IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE

_______________________________________ 

)

FEDERAL TRADE COMMISSION and )

STATE OF MAINE, )

) Case No. 1:17-cv-00067-NT

Plaintiffs, )

)

v. ) STIPULATED FINAL ORDER

) FOR PERMANENT INJUNCTION

) AND OTHER EQUITABLE

XXL IMPRESSIONS LLC a limited liability ) RELIEF AS TO DEFENDANT

company, also d/b/a BETTER HEALTH ) RONALD JAHNER

NUTRITIONALS, )

)

JEFFREY R. POWLOWSKY, individually )

and as an owner and officer of XXL )

IMPRESSIONS LLC, )

)

J2 RESPONSE L.L.P., a limited liability )

partnership, also d/b/a J2 RESPONSE, )

)

JUSTIN BUMANN, individually )

and as a partner of J2 RESPONSE L.L.P., )

)

JUSTIN STEINLE, individually and as a )

partner of J2 RESPONSE L.L.P., )

)

SYNERGIXX, LLC, a limited liability )

company, also d/b/a CTF MEDIA, )

)

CHARLIE R. FUSCO, individually )

and as an owner and officer of SYNERGIXX, )

LLC, )

)

RONALD JAHNER, and )

)

BRAZOS MINSHEW a/k/a SAMUEL BRANT, )

)

Defendants. )

_______________________________________ )

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Plaintiffs, the Federal Trade Commission (“FTC” or “Commission”) and the State of 

Maine, as represented in this matter by the Office of the Attorney General of Maine (“Maine 

AG”) (“Plaintiffs”), filed a Complaint for Permanent Injunction and Other Equitable Relief 

against Defendants pursuant to Section 13(b) of the Federal Trade Commission Act (“FTC Act”), 

15 U.S.C. § 53(b), and pursuant to Section 209 of the Maine Unfair Trade Practices Act (“Maine 

UTPA”), ME. REV. STAT. tit. 5, § 209, 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, and in violation of Section 207 of the Maine 

UTPA, ME. REV. STAT. tit. 5, § 207, in connection with the labeling, advertising, marketing, 

distribution, and sale of products purported to provide relief from joint and back pain and to

prevent or mitigate cognitive decline.

The Commission, the State of Maine, and Defendant Ronald Jahner (“Defendant Jahner”) 

stipulate to the entry of this Final Order for Permanent Injunction and Other Equitable Relief as 

to Defendant Jahner.

FINDINGS

1. This Court has jurisdiction over this matter.

2. The Complaint charges that Defendant Jahner participated in deceptive acts or 

practices in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52, and in 

violation of Section 207 of the Maine UTPA, ME. REV. STAT. tit. 5, § 207, in connection with the 

labeling, advertising, marketing, distribution, and sale of products purported to provide pain 

relief and to prevent or mitigate cognitive decline.

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3. Defendant Jahner neither admits nor denies any of the allegations in the

Complaint, except as specifically stated in this Order. Defendant Jahner admits the facts 

necessary to establish jurisdiction only for purposes of this action.

4. Defendant Jahner waives any claim that he may have under the Equal Access to 

Justice Act, 28 U.S.C. § 2412, concerning the prosecution of this action through the date of this 

Order, and agrees to bear his own costs and attorney fees.

5. Defendant Jahner and Plaintiffs waive all rights to appeal or otherwise challenge 

or contest the validity of this Order.

DEFINITIONS

For the purpose of this Order, the following definitions apply:

1. “Clear(ly) and conspicuous(ly)” means that a required disclosure is difficult to 

miss (i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of 

the following ways:

A. In any communication that is solely visual or solely audible, the disclosure 

must be made through the same means through which the communication 

is presented. In any communication made through both visual and audible 

means, such as a television advertisement, the disclosure must be 

presented simultaneously in both the visual and audible portions of the 

communication even if the representation requiring the disclosure is made 

in only one means;

B. A visual disclosure, by its size, contrast, location, the length of time it 

appears, and other characteristics, must stand out from any accompanying 

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text or other visual elements so that it is easily noticed, read, and 

understood;

C. An audible disclosure, including by radio, telephone or streaming video, 

must be delivered in a volume, speed, and cadence sufficient for ordinary 

consumers to easily hear and understand it;

D. In any communication using an interactive electronic medium, such as the 

Internet or software, the disclosure must be unavoidable;

E. The disclosure must use diction and syntax understandable to ordinary 

consumers and must appear in each language in which the representation 

that requires the disclosure appears;

F. The disclosure must comply with these requirements in each medium 

through which it is received, including all electronic devices and face-toface communications;

G. The disclosure must not be contradicted or mitigated by, or inconsistent 

with, anything else in the communication; and

H. When the representation or sales practice targets a specific audience, such 

as children, the elderly, or the terminally ill, “ordinary consumers” 

includes reasonable members of that group.

2. “Close proximity” means that the disclosure is very near the triggering 

representation. For example, a disclosure made through a hyperlink, pop-up, interstitial, or other 

similar technique is not in close proximity to the triggering representation.

3. “Covered Product” means any Dietary Supplement, Food, or Drug, including 

but not limited to FlexiPrin and CogniPrin.

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4. “Defendant” means Ronald Jahner.

5. “Dietary supplement” means: 

A. any product labeled as a dietary supplement or otherwise represented as a 

dietary supplement; or 

B. any pill, tablet, capsule, powder, softgel, gelcap, liquid, or other similar 

form containing one or more ingredients that is a vitamin, mineral, herb or 

other botanical, amino acid, probiotic, or other dietary substance to 

supplement the diet by increasing the total dietary intake, or a concentrate, 

metabolite, constituent, extract, or combination of any ingredient 

described above, that is intended to be ingested, and is not represented to 

be used as a conventional food or as a sole item of a meal or the diet.

6. “Drug” means: (1) articles recognized in the official United States 

Pharmacopoeia, official Homeopathic Pharmacopoeia of the United States, or official National 

Formulary, or any supplement to any of them; (2) articles intended for use in the diagnosis, cure, 

mitigation, treatment, or prevention of disease in humans or other animals; (3) articles (other 

than food) intended to affect the structure or any function of the body of humans or other 

animals; (4) articles intended for use as a component of any article specified in (1), (2), or (3); 

but does not include devices or their components, parts, or accessories.

7. “Essentially Equivalent Product” means a product that contains the identical 

ingredients, except for inactive ingredients (e.g., binders, colors, fillers, excipients), in the same 

form and dosage, and with the same route of administration (e.g., orally, sublingually), as the 

Covered Product; provided that the Covered Product may contain additional ingredients if 

reliable scientific evidence generally accepted by experts in the field indicates that the amount 

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and combination of additional ingredients is unlikely to impede or inhibit the effectiveness of the 

ingredients in the Essentially Equivalent Product.

8. “Food” means: (1) any article used for food or drink for humans or other 

animals; (2) chewing gum; and (3) any article used for components of any such article.

9. “Including” means including but not limited to.

10. “Material Connection” means any relationship that materially affects the weight 

or credibility of any Endorsement and that would not reasonably be expected by consumers.

11. “Person” means a natural person, an organization, or other legal entity, including 

a corporation, partnership, sole proprietorship, limited liability company, association, 

cooperative, or any other group or combination acting as an entity.

I.

PROHIBITED REPRESENTATIONS: PAIN RELIEF, CARTILAGE REBUILDING, 

COGNITIVE DECLINE, MEMORY IMPROVEMENT, AND DISEASE CLAIMS

IT IS HEREBY ORDERED that Defendant, Defendant’s officers, agents, employees, 

and attorneys, and all other persons in active concert or participation with any of them, who 

receive actual notice of this Order, whether acting directly or indirectly, in connection with the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product, are hereby permanently restrained and enjoined from making, or assisting 

others in making, expressly or by implication, including through the use of a product name, 

Endorsement, depiction, or illustration, any representation, that, in humans, such Covered 

Product:

A. Reduces joint pain, inflammation, or stiffness, including in as little as two hours;

B. Provides relief from back pain;

C. Reduces the need for medication; 

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D. Helps rebuild damaged joints or cartilage;

E. Reverses, mitigates, or prevents cognitive or mental decline;

F. Improves memory; 

G. Restores lost memory capacity; or

H. Cures, mitigates, or treats any disease;

unless the representation is non-misleading and, at the time of making such representation, 

Defendant possesses and relies upon competent and reliable scientific evidence substantiating

that the representation is true. For purposes of this Section, competent and reliable scientific 

evidence shall consist of human clinical testing of the Covered Product, or of an Essentially 

Equivalent Product, that is sufficient in quality and quantity based on standards generally 

accepted by experts in the relevant disease, condition, or function to which the representation 

relates, when considered in light of the entire body of relevant and reliable scientific evidence, to 

substantiate that the representation is true. Such testing shall be: (1) randomized, double-blind, 

and placebo-controlled; and (2) conducted by researchers qualified by training and experience to 

conduct such testing. Defendant shall have the burden of proving that a product satisfies the 

definition of Essentially Equivalent Product.

Provided, however, that no provision of this Section shall apply to personal treatment or 

coaching sessions between the Defendant and any client, which do not include the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product, if those sessions are subject to the authority of any professional licensing board 

in any state.

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II.

PROHIBITED REPRESENTATIONS: OTHER HEALTH-RELATED CLAIMS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, and 

employees, and all other persons in active concert or participation with any of them, who receive 

actual notice of this Order, whether acting directly or indirectly, in connection with the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product, other than a representation covered by Section I of this Order, are permanently 

restrained and enjoined from making, or assisting others in making, expressly or by implication, 

including through the use of a product or program name, Endorsement, depiction, or illustration, 

any representation about the health benefits, safety, performance, or efficacy of any Covered 

Product, unless the representation is non-misleading, and, at the time of making such 

representation, Defendant possesses and relies upon competent and reliable scientific evidence 

that is sufficient in quality and quantity based on standards generally accepted by experts in the 

relevant disease, condition, or function to which the representation relates, when considered in 

light of the entire body of relevant and reliable scientific evidence, to substantiate that the 

representation is true.

For purposes of this Section, competent and reliable scientific evidence means tests, 

analyses, research, or studies (1) that have been conducted and evaluated in an objective manner 

by experts in the relevant disease, condition, or function to which the representation relates; 

(2) that are generally accepted by such experts to yield accurate and reliable results; and (3) that 

are randomized, double-blind, and placebo controlled human clinical testing of the Covered 

Product, or of an Essentially Equivalent Product, when such experts would generally require 

such human clinical testing to substantiate that the representation is true.

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Provided, however, that no provision of this Section shall apply to personal treatment or 

coaching sessions between the Defendant and any client, which do not include the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product, if those sessions are subject to the authority of any professional licensing board 

in any state.

III.

PROHIBITED REPRESENTATIONS REGARDING TESTS, STUDIES,

OR INGREDIENTS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, and 

employees, and all other persons in active concert or participation with any of them, who receive 

actual notice of this Order, whether acting directly or indirectly, in connection with the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product are hereby permanently restrained and enjoined from misrepresenting, in any 

manner, expressly or by implication, including through the use of any product name, 

Endorsement, depiction, or illustration:

A. That any Covered Product is clinically proven to restore or improve memory, or 

mitigate cognitive decline;

B. That any Covered Product is clinically proven to rebuild joint cartilage, reduce 

back or joint pain, reduce stiffness, or reduce inflammation;

C. That the performance or benefits of any Covered Product are scientifically 

proven; or

D. The existence, contents, validity, results, conclusions, or interpretations of any 

test, study, or research.

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IV.

FDA-APPROVED CLAIMS

IT IS FURTHER ORDERED that nothing in this Order prohibits Defendant, 

Defendant’s officers, agents, and employees, or all other persons in active concert or 

participation with any of them from:

A. For any drug, making a representation that is approved in labeling for such drug 

under any tentative final or final monograph promulgated by the Food and Drug 

Administration, or under any new drug application approved by the Food and 

Drug Administration; and

B. For any product, making any representation that is specifically authorized for use 

in labeling for such product by regulations promulgated by the Food and Drug 

Administration pursuant to the Nutrition Labeling and Education Act of 1990 or 

permitted under Sections 303-304 of the Food and Drug Administration 

Modernization Act of 1997.

V.

PROHIBITED REPRESENTATIONS AS AN EXPERT ENDORSER

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, and

employees, and all other persons in active concert or participation with any of them, who receive 

actual notice of this Order, whether acting directly or indirectly, in connection with the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

Covered Product are permanently restrained and enjoined from making, expressly or by 

implication, any representations as an expert endorser, including, but not limited to, the 

representations covered by Section I of this Order, entitled Prohibited Representations: Pain 

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Relief, Cartilage Rebuilding, Cognitive Decline, Memory Improvement, And Disease Claims

and Section II of this Order, entitled Prohibited Representations: Other Health-Related Claims, 

above, unless he possesses the represented expertise and he possesses and relies upon:

A. Competent and reliable scientific evidence required for the particular

representation, as set forth in Sections I and II, above; and

B. An actual exercise of the represented expertise, in the form of an

evaluation or test of such product conducted and evaluated in an objective manner 

and which is generally accepted in the relevant profession to yield accurate and 

reliable results.

VI.

DISCLOSURE OF MATERIAL CONNECTIONS

IT IS FURTHER ORDERED that Defendant, Defendant’s officers, agents, and 

employees, and all other persons in active concert or participation with any of them, who receive 

actual notice of this Order, whether acting directly or indirectly, in connection with the 

manufacturing, labeling, advertising, promotion, offering for sale, sale, or distribution of any 

good or service, are permanently restrained and enjoined from making any representation, 

expressly or by implication, including through the use of a product or program name, 

Endorsement, depiction, or illustration, about any endorser of a good or service unless they 

disclose, Clearly and Conspicuously, and in close proximity to the representation, a Material 

Connection, when one exists, between such endorser and Defendant or any other individual or 

entity manufacturing, labeling, advertising, promoting, offering for sale, selling, or distributing 

such good or service.

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VII.

COOPERATION WITH FTC AND MAINE

IT IS FURTHER ORDERED that Defendant must fully cooperate with representatives 

of the Commission, the Maine AG, and any of their representatives in this case and in any 

investigation related to or associated with the transactions or the occurrences that are the subject 

of the Complaint. Defendant must provide truthful and complete information, evidence, and 

testimony. Defendant must appear for interviews, discovery, hearings, trials, and any other 

proceedings that a representative of the Commission or the Maine AG may reasonably request 

upon 5 days’ written notice, or other reasonable notice, at such places and times as a 

Commission or Maine AG representative may designate, without the service of a subpoena.

VIII.

ORDER ACKNOWLEDGMENTS

IT IS FURTHER ORDERED that Defendant acknowledge receipt of this Order within 

7 days of entry of this Order. Such acknowledgment must be sworn under penalty of perjury and

must be submitted to the Commission and the State of Maine upon receipt of this Order. 

Additionally,

A. For 10 years after entry of this Order, Defendant must, for any 

business involved in the sale or marketing of any Covered Product that Defendant 

is the majority owner or controls directly or indirectly, must deliver a copy of this 

Order to:

1. All principals, officers, directors, LLP and LLC partners, managers, and 

members;

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2. All employees, agents, and representatives who participate in the 

manufacturing labeling, advertising, marketing, distribution, or sale of any 

Covered Product or service; and

3. Any business entity resulting from any change in structure as set forth in 

the Section titled Compliance Reporting.

Delivery must occur within 7 days of entry of this Order for current personnel. For all 

others, delivery must occur before they assume their responsibilities.

B. From each individual or entity to which Defendant delivered a copy of this Final 

Order, Defendant must obtain, within 30 days, a signed and dated 

acknowledgment of receipt of this Order.

IX.

COMPLIANCE REPORTING

IT IS FURTHER ORDERED that Defendant make timely submissions to the 

Commission and to the Maine AG:

A. 60 days after entry of this Order, Defendant must submit a 

compliance report, sworn under penalty of perjury:

1. Defendant must: (a) identify the primary physical, postal, and 

email address and telephone number as designated points of contact, 

which Plaintiffs’ representatives may use to communicate with Defendant;

(b) identify all of Defendant’s businesses by all of their names, telephone

numbers, and physical, postal, email, and Internet addresses; (c) describe, 

the activities of each business, including the goods and services offered,

the means of advertising, marketing, and sales, and the involvement of any 

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other Defendant (which Defendant must describe if he knows or should 

know due to his own involvement); (d) describe in detail whether and how 

Defendant is in compliance with each Section of this Order; and 

(e) provide a copy of each Order Acknowledgment obtained pursuant 

to this Order, unless previously submitted to Plaintiffs.

2. Additionally, Defendant must: (a) identify all telephone numbers and all 

physical, postal, email, and Internet addresses, including all residences;

(b) identify all business activities, including any business for which 

Defendant performs services whether as an employee or otherwise and any 

entity in which Defendant has any ownership interest; and (c) describe in 

detail Defendant’s involvement in each such business, including title, role, 

responsibilities, participation, authority, control, and any ownership.

B. For 10 years after entry of this Order, Defendant must submit a compliance

notice, sworn under penalty of perjury, within 14 days of any change in the following:

1. Defendant must report any change in: (a) any designated point of contact; 

(b) the structure of any corporation or any entity that Defendant has any 

ownership interest in or control, directly or indirectly, that may affect 

compliance obligations arising under this Order, including: creation, 

merger, sale, or dissolution of the entity or any subsidiary, parent, or 

affiliate that engages in any acts or practices subject to this Order.

2. Additionally, Defendant must report any change in: (a) names, including

aliases or fictitious names, or residence addresses; or (b) titles or roles in 

any business activity, including any business for which Defendant 

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performs services whether as an employee or otherwise and any entity in 

which Defendant has any ownership interest, and identify the name, 

physical address, and any Internet address of the business or entity.

C. For a period of 10 years, Defendant must submit to the Commission and 

the Maine AG notice of the filing of any bankruptcy petition, insolvency proceeding,

or similar proceeding by or against Defendant within 14 days of its filing.

D. Any submission to the Commission or the Maine AG required by this Order 

to be sworn under penalty of perjury must be true and accurate and comply with 

28 U.S.C. § 1746, such as by concluding: “I declare under penalty of perjury 

under the laws of the United States of America that the foregoing is true and 

correct. Executed on: ________” and supplying the date, signatory’s full name, 

title (if applicable), and signature.

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to 

DEBrief@ftc.gov or sent by overnight courier (not the U.S. Postal Service) to: 

Associate Director for Enforcement, Bureau of Consumer Protection, Federal 

Trade Commission, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580. 

The subject line must begin: FTC v. XXL Impressions LLC et al., and the number 

X170021.

F. Unless otherwise directed by a Maine AG representative in writing, all 

submissions to the Maine AG pursuant to this Order must be sent by 

overnight courier (not the U.S. Postal Service) to: Office of the Attorney General 

of Maine, Consumer Protection Division, 111 Sewall Street, 6th Floor, Augusta, 

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ME 04330. The subject line must begin: Order in re State of Maine v. 

XXL Impressions LLC et al. and must identify the Court and docket number of 

this Order as ordered by the Court.

X.

RECORDKEEPING

IT IS FURTHER ORDERED that in connection with the sale of any Covered Product, 

Defendant must create certain records for 10 years after entry of the Order, and retain each such 

record for 5 years. Specifically, Defendant must, for any business that Defendant is a majority 

owner or controls, directly or indirectly, must create and retain the following records:

A. Accounting records showing the revenues from all goods or services sold, all 

costs incurred in generating those revenues, and the resulting net profit or loss;

B. Personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person’s: name; address; telephone numbers; job title 

or position; dates of service; and (if applicable) the reason for termination;

C. Complaints and full or partial refund requests, whether received directly or 

indirectly, such as through a third party, and any response;

D. All records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Commission and the Maine AG; and

E. A copy of each unique advertisement or other marketing material.

XI.

COMPLIANCE MONITORING

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant’s

compliance with this Order:

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A. Within 14 days of receipt of a written request from a representative of 

the Commission or the Maine AG, Defendant must: submit additional 

compliance reports or other requested information, which must be sworn under 

penalty of perjury; appear for depositions; and produce documents for inspection 

and copying. Plaintiffs are also authorized to obtain discovery, without further 

leave of court, using any of the procedures prescribed by Federal Rules of Civil 

Procedure 29, 30 (including telephonic depositions), 31, 33, 34, 36, 45, and 69.

B. For matters concerning this Order, the Plaintiffs are authorized to

communicate directly with Defendant. Defendant must permit Plaintiffs’ 

representatives to interview any employee or other person affiliated with 

Defendant who has agreed to such an interview. The person interviewed may 

have counsel present.

C. Plaintiffs may use all other lawful means, including posing, through their

representatives, as consumers, suppliers, or other individuals or entities, to 

Defendant or any individual or entity affiliated with Defendant, without the 

necessity of identification or prior notice. Nothing in this Order limits the 

Commission’s lawful use of compulsory process, pursuant to Sections 9 and 20 of 

the FTC Act, 15 U.S.C. §§ 49, 57b-1. Nothing in this Order limits the Maine AG’s

lawful use of compulsory process, pursuant to section 211 of the Maine UTPA, ME. REV.

STAT. tit. 5, § 211. Defendant hereby consents to the disclosure by the Maine AG to any 

law enforcement agency and any representative of the State of Maine of any material or 

information produced by Defendant pursuant to section 211 of the Maine UTPA, whether 

produced before or after the date of this Order.

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XII.

RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court shall retain jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order.

IT IS SO ORDERED this ___ day of ____________, 2017.

__________________________________

United States District Court Judge

IT IS SO STIPULATED this 14th day of August, 2017.

DAVID C. SHONKA

Acting General Counsel

 

/s/ James A. Prunty

James A. Prunty

David P. Frankel

Federal Trade Commission

600 Pennsylvania Avenue, NW

Washington, D.C. 20580

Telephone: 202-326-2438, 2812

Facsimile: 202-326-3259

Email: jprunty@ftc.gov

dfrankel@ftc.gov

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION

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IT IS SO STIPULATED this 14th day of August, 2017.

JANET T. MILLS

Attorney General, State of Maine

/s/ Brendan F.X. O’Neil

Brendan F.X. O’Neil

Linda J. Conti

Assistant Attorney General

Office of the Attorney General of Maine

6 State House Station

Augusta, Maine 04333-0006

Telephone: 207-626-8842, 8591

Facsimile: 207-624-7730 

Email: brendan.oneil@maine.gov

IT IS SO STIPULATED this 14th day of August, 2017.

/s/ Ronald Jahner

Defendant Ronald Jahner, pro se

480 Banyan Tree Lane

Buffalo Grove, Illinois 60089

Telephone: 773-294-9521

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