes customer

 “my numbers have dropped dramatically”

 DAVID D.: I started taking the Nobetes, and

my numbers dropped dramatically. It got everything

under control, everything at the doctor. The doctor

was amazed.

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

 DAVID D.: Everything -- everything turned

out real well. My numbers were down a little over

100, 120, right in that range, and the doctors are --

are very impressed. So I’ve done very well.

 On Screen: Individual results will vary

 DAVID D.: You know, it’s one of those

things you’ve got to stick with it. You can’t just

try it for a little while and then you have to take a

couple of them a day. One -- I usually take one in

the morning and one in the evening. They have worked

really well for me. Very happy with the product.

J.D. H. A lot of prescriptions keep you on

-- a lot of the medications you get at the pharmacy

keeps you at the pharmacy.

 On Screen: JD H. Type 2 Diabetic

10

 Actual Nobetes customer

J.D. H.: They’ll give you a medication that

will do this and a medication that will do that. But

these are all supplements.

 On Screen: Individual results will vary

J.D. H.: These help build your body up to a

level where your body works for you. They -- this is

some incred- -- this -- this is unchartered territory. 

We’re in a whole new field here. This is way ahead of

the curve. Get onboard with me. I beg you, get

onboard with me.

 On Screen: This following is a paid program

brought to you by Nobetes

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 BREAKING HEALTH NEWS!

 ANNOUNCER: Here’s some breaking health

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news.

 On Screen: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 KYRSTEN M.: I’m a Type 1 diabetic, meaning

I’m insulin-dependent.

 On Screen: Kyrsten M.

 actual customer

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 Insulin dependent diabetic

 KYRSTEN M.: When I started taking Nobetes,

my blood sugar levels were up to 285.

 On Screen: 1-844-44-55-66-7

 nobetes.com

 KYRSTEN M.: After only one day of taking

Nobetes, my blood sugar dropped to 115.

 On Screen: Levels 285 (gradual down arrow)

115 Blood sugar levels

 after only 1 day

 KYRSTEN M.: Now, I know it seems

unbelievable. And, quite frankly, when I looked down

12

at my glucometer, I was surprised at what I was seeing

as well. And to anyone who’s skeptical about Nobetes,

I would tell you that it’s a natural product, it

works.

 On Screen: Eddie J.

 actual customer

1-844-44-55-66-7

nobetes.com

On Screen: Levels 280 (gradual down arrow)

130 Blood sugar levels

 EDDIE J.: After I took Nobetes, my numbers

went from 280 down to 130 within five to seven days.

And I’ve maintained these numbers, these low numbers,

on a regular basis for about two months now.

 On Screen: Lorraine B.

 actual customer, Louisiana

1-844-44-55-66-7

nobetes.com

Levels 549 (gradual down arrow) 112 Blood

sugar levels

 LORRAINE B.: It worked. The first pill I

took, I could feel a difference. I went from 549 to

112 in 24 hours with Nobetes.

 On Screen: JD H. Type 2 Diabetic

 actual customer

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Complaint Exhibit B

26
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 5 of 13 Page ID #:29 

13

1-844-44-55-66-7

nobetes.com

On Screen: Levels 240 (gradual down arrow)

161 Blood sugar levels

J.D. H.: I just tested myself on camera. I

used to be a 240. Now it’s at 161. This is less than

a week. Nobetes, I’m here -- I’m here to stay.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 On Screen: 1-844-44-55-66-7

 nobetes.com

 ANNOUNCER: Get your bottle free.

 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

 ANNOUNCER: Just pay $6.95 processing and

handling. Go to nobetes.com or call 1-844-44-55-66-7

right now. That’s 1-844-44-55-66-7 right now.

 On Screen: Bob C.

 actual customer

 On Screen: Levels 549 (gradual down arrow)

88 Blood sugar levels

 BOB C.: My blood sugar was at 549, and in a

14

short period of time, I’ve dropped down to 84 to 88

and a half.

 On Screen: Individual results will vary

 BOB C.: And I have the blood test to prove

it.

 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to nobetes.com or call 1-844-

44-55-66-7 right now.

 TONY V.: When you can’t put a price tag on

your health, that’s one thing --

 On Screen: Tony V. Type 2 Diabetic

 Actual Nobetes customer

 These statements have not been evaluated by

the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

 TONY V.: -- and this -- this -- I want to

say it’s a disease, you know, it’s -- it’s serious,

but, you know, a lot of people don’t take it serious. 

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But if you can help yourself, you know, the cost of

Nobetes is -- is really affordable, and it costs

nothing to try it.

 On Screen: Individual results will vary

 1-(844) 44-55-66-7

 nobetes.com

 TONY V.: So you don’t have to take my word. 

Request a bottle and try it for yourself. But, again,

there’s no price tag on good health.

 On Screen: Guadalupe D. Type 1 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

 GUADALUPE D.: Before Nobetes, I was taking

insulin for 30 milligrams in the morning and 30

milligrams in the afternoon.

 On Screen: Individual results will vary

 GUADALUPE D.: So, now, I’m taking insulin

only in the morning, 30 milligrams. And I take in

nighttime.

 On Screen: Henry H. Type 2 Diabetic

 Actual Nobetes customer

 “took the risk and it worked”

 1-(844) 44-55-66-7

 nobetes.com

16

 HENRY H.: I’ve been taking Nobetes now for

about two years. I wanted to call in and -- and give

a reference for it because I’m very pleased with it. 

Started out with hearing about it on the radio. You

know, you -- if you’re like me, you’ve heard a lot of

things on TV in advertisements and on the radio and

you aren’t sure.

 On Screen: Individual results will vary

 HENRY H.: And I wasn’t sure, but I figured

you just -- you -- you step out there and you take

that risk. And so it’s a little bit of -- of money to

get started, but if it doesn’t work, well, done that,

been there, and you’re on to the next thing. But it

did work, and I was amazed at how well it did work.

 Before I took it, I took the bottles in to

my doctor. She got with the nutritionist there, and

they looked it all over and they didn’t see any reason

why I couldn’t take it, so I started on it, and I

started at three pills a day, and then -- then I

backed it off after three months. But for the first

three months, I did it three pills a day, and my blood

sugar went from a 9.2 down to a 6.5.

 On Screen: Levels 9 (gradual down arrow)

6.5 A1C levels

 HENRY H.: And that’s the only thing I did

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Complaint Exhibit B

27
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 6 of 13 Page ID #:30 

17

different. I’m 60 years old. I don’t exercise. The

product works well. It works well for me. And my

doctor recommended it to many of her patients, and

they’re having success with it. She’s told me that. 

And I was backed off of taking it for a little bit. I

was only taking two a day. I had -- was eating more

candy, and my blood sugar had gotten itself up there

to 9.5 on the A1C, so again I went back to three pills

a day. I backed off a little on the candy -- not a

lot, but a little, and I’m down to 6.2 now.

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 ANNOUNCER: Now you may be able to reverse

this.

 On Screen: Natural dietary supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes.

18

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 ANNOUNCER: The following are actual Nobetes

customers that wanted to get the word out and share

with you their experience with the Nobetes supplement

and how it has helped them in their fight against

diabetes. These are not paid actors. These are

actual customers.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 Eddie J. Type 2 Diabetic

 Actual Nobetes customer

 EDDIE J.: If you were my daughter and you

had diabetes and you were skeptical, the first thing I

would tell you to do is take the bottle I have here

that has all the ingredients, the nutrients,

everything that’s in this bottle, and take it to your

doctor. Let him look this over completely. Let him

endorse it. Don’t even touch it until he endorses it.

 Believe me, you’ll thank me. You will keep

taking it on a regular basis because Nobetes really

does work.

 On Screen: Individual results will vary

 EDDIE J.: It’s not a drug, and that’s

fantastic. No side effects. That’s fantastic. 

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That’s what I would tell my daughter. It’s -- it’s up

to you. You have to want to do it yourself. It’s

just not something you can just lay down in bed and

hope it works. You’ve got to put an effort into it. 

You have to make it happen for yourself. And Nobetes

will help, it really will.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 Krysten M. Type 1 Diabetic

 Actual Nobetes customer

 KRYSTEN M.: They have a natural insulin

response. Now, if you’re diabetic, you have problems

with your insulin. For Type 1 diabetics, you have

absolutely no insulin in your body, so you must inject

insulin. Insulin is obviously required to live. 

Otherwise, you cannot use any of the sugar in your

body, and sugar is necessary.

 Type 2 diabetics, there can be a couple

problems. Their insulin can either be working

inefficiently or in maybe that they don’t have enough

insulin.

 On Screen: This following is a paid program

brought to you by Nobetes

 KRYSTEN M.: So Type 2 diabetics may also be

insulin-dependent, depending on what type of issue

20

they have. But for Type 1 diabetics, you must take

insulin because your body does not have any.

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 BREAKING HEALTH NEWS!

 ANNOUNCER: Here’s some breaking health

news.

 On Screen: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 On Screen: Kyrsten M.

 actual customer

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

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Complaint Exhibit B

28
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 7 of 13 Page ID #:31 

21

 KYRSTEN M.: I’m a Type 1 diabetic, meaning

I’m insulin-dependent. When I started taking Nobetes,

my blood sugar levels were up to 285.

 Insulin dependent diabetic

 KYRSTEN M.: After only one day of taking

Nobetes, my blood sugar dropped to 115.

 On Screen: Levels 285 (gradual down arrow)

115 Blood sugar levels

 KYRSTEN M.: Now, I know it seems

unbelievable. And, quite frankly, when I looked down

at my glucometer, I was surprised at what I was seeing

as well.

 On Screen: Individual results will vary

 KYRSTEN M.: And to anyone who’s skeptical

about Nobetes, I would tell you that it’s a natural

product, it works.

 On Screen: Eddie J.

 actual customer

1-844-44-55-66-7

nobetes.com

Levels 280 (gradual down arrow) 130 Blood

sugar levels

 EDDIE J.: After I took Nobetes, my numbers

went from 280 down to 130 within five to seven days.

And I’ve maintained these numbers, these low numbers,

22

on a regular basis for about two months now.

 On Screen: Lorraine B.

 actual customer, Louisiana

1-844-44-55-66-7

nobetes.com

Levels 549 (gradual down arrow) 112 Blood

sugar levels

 LORRAINE B.: It worked. The first pill I

took, I could feel a difference. I went from 549 to

112 in 24 hours with Nobetes.

 On Screen: JD H. Type 2 Diabetic

 actual customer

1-844-44-55-66-7

nobetes.com

J.D. H.: I just tested myself on camera.

On Screen: Levels 280 (gradual down arrow)

161 Blood sugar levels

J.D. H.: I used to be a 240. Now it’s at

161. This is less than a week. Nobetes, I’m here --

I’m here to stay.

 On Screen: 1-844-44-55-66-7

 nobetes.com

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you. Get your bottle

free.

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 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

 ANNOUNCER: Just pay $6.95 processing and

handling. Go to nobetes.com or call 1-844-44-55-66-7

right now. That’s 1-844-44-55-66-7 right now.

 On Screen: Bob C.

 actual customer

1-844-44-55-66-7

nobetes.com

Levels 549 (gradual down arrow) 84 Blood

sugar levels

 BOB C.: My blood sugar was at 549, and in a

short period of time, I’ve dropped down to 84 to 88

and a half --

 On Screen: Individual results will vary

 BOB C.: -- and I have the blood test to

prove it.

 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

24

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to nobetes.com or call 1-844-

44-55-66-7 right now.

 On Screen: John R. Type 2 Diabetic

 Actual Nobetes customer

 “been using Nobetes for 2 years”

 JOHN R.: My name’s John. I’m from

Pennsylvania, and I am an actual user of Nobetes for

over two years. I heard a radio advertisement for the

product. I was having problems. My A1Cs were running

into the high 7s, and I had to do something.

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

 JOHN R.: Nothing else was working for me,

and I did not want to do injections, so I tried this

product. I dropped my A1C from the high 7s to the low

6s.

 On Screen: Levels 7 (gradual down arrow) 6

A1C levels

 JOHN R.: I suggested it to a few friends. 

They were in the same situation I was. The same thing

happened with them. I suggested it to my mother, who

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Complaint Exhibit B

29
INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 8 of 13 Page ID #:32 

25

was on two injections per day.

 On Screen: Individual results will vary

 JOHN R.: She started taking it. And then

within a month, she was down to one injection a day.

I highly recommend this. It’s a fantastic product and

keeps you healthy. So my suggestion is just do it and

take it. Thank you.

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 ANNOUNCER: Now you may be able to reverse

this.

 On Screen: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes.

 The following are actual Nobetes customers

that wanted to get the word out and share with you

their experience with the Nobetes supplement and how

26

it has helped them in their fight against diabetes.

These are not paid actors. These are actual

customers.

 EDDIE J.: The one thing that I really love

about Nobetes, it’s the safe way to go.

 On Screen: Eddie J. Type 2 Diabetic

 Actual Nobetes customer

 EDDIE. J.: It -- it isn’t like you got to

wonder am I taking something that’s going to knock me

out, make me groggy --

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 EDDIE J.: -- can’t drive a car, worry about

whether I’m going to get dizzy or any -- any of those

type of -- of problems that you get with the side

effects of other types of medicine, because we’re all

different and, you know, we all react to everything

differently.

 On Screen: Individual results will vary

 EDDIE J.: Now, you know, maybe it won’t

work for some people, but I’ll tell you one thing, I’m

a big guy. I’m almost 300 pounds, and when my numbers

were running at 280, 270, it was pretty scary. To

know that they’re down now --

 On Screen: Individual results will vary

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 EDDIE J.: -- at least I got a fighting

chance. And I love the Nobetes.

 On Screen: Guadalupe D. Type 1 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

 GUADALUPE D.: No, I don’t -- I’m not aware

of side effects because Nobetes is like vitamins --

 On Screen: Individual results will vary

 GUADALUPE D.: -- you know, taking vitamins

and no side effects at all.

 On Screen: Tony V. Type 2 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

 TONY V.: You know, I’ve tried a lot of

product over the years and, you know, I -- you know,

without no prevail, they didn’t work like Nobetes.

 On Screen: Individual results will vary

 TONY V.: I would urge people who are

diagnosed with Type 2 diabetes to at least give it a

try. Give it a try, eat right, exercise, and wean

yourself from medication.

 On Screen: Bob C. Type 2 Diabetic

 Actual Nobetes customer

28

 1-(844) 44-55-66-7

 nobetes.com

 BOB C.: Well, when you take meds, you know,

there’s always that question, is it going to work, is

it not going to work.

 On Screen: Individual results will vary

 BOB C.: The question that I have for you is

-- or the answer I have is this works. This is proven

work, and I’ve got the blood test to prove it.

Nobetes did the job, and it’s doing the job, and it’s

got me under control.

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

 BOB C.: I lost 48 pounds on special diets,

and I feel great.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

J.D. H.: I just tested myself on camera.

On Screen: Levels 240 (gradual down arrow)

161 Blood sugar levels

 JD H. Type 2 Diabetic

 Actual Nobetes customer

J.D. H.: I used to be a 240. Now it’s at

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Complaint Exhibit B

30
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 9 of 13 Page ID #:33 

29

161. This is less than a week. I’ve lost eight

pounds. I’ve improved my relationship at home.

 On Screen: Individual results will vary

J.D. H.: Nobetes is something you should

definitely look into if you’re a Type 2 diabetic. 

Nobetes, I’m here -- I’m here to stay. How about you?

 On Screen: This following is a paid program

brought to by Nobetes [sic]

J.D. H.: If you’re a diabetic, Nobetes is

what you should be on.

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 FEMALE ANNOUNCER: Diabetics can have a hard

time avoiding many of their favorite foods. The

temptation to eat desserts and other high-carb, sugary

foods is almost impossible to overcome all the time. 

Our customers are thankful they have Nobetes,

30

especially at those times when they fall victim to

temptation.

 This is the miracle natural product you have

been waiting for. Give Nobetes a try. Call now for

your free trial.

 On Screen: David D. Type 2 Diabetic

 Actual Nobetes customer

 “Nobetes has helped me keep my profession”

 DAVID D.: My name is David Dahlberg

(phonetic). I live in Maine. I -- I’m a over-theroad truck driver, and I’ve been using Nobetes for

quite a while now, and it’s done wonders for me.

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

 DAVID D.: I have my CDL license to drive a

truck.

 On Screen: Individual results will vary

 DAVID D.: That’s my livelihood, and I need

to keep my blood sugars a lot lower than, you know,

what they’ve been.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 DAVID D.: And I’ve been running about 260

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to 300, right in that range, and Nobetes in a very

short time has got my numbers down to where they

should be, 120.

 On Screen: Levels 300 (gradual down arrow)

120 Blood sugar levels

_________________

 1-(844) 44-55-66-7

 nobetes.com

 TONY V.: I’m a life insurance agent, and a

lot of my clients are -- you know, they have health

issues.

 On Screen: Tony V. Type 2 Diabetic

 Actual Nobetes customer

 TONY V.: It’s either high blood pressure,

diabetes, or whatever, and so that in itself, you

know, is all the more reason why you should try to do

it naturally --

 On Screen: Individual results will vary

 TONY V.: -- but Nobetes, you know, it saved

-- it saved me from, you know, the high cost of

medication.

 On Screen: Krysten M. Type 1 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

32

 KRYSTEN M.: When I first began taking

Nobetes, I was a student at the university, it was a

very stressful environment, and I was working, and I

was doing a lot of studying. And the stress in

general just had me up and down with my blood sugar

level, so I was constantly feeling sick.

 On Screen: Individual results will vary

 KRYSTEN M.: I started taking Nobetes, and

my blood sugar label -- levels stabilized at a normal

range. And I just felt great.

 On Screen: Henry H. Type 2 Diabetic

 Actual Nobetes customer

 “took the risk and it worked”

 1-(844) 44-55-66-7

 nobetes.com

 HENRY H.: The thing that I would like

people to do is to try it. Try it with an open mind

and see if it helps you because everyone that I’ve

talked to that I’ve recommended it to, it’s helped

them.

 On Screen: Individual results will vary

 HENRY H.: And the doctor that I go to has

recommended it to her patients, and she’s told me it’s

helped many of them, you know, keeping their blood

sugars in control and in check.

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Complaint Exhibit B

31
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 10 of 13 Page ID #:34 

33

 On Screen: Levels 9 (gradual down arrow) 6

A1C levels

 HENRY H.: So step out there and take the

risk and see if it helps you because I can’t imagine

it not helping you.

 On Screen: 1-(844) 44-55-6607

 nobetes.com

 BOB C.: My blood sugar was at 549, and I

counseled with my doctor, and he told me that he was

going to give me the insulin.

 On Screen: Individual results will vary

 BOB C.: And I told him there’s no way that

I will take insulin through an injectable needle. I

said to him, I was going to try this new supplement

called Nobetes, and I can’t tell you any more than it

works.

 On Screen: Levels 549 (gradual down arrow)

88 Blood sugar levels

 BOB C.: I was at 549. I’m down to 88 and a

half. I feel great. I have no side effects, no

tingling, no sharp pains. My vision’s fine. And

before that, I did have sharp pains in my feet and my

fingers, and now everything is fine. I can tell you

it’s an all-natural supplement. I would stand behind

it.

34

 On Screen: Eddie J. Type 2 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

 EDDIE J.: I couldn’t believe that my

numbers were dropping like they were because I thought

the machine was broken. I thought that the batteries

were low. I checked everything. I even got another

machine, truth be known -- the truth.

 On Screen: Individual results will vary

 EDDIE J.: And -- but it just kept working

and working, and it just -- consistently. And I got

to tell you the truth, I wouldn’t sit here and BS you. 

I’m just not that kind of person. I would not do this

to -- to -- unless it was the truth, because I only

tell the truth. I’m that type of person. And the

Nobetes does work.

 On Screen: Tony V. Type 2 Diabetic

 Actual Nobetes customer

 1-(844) 44-55-66-7

 nobetes.com

 TONY V.: And I heard about Nobetes, and

they offered a money-back guarantee if it didn’t work,

so what did I have to lose? So I called them up,

ordered it, and almost immediately I start feeling

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more energy.

 On Screen: Individual results will vary

 TONY V.: My thought process was not cloudy. 

You know, I felt -- and then when I started testing

the sugar levels, they dropped significantly. But

it’s all about diet and exercise as well. I -- I

wouldn’t be sitting here, you know, you know, giving

this testimony if it didn’t work.

 On Screen: JD H. Type 2 Diabetic

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

J.D. H.: I’m very passionate about this

product. I don’t want to go blind. I don’t want to

go get -- go into a coma. I don’t want to have a

stroke. I want to be around for my kids.

 On Screen: Individual results will vary

J.D. H.: So it’s important not only to me,

but it’s important that I share this message with you. 

Nobetes is changing my life. And you should hop

onboard.

 ANNOUNCER: Is your diabetes out of control?

 On Screen: Is your diabetes out of control?

 ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

36

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 ANNOUNCER: Now you may be able to reverse

this.

 On Screen: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes.

 On Screen: John R. Type 2 Diabetic

 Actual Nobetes customer

 “its all natural with absolutley [sic] no

side effects”

 1-(844) 44-55-66-7

 nobetes.com

 JOHN R.: Yes, one of the things that I

really like about Nobetes is that it’s all-natural.

There’s no side effects, no jitters, no anything about

it, absolutely no side effects whatsoever.

 On Screen: Individual results will vary

 JOHN R.: And my doctor, I -- after I

finally confessed to him and he looked at it --

 On Screen: Levels 7 (gradual down arrow) 6

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Complaint Exhibit B

32
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 11 of 13 Page ID #:35 

37

A1C levels

 JOHN R.: -- he’s like, yeah, okay, if it’s

working and these things are working for you, go ahead

and take them. I said, okay, Doc, I will continue

taking them, trust me.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 LANCE T.: If you’re a diabetic and your

sugar levels are out of control, you have to try this

natural product called Nobetes.

 On Screen: Individual results will vary

 Levels 227 (gradual down arrow) 85 Blood

sugar levels

 LANCE T.: It brought my sugar levels down

to 85 in less than ten days. It’s a natural product. 

It’s a great product. I recommend it to any diabetic.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 EDDIE J.: I went from a blood sugar count

of 280 to 130 within five to seven days. Nobetes is

really terrific for me. I’ve gone to quite a few

doctors using different kinds of medications, and the

fluctuation was just drastic, it was just a disaster.

 And when I did take the Nobetes, I -- of

course I was skeptical, but I must say that it works

38

for me, it’s terrific.

 On Screen: Levels 280 (gradual down arrow)

130 Blood sugar levels

 EDDIE J.: And -- and if you have diabetes,

you have to try this Nobetes.

 On Screen: Individual results will vary

 EDDIE J.: It is a supplement; it’s not a

drug. You don’t have to worry about dizzy spells,

driving, going places, any anxiety. This product is

terrific, and I endorse it 100 percent. Try the

Nobetes. It is really super.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

 TONY V.: I’m Tony. I’m an actual customer

of Nobetes.

 On Screen: Individual results will vary

 TONY V.: I am a Type 2 diabetic. I

strongly urge you to try the product. It’s free, and

you won’t regret it.

 On Screen: Individual results will vary

 1-(844) 44-55-66-7

 nobetes.com

 GUADALUPE D.: I have been taking the

Nobetes for two years. And I noticed the -- the

number had dropped.

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 On Screen: Levels 400 (gradual down arrow)

125 Blood sugar levels

 GUADALUPE D.: Before it was 450, and now

it’s about 125. Excellent. Nobetes is perfect.

 On Screen: 1-(844) 44-55-66-7

 nobetes.com

J.D. H.: I went from a 240 to a 110.

On Screen: Levels 240 (gradual down arrow)

110 Blood sugar levels

J.D. H.: 240 to 110. I’ve lost eight

pounds.

 On Screen: These statements have not been

evaluated by the Food and Drug Administration

 This product is not intended to diagnose,

treat, cure or prevent any disease.

J.D. H.: I have more energy to play with my

kids. I have a beautiful wife that loves that I’m

taking care of myself.

 On Screen: This following is a paid program

brought to by Nobetes [sic]

J.D. H.: And I’m going to be here.

ANNOUNCER: Is your diabetes out of control?

On Screen: Is your diabetes out of control?

ANNOUNCER: Are your numbers ranging from

150 to 550 or more?

40

 On Screen: Are your numbers ranging from

150 to 500 or more?

 ANNOUNCER: Are your blood sugar numbers

dangerously high?

 On Screen: Are your blood sugar numbers

dangerously high?

 BREAKING HEALTH NEWS!

 ANNOUNCER: Here’s some breaking health

news.

 On Screen: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 On Screen: Kyrsten M.

 actual customer

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 Insulin dependent diabetic

 KYRSTEN M.: I’m a Type 1 diabetic, meaning

I’m insulin-dependent. When I started taking Nobetes,

my blood sugar levels were up to 285. After only one

day of taking Nobetes, my blood sugar dropped to 115.

 On Screen: Levels 285 (gradual down arrow)

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Complaint Exhibit B

33
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 12 of 13 Page ID #:36 

41

115 Blood sugar levels

 KYRSTEN M.: Now, I know it seems

unbelievable. And, quite frankly, when I looked down

at my glucometer, I was surprised at what I was seeing

as well.

 On Screen: after only 1 day

 KYRSTEN M.: And to anyone who’s skeptical

about Nobetes --

 On Screen: Individual results will vary

 KYRSTEN M.: -- I would tell you that it’s a

natural product, it works.

 On Screen: Eddie J.

 actual customer

1-844-44-55-66-7

nobetes.com

On Screen: Levels 280 (gradual down arrow)

130 Blood sugar levels

 EDDIE J.: After I took Nobetes, my numbers

went from 280 down to 130 within five to seven days.

 On Screen: Individual results will vary

 EDDIE J.: And I’ve maintained these

numbers, these low numbers, on a regular basis for

about two months now.

 On Screen: Lorraine B.

 actual customer, Louisiana

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1-844-44-55-66-7

nobetes.com

Levels 549 (gradual down arrow) 112 Blood

sugar levels

 LORRAINE B.: It worked. The first pill I

took, I could feel a difference. I went from 549 to

112 in 24 hours with Nobetes.

 On Screen: Individual results will vary

 ________________________

 On Screen: JD H. Type 2 Diabetic

 actual customer

1-844-44-55-66-7

nobetes.com

J.D. H.: I just tested myself on camera.

On Screen: Levels 240 (gradual down arrow)

161 Blood sugar levels

J.D. H.: I used to be a 240. Now it’s at

161. This is less than a week. Nobetes, I’m here --

I’m here to stay.

 On Screen: Individual results will vary

 On Screen: 1-844-44-55-66-7

 nobetes.com

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you. Get your bottle

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free.

 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

 ANNOUNCER: Just pay $6.95 processing and

handling. Go to nobetes.com or call 1-844-44-55-66-7

right now. That’s 1-844-44-55-66-7 right now.

 On Screen: Bob C.

 actual customer

1-844-44-55-66-7

nobetes.com

On Screen: Levels 549 (gradual down arrow)

84 Blood sugar levels

 BOB C.: My blood sugar was at 549 --

 On Screen: Individual results will vary

 BOB C.: -- and in a short period of time,

I’ve dropped down to 84 to 88 and a half, and I have

the blood test to prove it.

 On Screen: Free Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

 less S&H

44

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to nobetes.com or call 1-844-

44-55-66-7 right now.

 (Fine print; disclaimer and liability

determinations, two screens.)

 RECORDING: The preceding program was

brought to you by Nobetes.

 On Screen: The preceding program was

brought to you by NOBETES

 nobetes.com

 RECORDING: Just remember, Nobetes.com.

That’s Nobetes.com.

 (The recording was concluded.)

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Complaint Exhibit B

 34
 

INFOMERCIAL: No Betes..saves lives 

NoBetes 12/15/2017 

Case 2:18-cv-10068 Document 1-2 Filed 12/03/18 Page 13 of 13 Page ID #:37 

45

 CERTIFICATE OF TRANSCRIPTIONIST

 I, Sara J. Vance, do hereby certify that the

foregoing proceedings and/or conversations were

transcribed by me via CD, videotape, audiotape or

digital recording, and reduced to typewriting under my

supervision; that I had no role in the recording of

this material; and that it has been transcribed to the

best of my ability given the quality and clarity of

the recording media.

 I further certify that I am neither counsel

for, related to, nor employed by any of the parties to

the action in which these proceedings were

transcribed; and further, that I am not a relative or

employee of any attorney or counsel employed by the

parties hereto, nor financially or otherwise

interested in the outcome of the action.

DATE: 2/23/2018

SARA J. VANCE, CERT

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Complaint Exhibit B

35
Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 1 of 14 Page ID #:38 

Exhibit C 
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 2 of 14 Page ID #:39 

OFFICIAL TRANSCRIPT PROCEEDING 

FEDERAL TRADE COMMISSION 

MATTER NO. 1723119 

TITLE NOBETES 

DATE RECORDED: JANUARY 3, 2017 

TRANSCRIBED: NOVEMBER 20, 2017

REVISED: FEBRUARY 28, 2018

PAGES 1 THROUGH 51 

NOBETES INFOMERCIAL 

YouTube Video NB_28:30 1-3-17 

For The Record, Inc.

(301) 870-8025 - www.ftrinc.net - (800) 921-5555 

2

1 FEDERAL TRADE COMMISSION 

2 I N D E X 

3

4 RECORDING: PAGE: 

5 Nobetes Infomercial 4 

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3

1 FEDERAL TRADE COMMISSION 

2

3 In the Matter of: ) 

4 Nobetes ) Matter No. 1723119 

5 ) 

6 ------------------------------) 

7 January 3, 2017 

8

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11 The following transcript was produced from a 

12 digital file provided to For The Record, Inc. on 

13 November 9, 2017. 

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4

1 P R O C E E D I N G S 

2 - - - - -

3 NOBETES INFOMERCIAL 

4 ON SCREEN: The following program is brought 

5 to you by Nobetes. 

6 ANNOUNCER: The following is a paid program 

7 brought to you by Nobetes. 

8 ANNOUNCER: Is your diabetes out of control? 

9 Are your blood sugar numbers dangerously high? 

10 ON SCREEN: Natural Dietary Supplement 

11 ANNOUNCER: You need to try the all-natural 

12 dietary supplement called Nobetes. Just listen to 

13 what other diabetics are saying. 

14 ON SCREEN: Mitch Darnell, MS, OSM.CTRC 

15 1-844-44-55-66-7 

16 nobetes.com 

17 MITCH DARNELL: I'm all about natural 

18 products that help empower your body to heal without 

19 any side effects. 

20 ON SCREEN: Natural Dietary Supplement 

21 MITCH DARNELL: I was introduced to Nobetes. 

22 ON SCREEN: Mitch Darnell, MS, OSM.CTRC 

23 1-844-44-55-66-7 

24 nobetes.com 

25 MITCH DARNELL: It's an all-natural dietary 

Complaint Exhibit C

36
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 3 of 14 Page ID #:40 

5

supplement that helps control blood sugar within

normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

fill the nutrient shortages that diabetes causes. If

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

6

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now. 

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes continuity order, cancel any time

 30 day money back guarantee 

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 ON SCREEN: Daryl A. 

 Actual Nobetes customer

 “If you use the stuff, it works very very

well”

 DARYL A.: I'm a truck driver and I actually

am a real Nobetes user. I've been using it for almost

a year now. I take one Nobetes in the morning and I

take one Nobetes in the evening, about 12 hours apart,

and that alone keeps my blood sugar at a normal level.

(Inaudible) can't figure this stuff out, but I tell

you, it works. 

7

 You know, you're always skeptical when you

hear about something on the radio when it comes to

your health. But I'm telling you, if you use the

stuff, it actually works and it works very well and I

would recommend it to anybody and everybody.

 ANNOUNCER: Diabetics can have a hard time

avoiding many of their favorite foods. The temptation

to eat desserts and other high-carb sugary foods is

almost impossible to overcome all of the time. Our

customers are thankful they have Nobetes, especially

those times when they fall victim to temptation. 

 This is the miracle natural product you have

been waiting for. Give Nobetes a try. Call now for

your free trial.

 ANNOUNCER: The following are actual Nobetes

customers that wanted to get the word out and share

with you their experience with the Nobetes supplement

and how it has helped them in their fight against

diabetes. These are not paid actors. These are

actual customers.

 ON SCREEN: Eddie J.

 Actual Nobetes customer

 EDDIE J.: I'm a big guy and I take Nobetes

and I'll tell you --

 ON SCREEN: Eddie J.

8

 Actual Nobetes customer

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 EDDIE J.: -- if I was looking for anything

to change my lifestyle, it sure was Nobetes because,

now, when I go to a birthday party, I can have a

little piece of cake. And I don't go overboard, but I

endorse Nobetes 100 percent.

 ON SCREEN: Tony V.

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

TONY V.: You know, I’ve tried a lot of

product over the years and, you know, I -- you know,

without no prevail, they didn't work like Nobetes. I

would urge people who are diagnosed with type 2

diabetes to at least give it a try. Give it a try,

eat right, exercise, and wean yourself from

medication.

 ON SCREEN: Krysten M. 

 Actual Nobetes customer

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Complaint Exhibit C

37
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 4 of 14 Page ID #:41 

9

1-844-44-55-66-7

nobetes.com

KRYSTEN M.: When I first began taking

Nobetes, I was a student at the university. It was a

very stressful environment. I was working and I was

doing a lot of studying. And the stress in general

just had me up and down with my blood sugar level. So

I was constantly feeling sick. I started taking

Nobetes and my blood sugar levels stabilized a normal

range. And I just felt great.

 ON SCREEN: Bob C. 

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

BOB C.: Well, when you take meds, you know,

there's always that question, is it going to work, is

it not going to work. The question that I have for

you is -- or the answer I have is this works. This is

proven to work and I've got the blood tests to prove

it. 

 Nobetes did the job and it's doing the job

and it's got me under control. I lost 48 pounds on

special diets and I feel great.

10

 ON SCREEN: Lance T.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

LANCE T.: I really don't believe it. I

thought maybe my meter was wrong or something. But I

went to the doctor and he tested me, too, and it's

unreal. This product works. It really does. I mean,

you can't go out and eat pizza and have apple pie and

not exercise. I mean, you have to exercise and watch

your diet. I mean, I've taken flour and sugar out of

my diet and it's worked for me. But you -- if you

take Nobetes, try it, you'll like it.

 ON SCREEN: 1-844-44-55-66-7

 nobetes.com

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Now you may be able to reverse

this. You need to try the all-natural dietary

supplement called Nobetes. 

 ON SCREEN: Tony V.

 Actual Nobetes customer

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 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

TONY V.: You can't put a price tag on your

health, that's one thing and this -- I want to say

it's a disease, you know, it's serious. But, you

know, a lot of people don't take it serious. But if

you could help yourself, you know, the cost of Nobetes

is really affordable and it costs nothing to try it. 

So you don't have to take my word. Request a bottle

and try it for yourself. But, again, there's no price

tag on good health.

 ON SCREEN: Guadalupe D.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

GUADALUPE D.: Before Nobetes I was taking

insulin for 30 milligrams in the morning and 30

milligrams in the afternoon. 

 ON SCREEN: Guadalupe D.

 Actual Nobetes customer

 This following is a paid program brought to

by Nobetes

 GUADALUPE D.: So now I'm taking insulin

12

only in the morning, 30 milligrams. I'm not taking it

at nighttime. 

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: I'm all about natural

products that help empower your body to heal without

any side effects. 

 ON SCREEN: Natural Dietary Supplement 

 MITCH DARNELL: I was introduced to Nobetes. 

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: It's an all-natural dietary

supplement that helps control blood sugar within

normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

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Complaint Exhibit C

38
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 5 of 14 Page ID #:42 

Complaint Exhibit C

39

13

fill the nutrient shortages that diabetes causes. If

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes Continuity order, cancel anytime

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now.

 ON SCREEN: Free 

14

 Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 ON SCREEN: David D.

 Actual Nobetes customer

 “Nobetes has helped me keep my profession.”

1-844-44-55-66-7

nobetes.com

DAVID DOLBERT: My name is David Dolbert. I

live in Maine. I -- I'm an over-the-road truck driver

and I've been using Nobetes for quite a while now and

it's done wonders for me. I have my CDL license to

drive a truck. That's my livelihood. And I need to

keep my blood sugars a lot lower than, you know, what

they've been. Nobetes, in a very short time, has got

my numbers to where they should be.

 ON SCREEN: Eddie J.

 Actual Nobetes customer

1-844-44-55-66-7

15

 nobetes.com

 EDDIE J.: Nobetes really does work. It's

not a drug and that's fantastic. No side effects. 

That's fantastic. That's what I would tell my

daughter. 

 It's up to you. You have to want to do it

yourself. It's just not something you can just lay

down in bed and hope it works. You got to put an

effort into it. You have to make it happen for

yourself. And Nobetes will help. It really will.

 ON SCREEN: Guadalupe D.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

GUADALUPE D.: And Nobetes is like vitamins,

you know, taking vitamins and no side effects at all.

 ON SCREEN: Tony V.

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

TONY V.: I'm a life insurance agent and a

lot of my clients are -- you know, they have heath

issues. Either high blood pressure, diabetes or

16

whatever, and so that, in itself, you know, is all the

more reason why you should try to do it naturally. 

But Nobetes, you know, it saved -- it have saved me

from, you know, the high cost of medication.

 ON SCREEN: 1-844-44-55-66-7

 nobetes.com

 MITCH DARNELL: It's important to take care

of yourself, control your blood sugar within normal

levels and live a healthy, vibrant life, and I believe

Nobetes can help you do that.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: Now, you may be able to reverse

this. You need to try the all-natural dietary

supplement called Nobetes. 

 ON SCREEN: Henry H. 

 Actual Nobetes customer

 “took the risk and it worked”

 HENRY H.: The thing that I would like

people to do is to try it. Try it with an open mind

and see if it helps you because everyone that I've

talked to, that I've recommended it to, it's helped

them. And the doctor that I go to has recommended it

to her patients and she's told me it's helped many of

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YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 6 of 14 Page ID #:43 

17

them keeping their blood sugars in control and in

check. So step out there and take the risk and see if

it helps you because I can't imagine it not helping

you.

 ON SCREEN: Tony V. 

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

TONY V.: And I heard about Nobetes and they

offered a money back guarantee if it didn't work, so

what did I have to lose? So I called them up, ordered

it, and almost immediately I start feeling more

energy. My thought process was not cloudy. I

wouldn't be sitting here, you know -- you know, giving

this testimony if it didn't work. 

 ON SCREEN: Eddie J.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

EDDIE J.: And I got to tell you the truth.

I wouldn't sit here and BS you. I'm just not that

kind of person. I would not do this to -- unless it

was the truth, because I only tell the truth. I'm

18

that type of person. And the Nobetes does work.

 ON SCREEN: Rose A.

 Actual Nobetes customer

 “with Nobetes my blood sugar levels have

been in normal range”

1-844-44-55-66-7

nobetes.com

ROSE A.: Hi, my name is Rose. I have been

using the product, Nobetes, now for about two and a

half years. I eat anything I'd like. I try to, you

know, stay to a regular diet and I do some exercise,

not a lot. And with Nobetes, I -- my blood sugars

have been in normal range for the last two years. I

only take one a day and I just -- I recommend the

product to anybody that has diabetes and they can't

get it under control.

 ON SCREEN: JD H. 

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

JD H.: I'm very passionate about this

product. I don't want to go blind. I don't want to

go get -- go into a coma. I don't want to have a

stroke. I want to be around for my kids. So it's

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important not only to me, but it's important that I

share this message with you. 

 ON SCREEN: This following is a paid program

brought to by Nobetes

 JD H.: Nobetes is changing my life. And

you should hop on board.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: I'm all about natural

products that help empower your body to heal without

any side effects. 

 ON SCREEN: Natural Dietary Supplement 

 MITCH DARNELL: I was introduced to Nobetes. 

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: It's an all-natural dietary

supplement that helps control blood sugar within

20

normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

fill the nutrient shortages that diabetes causes. If

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes Continuity order, cancel anytime

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

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Complaint Exhibit C

40
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 7 of 14 Page ID #:44 

21

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now. 

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee 

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 ON SCREEN: John R.

 Actual Nobetes customer

 “its all natural with absolutely no side

effects”

1-844-44-55-66-7

nobetes.com

JOHN R.: Yes, one of the things that I

really like about Nobetes is that it's all-natural,

there's no side effects, no jitters, no anything about

it, absolutely no side effects whatsoever. And my

doctor -- I -- after I finally confessed to him and he

looked at it, he's like, yeah, okay, if it's working

22

and these things are working for you, go ahead and

take them. I said, okay, Doc, I will continue taking

them, trust me.

 ON SCREEN: Lance T.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

LANCE T.: If you're a diabetic and your

sugar levels are out of control, you have to try this

natural product called Nobetes. It's a natural

product, it's a great product. I'd recommend it to

any diabetic.

 ON SCREEN: Eddie J.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

EDDIE J.: Nobetes is really terrific for

me. I've gone to quite a few doctors using different

types of medications and the fluctuation was just

drastic. It was just a disaster. And when I did take

the Nobetes, of course, I was skeptical, but I must

say that it worked for me. It's terrific. 

 And any -- if you have diabetes, you have to

try this Nobetes. It is a supplement, it's not a

drug. You don't have to worry about dizzy spells,

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driving, going places, any anxiety. This product is

terrific and I endorse it 100 percent. Try the

Nobetes. It is really super. 

 ON SCREEN: Tony V.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

TONY V.: I'm Tony, I'm an actual customer

of Nobetes. I am a type 2 diabetic. I strongly urge

you to try the product. It's free and you won't

regret it.

 ON SCREEN: Guadalupe D.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

This following is a paid program brought to

by Nobetes

 GUADALUPE D.: I have been taking Nobetes

for two years, excellent. Nobetes is perfect.

 ANNOUNCER: Diabetics can have a hard time

avoiding many of their favorite foods. The temptation

to eat desserts and other high-carb sugary foods is

almost impossible to overcome all of the time. Our

customers are thankful they have Nobetes, especially

those times when they fall victim to temptation. This

24

is the miracle natural product you have been waiting

for. Give Nobetes a try. Call now for your free

trial.

 ANNOUNCER: The following are actual Nobetes

customers that wanted to get the word out and share

with you their experience with the Nobetes supplement

and how it has helped them in their fight against

diabetes. These are not paid actors. These are

actual customers.

 ON SCREEN: Robert B.

 Actual Nobetes customer

 “it enhances any medicine your making [sic],

considerably

1-844-44-55-66-7

nobetes.com

ROBERT B.: I think it's a fantastic

product. I ain't -- I ain't going to say that it --

it's the cure or nothing like that, but I'll say it

enhances any medicine that you're taking considerably. 

I never changed my diet. I mean, I exercise every

day, I always have. I'm 57 years old. I mean, I want

to eat what I want to eat when I want to eat it. 

 So, yeah, I’ve never changed my diet and I

still eat the same old crap I always did. But once I

eat all that crap, my sugar will go up. But when I

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Complaint Exhibit C

41
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 8 of 14 Page ID #:45 

25

take my Nobetes after dinner, by evening, I’m right

back where I was when I started. 

 ON SCREEN: Eddie J.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

EDDIE J.: I’m a big guy and I take Nobetes

and I’ll tell you, if I was looking for anything to

change my lifestyle, it sure was Nobetes because, now,

when I go to a birthday party, I can have a little

piece and I don’t go overboard, but I endorse Nobetes

100 percent.

 ON SCREEN: Tony V.

 Actual Nobetes customer

 Individual results will vary (appears

briefly on screen.)

1-844-44-55-66-7

nobetes.com

TONY V.: You know, I’ve tried a lot of

products over the years and, you know, I -- you know,

without no prevail, they didn’t work like Nobetes. I

would urge people who are diagnosed with type 2

diabetes to at least give it a try. 

 ON SCREEN: Tony V.

 Actual Nobetes customer

26

 This following is a paid program brought to

by Nobetes

 TONY V.: Give it a try, eat right,

exercise, and wean yourself from medication.

 ANNOUNCER: The following is a paid program

brought to you by Nobetes.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: I'm all about natural

products that help empower your body to heal without

any side effects. 

 ON SCREEN: Natural Dietary Supplement 

 MITCH DARNELL: I was introduced to Nobetes. 

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: It's an all-natural dietary

supplement that helps control blood sugar within

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normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

fill the nutrient shortages that diabetes causes. If

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes Continuity order, cancel anytime

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

28

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now. 

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee 

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 ON SCREEN: John S.

 Actual Nobetes customer

 “I’m a customer of Nobetes, my sugar levels

have been kept at a normal range”

1-844-44-55-66-7

nobetes.com

JOHN S.: My name is John. I’m a customer

of Nobetes. My sugar level has been kept at a normal

range. I would recommend this highly. I’ve

recommended it to other friends and it has worked for

me really, really good.

 ON SCREEN: Krysten M.

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Complaint Exhibit C

42
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 9 of 14 Page ID #:46 

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

KRYSTEN M.: When I first began taking

Nobetes, I was a student at the university. It was a

very stressful environment. I was working and I was

doing a lot of studying. And the stress in general

just had me up and down with my blood sugar level. So

I was constantly feeling sick. I started taking

Nobetes and my blood sugar levels stabilized a normal

range, and I just felt great.

 ON SCREEN: Bob C.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

BOB C.: Well, when you take meds, you know,

there’s always that question, is it going to work, is

it not going to work? The question that I have for

you is -- or the answer I have is this works. This is

proven to work and I’ve got the blood tests to prove

it. Nobetes did the job and it’s doing the job and

it’s got me under control. I lost 48 pounds on

special diets and I feel great.

30

 ON SCREEN: Henry H.

 Actual Nobetes customer

 “I’m 60 years old and I don’t eat right, the

product works well”

1-844-44-55-66-7

nobetes.com

HENRY H.: I took the bottles into my

doctor. She got with the nutritionist there and they

looked it all over and they didn’t see any reason why

I couldn’t take it. So I started on it and I started

at three pills a day and then I backed it off after

three months. And that’s the only thing I did

different. I’m 60 years old. I don’t exercise. I

don’t eat right. I eat what I want when I want. But

the product works well.

 ON SCREEN: Lance T.

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

LANCE T.: I really don’t believe it. I

thought maybe my meter was wrong or something. But I

went to the doctor and he tested me, too, and it’s

unreal. This product works. It really does. I mean,

29 31

you can’t go out and eat pizza and have apple pie and

not exercise. I mean, you have to exercise and watch

your diet. I mean, I’ve taken flour and sugar out of

my diet and it worked for me. But if you take

Nobetes, try it, you’ll like it.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: Now, you may be able to reverse

this. You need to try the all-natural dietary

supplement called Nobetes. 

 ON SCREEN: Tony V.

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

nobetes.com

TONY V.: You can't put a price tag on your

health, that's one thing and this -- I want to say

it's a disease, you know, it's serious. But, you

know, a lot of people don't take it serious. But if

you would help yourself, you know, the cost of Nobetes

is really affordable and it costs nothing to try it. 

So you don't have to take my word. Request a bottle

and try it for yourself. But, again, there's no price

32

tag on good health.

 ON SCREEN: Guadalupe D.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

GUADALUPE D.: Before Nobetes I was taking

insulin for 30 milligrams in the morning and 30

milligrams in the afternoon. So now I'm taking

insulin only in the morning, 30 milligrams. I'm not

taking it at nighttime. 

 ON SCREEN: Oscar

 Actual Nobetes customer

 “if the item wasn’t any good, I’d be hanging

up the phone on you” 

1-844-44-55-66-7

nobetes.com

This following is a paid program brought to

by Nobetes

 OSCAR: If I didn’t think this item was any

good, I’d be hanging up the phone on you. That’s what

you get from the old folks. We just tell you the

truth, it’s good or it’s not. And if it’s not, we --

you won’t hear from us. But I’m glad that I did take

that chance. Like I said, hopefully, I can get off

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Complaint Exhibit C

43
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 10 of 14 Page ID #:47 

33

the other pills.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: I'm all about natural

products that help empower your body to heal without

any side effects. 

 ON SCREEN: Natural Dietary Supplement 

 MITCH DARNELL: I was introduced to Nobetes. 

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: It's an all-natural dietary

supplement that helps control blood sugar within

normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

fill the nutrient shortages that diabetes causes. If

34

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes Continuity order, cancel anytime

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now.

 ON SCREEN: Free 

 Bottle

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 Processing & Handling

 $6.95

 30 day money back guarantee 

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 ON SCREEN: Henry H.

 Actual Nobetes customer

 “took a risk and was amazed how well it

worked”

1-844-44-55-66-7

nobetes.com

HENRY H.: My name is Henry. I’ve been

taking Nobetes now for about two years. I wanted to

call in and give a reference for it because I am very

pleased with it. If you’re like me, you’ve heard a

lot of things on TV and advertisements and on the

radio and you aren’t sure, and I wasn’t sure, but I

figured you step out there and you take that risk and

if it doesn’t work, well, done that, been there, and

you’re on to the next thing. But it did work. I was

amazed at how well it did work.

 ANNOUNCER: Is your diabetes out of control?

36

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: Now, you may be able to reverse

this. You need to try the all-natural dietary

supplement called Nobetes. 

 ON SCREEN: John

 Actual Nobetes customer

 “nothing else was working for me, it’s a

fantastic product”

1-844-44-55-66-7

nobetes.com

JOHN: My name’s John. I’m from

Pennsylvania and I am an actual user of Nobetes for

over two years. I heard a radio advertisement for the

product. I was having problems and I had to do

something. Nothing else was working for me. And I

did not want to do injections. So I tried this

product. I highly recommend this. It’s a fantastic

product. (Inaudible) and keeps you healthy. So my

suggestion is just do it and take it. (Inaudible).

 ON SCREEN: Tony V.

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.)

1-844-44-55-66-7

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Complaint Exhibit C

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YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 11 of 14 Page ID #:48 

37

 nobetes.com

 TONY V.: I’m Tony. I’m an actual customer

of Nobetes. I am a type 2 diabetic. I strongly urge

you to try the product. It’s free and you won’t

regret it.

 ON SCREEN: Virginia

 Actual Nobetes customer

 “I became discouraged until Nobetes, finally

something is working”

1-844-44-55-66-7

nobetes.com

VIRGINIA: I’m Virginia and I’m an actual

customer of Nobetes. And if you’re like me and you’re

having trouble keeping your sugar numbers down, I was

very skeptical because I’ve used lots of different

products that never worked and so I became very

discouraged until I got the Nobetes. And something is

finally working and it’s wonderful. So I would just

recommend it to anyone.

 ON SCREEN: Eddie J.

 Actual Nobetes customer

1-844-44-55-66-7

nobetes.com

EDDIE J.: The one thing that I really love

about Nobetes, it’s the safe way to go. It isn’t like

38

you’ve got to wonder, am I taking something that’s

going to knock me out, make me groggy, can’t drive a

car, worry about whether I’m going to get dizzy or any

of those type of problems that you get with the side

effects of other types of medicines, because we’re all

different and, you know, we all react to everything

differently. Now, you know, maybe it won’t work for

some people, but I’ll tell you one thing, I’m a big

guy, I’m over 300 pounds, and when my numbers were

running 280, 270, it was pretty scary. To know that

they’re down now, at least I got a fighting chance and

I love the Nobetes.

 ON SCREEN: Frank E.

 Actual Nobetes customer

 “Nobetes has my blood sugar levels under

control”

1-844-44-55-66-7

nobetes.com

FRANK E.: Nobetes is -- I’ve taken it a

couple days, it has my sugar count under control and I

would recommend anyone to try this.

 ON SCREEN: JD H. 

 Actual Nobetes customer

 Individual results will vary (appears on

screen briefly.) 

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1-844-44-55-66-7

nobetes.com

JD H.: I’m very passionate about this

product. I don't want to go blind. I don't want to

go get -- go into a coma. I don't want to have a

stroke. I want to be around for my kids. So it's

important not only to me, but it's important that I

share this message with you. Nobetes is changing my

life. And you should hop on board.

 ANNOUNCER: Is your diabetes out of control?

Are your blood sugar numbers dangerously high? 

 ON SCREEN: Natural Dietary Supplement

 ANNOUNCER: You need to try the all-natural

dietary supplement called Nobetes. Just listen to

what other diabetics are saying.

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

nobetes.com

MITCH DARNELL: I'm all about natural

products that help empower your body to heal without

any side effects. 

 ON SCREEN: Natural Dietary Supplement 

 MITCH DARNELL: I was introduced to Nobetes. 

 ON SCREEN: Mitch Darnell, MS, OSM.CTRC

1-844-44-55-66-7

40

 nobetes.com

 MITCH DARNELL: It's an all-natural dietary

supplement that helps control blood sugar within

normal levels, with the added benefit it leaves you

feeling better and really contributes to your overall

greater health. 

 Nobetes has 35 supplements in it that can

fill the nutrient shortages that diabetes causes. If

you were you to go out and try to buy all of these

supplements at $3 to $4 a piece, it could cost you

$150 or more. 

 Diabetics, this is the miracle product

you've been waiting for, Nobetes.

 ON SCREEN: Nobetes bottle label

 These statements have not been evaluated by

the Food and Drug Administration. This product is not

intended to diagnose, treat, cure or prevent any

disease.

 ANNOUNCER: Give Nobetes a try and see what

this miracle product can do for you.

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 Includes Continuity order, cancel anytime

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Complaint Exhibit C

45
YouTube Video NB_28:30 1-3-17 

NoBetes 1/3/2017 

Case 2:18-cv-10068 Document 1-3 Filed 12/03/18 Page 12 of 14 Page ID #:49 

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Get your bottle free. Just pay

6.95 processing and handling. Go to Nobetes.com or

call 1-844-445-5667 right now. That's 1-844-445-5667

right now. 

 ON SCREEN: Free 

 Bottle

 Processing & Handling

 $6.95

 30 day money back guarantee 

less S&H

1-844-44-55-66-7

nobetes.com

ANNOUNCER: Go to Nobetes.com or call

1-844-445-5667 right now.

 MITCH DARNELL: Diabetics, this is the

miracle product you’ve been waiting for, Nobetes.

 ON SCREEN: All Nobetes customers must read

and agree to the below disclaimer and liability

limitations or do not take the product and return it

for a full refund. This constitutes actual notice of

the terms and conditions of use of the nobetes

product. This agreement is a total of three pages. 

READ ALL OF THEM (p.1)

42

DISCLAIMER AND LIABILITY LIMITATIONS

PLEASE READ BEFORE USING THE NOBETES PRODUCT

1. NoBetes formula is not intended to treat, cure or

prevent any disease. Please follow all of your

doctors’ orders. This product has not been evaluated

by the Food and Drug Administration (FDA), and NoBetes

Corporation and Side Effects Solutions Corporation

make no claims or representations that the NoBetes

product can cure, treat or prevent any disease.

2. Thank you for purchasing the NoBetes product. We

have created NoBetes for diabetics and we hope it can

help you. We believe in our product but nonetheless

we are always concerned that people in the general

public, drug companies, etc., wish to see our product

and other natural products like ours off the market

all together. Therefore, we have been advised by our

lawyers to include the following provisions. If you

do not agree with these provisions as set forth in

this three-page liability and disclaimer, do not take

the NoBetes product and return it for a full refund

plus any cost of return shipping you expend.

3. TERMS AND CONDITIONS FOR ALL CUSTOMERS AND USERS

OF NOBETES

4. By using the NoBetes supplement and/or ordering

Complaint Exhibit C

46

41 43

the product NoBetes and/or listening to or viewing any

of the NoBetes advertising such as but not limited to

television, radio, print, Internet or website you

agree to the following terms and conditions set forth

below by both Side Effects Solutions Corporation and

NoBetes Corporation:

5. WAIVER OF LIABILITY. YOU AGREE THAT SIDE EFFECT

SOLUTIONS CORPORATION AND/OR NOBETES CORPORATION,

THEIR EMPLOYEES, AFFILIATES, AGENTS, INDEPENDENT

CONTRACTORS, REPRESENTATIVES AND THEIR RESPECTIVE

OFFICERS OR DIRECTORS, SHALL NOT BE HELD LIABLE FOR

ANY CLAIM, LOSS, PERSONAL INJURY, DAMAGES, EXPENSES OR

COSTS WHETHER DIRECT OR INDIRECT, INCLUDING

CONSEQUENTLY OR SPECIAL DAMAGES, LOST PROFITS OR

OTHERWISE, ARISING OUT OF OR RELATING IN ANY WAY TO

THIS AGREEMENT AND/OR THE USE, TAKING,

All Nobetes customers must read and agree to the below

disclaimer and liability limitations or do not take

the product and return it for a full refund. This

constitutes actual notice of the terms and conditions

of use of the nobetes product. This agreement is a

total of three pages. READ ALL OF THEM. (p.2)

OR ADVERTISING OF THE PRODUCT NOBETES. THE NOBETES

CORPORATION AND/OR SIDE EFFECTS SOLUTIONS CORPORATION

ARE NOT RESPONSIBLE OR LIABLE FOR THE NOBETES WEB SITE

44

OR ADVERTISING, YOUR USE OR INABILITY TO USE THE WEB

SITE, YOUR PURCHASE OR USE OF ANY GOODS, SERVICES OR

INFORMATION FROM THIS WEB SITE OR TELEVISION, RADIO,

PRINT, AND/OR INTERNET ADVERTISING, OR FROM

UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR

TRANSMISSIONS OR DATA OR THE ACTS OF ANY THIRD PARTY

RELATED TO THE WEB SITE. YOU HEREBY WAIVE ANY CLAIMS

WITH RESPECT THERETO, WHETHER BASED ON CONTRACTUAL,

TORT, OR OTHER LIABILITY THEORIES, SUCH AS FALSE

ADVERTISING, GROSS NEGLIGENCE, AND/OR FRAUD. YOU

AGREE THAT YOU WILL NOT BRING ANY ACTION OR LAWSUIT

AGAINST NOBETES CORPORATION OR SIDE EFFECT SOLUTIONS

CORPORATION AND ITS OFFICERS, DIRECTORS, AGENTS,

INDEPENDENT CONTRACTORS, OR REPRESENTATIVES EVEN IF

YOU HAVE ADVISED THEM OF THE POSSIBILITY OF SUCH

DAMAGES.

6. Class Action Limitation. With no exception, you

will be required to submit claims that you have

against Side Effect Solutions Corporation and/or

NOBETES Corporation to binding and final arbitration:

(1)you shall only be permitted to pursue claims

against Side Effect Solutions Corporation on an

individual basis, not as a plaintiff or class member

in any class or representative action or proceeding

and (2)you shall be limited to seeking relief

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45

(including monetary, injunctive and declaratory

relief) on an individual basis. No class action

lawsuits but only individual claims shall be permitted

subject to binding arbitration in California through

JAMS arbitration services. (3)As a consumer of

NoBetes, I agree to waive all class action rights and

assume the risk of taking this product. Additionally,

this class action provision applies to all false

advertising claims and any claims based on the

marketing or advertising, including the commercials,

testimonials, etc., of the NoBetes supplement product.

7. I ASSUME THE RISK OF TAKING THE NOBETES SUPPLEMENT

PRODUCT AND I AM PERSONALLY AND FULLY RESPONSIBLE FOR

ANY AND ALL LIABILITY THAT MAY RESULT FROM TAKING THIS

PRODUCT. I HAVE ACTUAL KNOWLEDGE OF THE RISK INVOLVED

IN THE CONDUCT OR ACTIVITY OF TAKING THE NOBETES

SUPPLEMENT PRODUCT AND I MAKE THIS DECISION OF MY OWN

FREE WILL AND HAVE CONSULTED WITH MY DOCTOR PRIOR TO

TAKING THE PRODUCT.

8. LIMITATION OF LIABILITY. In no event shall

NoBetes Corporation or Side Effect Solutions

Corporation be liable for personal injury, breach of

contract, false advertising claims, consequential,

incidental, indirect, punitive or special damages, or

gross negligence damages or negligence damages in

46

EXCESS OF $100. A complete and total refund shall be

all the damages NoBetes Corporation and Side Effect

Solutions Corporation can be held liable for,

regardless of whether such liability is based on

breach of contract, tort, strict liability, breach of

warranties, failure of essential purpose, or both

negligence or gross negligence, and even if advised of

the likelihood of such damages. This damage

limitation is valid and enforceable in any state

within the United States of America.

ALL Nobetes customers must read and agree to the below

disclaimer and liability limitations or do not take

the product and

 ON SCREEN: return it for a full refund. 

This constitutes actual notice of the terms and

condition of use of the nobetes product. This

agreement is a total of three pages. READ ALL OF

THEM. (p.3) 

9. ATTORNEY FEES. In any litigation, arbitration, or

other proceeding by which Nobetes Corporation and/or

Side Effect Solutions Corporation, its employees,

affiliates, agents, independent contractors,

representatives and their respective officers or

directors have to defend themselves in any lawsuit

under this Agreement (whether in contract, tort or

Complaint Exhibit C

47

47

1 1 both) or seeks a declaration of any rights or

obligations under this Agreement, the Nobetes

Corporation and Side Effect Solutions Corporation

shall be awarded its reasonable attorney fees, and

costs and expenses incurred in defense of any lawsuit

brought against them.

10. SEVERANCE. IF A COURT OF COMPETENT AUTHORITY

HOLDS THAT ANY PROVISION OF THIS AGREEMENT (OR PART OF

ANY PROVISIONS) IS INVALID, ILLEGAL OR UNENFORCEABLE,

THAT PROVISION OR PART-PROVISION SHALL, TO THE EXTENT

REQUIRED, BE MODIFIED TO THE SLIGHTEST DEGREE

NECESSARY TO MAKE IT ENFORCEABLE, REMAINING AS CLOSE

AS POSSIBLE TO THE PARTIES’ ORIGINAL INTENT FOR THE

PROVISION. IF NOT POSSIBLE, THE OFFENDING PROVISION

WILL BE STRICKEN. IF A PROVISION OF THIS AGREEMENT IS

HELD TO BE UNENFORCEABLE, THE OTHER PROVISIONS WILL

REMAIN IN EFFECT.

INSTRUCTIONS

PLEASE START WITH 2 TABLETS PER DAY WHEN YOU RECEIVE

YOUR NOBETES PRODUCT. WE RECOMMEND YOU START WITH 1

TABLET 30 MINUTES BEFORE THE LARGEST CARBOHYDRATE MEAL

OF THE DAY AND A SECOND NOBETES TABLET 30 MINUTES

BEFORE THE SECOND LARGEST CARBOHYDRATE MEAL OF THE

DAY. WE RECOMMEND AFTER 5 DAYS, IF YOU ARE NOT SEEING

THE RESULTS YOU WOULD LIKE TO SEE, ADDING AN

48

ADDITIONAL TABLET BEFORE YOU GO TO BED FOR A TOTAL OF

THREE TABLETS PER DAY. WE SUGGEST THE 3 TABLET CYCLE

FOR ANOTHER 5 DAYS. IF THE 3 TABLET CYCLE IS NOT

ACHIEVING THE RESULTS YOU WOULD LIKE TO SEE, YOU CAN

ADD AN ADDITIONAL TABLET PER DAY, FOR A TOTAL OF 4

TABLETS. WE SUGGEST THE FOURTH TABLET WITH YOUR

LARGEST CARBOHYDRATE MEAL OF THE DAY-THUS TAKING 2

TABLETS WITH YOUR LARGEST MEAL. AT THIS POINT, YOU

WOULD BE TAKING 4 TABLETS A DAY UNTIL YOU ARE FINISHED

WITH YOUR TRIAL BOTTLES. (EVERY INDIVIDUAL IS

DIFFERENT AND IT IS OUR BELIEF THAT SOME REQUIRE MORE

NOBETES TABLETS PER DAY TO GET THE RESULTS THEY

DESIRE.) BELOW IS A DETAILED EXPLANATION OF WAYS

OTHERS HAVE USED NOBETES:

2 Tablet Method: Take 1 tablet per day approximately

a half hour before your largest (carbohydrate) meal.

Take the 2nd tablet approximately a half hour before

your 2nd largest (carbohydrate) meal for a total of 2

tablets per day.

3 Tablets Method: Take 1 tablet per day approximately

a half hour before your largest (carbohydrate) meal.

Take the 2nd tablet approximately a half hour before

your 2nd largest (carbohydrate) meal. Take 1

additional tablet after dinner approximately a half an

hour before you go to bed for a total of 3 tablets per

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49

1 day.

4 Tablet Method (a): Some NoBetes users prefer taking

2 tablets 30 minutes before their first largest

carbohydrate meal and 2 tablets before their second

largest carbohydrate meal for a total of 4 tablets a

day to achieve the results they desire.

4 Tablet Method (b): Take 2 tablets 30 minutes before

your largest carbohydrate meal and 1 tablet 30 minutes

prior to your second largest carbohydrate meal. Your

last tablet approximately 30 minutes before you go to

bed.

4 Tablet Method (c): Take 1 tablet when you wake up

in the morning, 1 tablet 30 minutes before your

largest two carbohydrate meals of the day and 1 tablet

approximately 30 minutes before you go to bed.

The aforementioned methods have worked for NoBetes

users in helping them achieve their goals.

Once you have reached your desired results, usually 1

or 2 tablets before the largest meal of the day will

usually maintain your results. Please adjust dosages

per your individual needs, but do not take more than 4

tablets per day. PLEASE MONITOR BLOOD SUGAR DAILY

WHEN USING NOBETES. ADJUST NOBETES INTAKE AS NEEDED.

 ANNOUNCER: The preceding program was

brought to you by Nobetes. Just remember Nobetes.com.

50

That’s Nobetes.com.

 ON SCREEN: The preceding program was

brought to you by Nobetes. 

 NOBETES

 Nobetes.com.

 (The recording was concluded.)

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1 CERTIFICATE OF TRANSCRIPTIONIST

 I, Elizabeth M. Farrell, do hereby certify

that the foregoing proceedings and/or conversations

were transcribed by me via CD, videotape, audiotape or

digital recording, and reduced to typewriting under my

supervision; that I had no role in the recording of

this material; and that it has been transcribed to the

best of my ability given the quality and clarity of

the recording media.

 I further certify that I am neither counsel

for, related to, nor employed by any of the parties to

the action in which these proceedings were

transcribed; and further, that I am not a relative or

employee of any attorney or counsel employed by the

parties hereto, nor financially or otherwise

interested in the outcome of the action.

DATE: 2/28/2018

ELIZABETH M. FARRELL, CERT

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Complaint Exhibit C

48