PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

________________________________________________ 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

______________________________________________ 

COMPLAINT COUNSEL’S OPPOSITION TO 

MOTION TO AMEND ANSWER AND CROSS MOTION TO AMEND COMPLAINT 

 Through a new motion attempting to plead “no contest” to portions of the Complaint, 

Respondents now seek—for a second time—to terminate this case on terms they dictate, and 

without unequivocally admitting all material allegations. However, exactly as their last attempt 

exceeded what the Rules permit, see No. 6006007 (Feb. 1, 2021) (denying motion), 

Respondents’ second try violates Rule 3.12(b)(2)’s requirement that they unequivocally admit 

that “all” material facts in the Complaint are “true.” (Emphasis added.) Additionally, 

Respondents continue to assert affirmative defenses disputing facts and the Commission’s ability 

to issue relief—although Rule 3.12(b)(2) does not authorize affirmative defenses. Because 

Respondents’ proposed partial nolo contendre amendment challenges several material facts and 

preserves the right to challenge others later, their motion must be denied. 

 However, even if their motion could be granted, which it cannot, conditions would have 

to be imposed because litigation would continue concerning Respondents’ remaining affirmative 

defenses, the scope of relief, and potential findings (which Respondents reserve the right to 

propose). First, Complaint Counsel should be permitted to submit an amended Complaint with 

additional detail relevant to these issues. Second, Respondents’ ambiguous proposed 

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amendment obscures which alleged facts they allegedly no longer contest. To avoid unnecessary 

litigation concerning what (if anything) Respondents have conceded, they must be ordered to 

resubmit their Answer, responding to the Complaint’s allegations specifically, paragraph-byparagraph. Third, the ALJ should permit discovery concerning any remaining factual issues; it is 

unfair to allow Respondents to propose findings of fact while disallowing discovery on those 

same facts. 

 Separately, regardless of the resolution of Respondents’ motion, Complaint Counsel’s 

cross-motion to amend the Complaint should be granted. See CCX-A. The amendment will 

facilitate a determination on the merits because it provides greater notice. See Rule 3.15(a)(1). 

However, because the amendment adds only details, not new theories, counts or defendants, it 

falls “reasonably within the scope of the original complaint[.]” Id. Therefore, this tribunal can 

grant the motion without certifying it to the Commission. See id. Furthermore, because 

Respondents have not served any discovery, the proposed amendment is not unduly prejudicial. 

BACKGROUND

 To dodge discovery likely to reveal that Respondents knew they lacked substantiation for 

disease claims they aggressively made to consumers in poor health, Respondents sought to 

impose a “contested stipulated cease-and-desist” order on Complaint Counsel. See Order, No. 

6006007. After the ALJ denied Respondents’ “novel” request made without “any case or other 

precedent,” id. at 3, Respondents moved to amend their answer, ostensibly to admit certain 

unspecified allegations while maintaining or obfuscating their position concerning others. 

Notably, Respondents motion emphasizes that they are simply “elect[ing] not to contest” 

allegations rather than admitting their truth. Motion at 2; see also id. (discussing their “election 

to not contest”); id. at 3 (Respondents have “elected not to contest” allegations). 

 Respondents also underscore their “concern that this election to not contest the 

allegations may be misconstrued” as, they imply, a genuine admission to the allegations. See id. 

at 2. Respondents then provide reasons for their decision not to contest certain allegations—

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none of which admit the truth of the allegations. Instead, Respondents complain they cannot 

contest the facts in the Complaint for various reasons including that administrative litigation is 

not “fair, impartial, or constitutional.”1 Id. at 3. Respondents also purport to lack “resources to 

continue this fight,” thereby implying that, with greater resources, they could disprove the 

Complaint’s allegations. Id. Finally, Respondents cite “additional material reasons” for their 

attempted “no contest” plea, but they “cannot disclose those reasons at this time” because they 

concern their “former legal counsel,” id. at 4, whom Respondents have repeatedly identified to 

Complaint Counsel as responsible for the claims their advertising makes. 

 Respondents’ motion attaches a proposed Answer that (incorrectly) asserts that 

Respondents admit the Complaint’s material allegations, but tellingly does not specify which 

allegations they consider material. Furthermore, Respondents assert affirmative defenses that 

challenge or preserve the right to challenge facts critical to the Complaint: 

 The proposed Answer contends the case is moot because, purportedly, “all 

alleged conduct (i.e., marketing and advertising) referenced in the 

Complaint ceased more than a year prior to the filing of the Complaint and 

will not recur in the future.” Proposed Answer at 2. Thus, the Answer 

contests important factual allegations necessary to maintain this action. 

See id. (“[T]he FTC Act does not grant the FTC the authority to seek a 

cease and desist order under these [factual] circumstances.”). 

 Although the Complaint alleges—as it must under 15 U.S.C. § 45—that 

this action is “in the public interest,” see Complaint at 1, Respondents’ 

proposed Answer contends that the matter is “not in the public interest,” 

Proposed Answer at 2. Of course, the FTC cannot maintain an action not 

“in the public interest.” See id. at 2 (disputing that the action is “in the 

public interest,” which is “required”). 

 The proposed Answer asserts that administrative hearings are 

unconstitutional and unlawful for many reasons. In this regard, the 

Answer preserves Respondents’ ability to challenge any admissions or nocontest positions both on appeal in this matter, see 15 U.S.C. § 45(c), and 

in any subsequent case under Section 19, 15 U.S.C. § 57b(a)(2). 

 

1

 Contrary to Respondents’ accusations, respondents prevail when Complaint Counsel 

fails to prove its case. See, e.g., McWane, Inc., No. 9351, 2014 WL 556261, *1-*2 (Jan. 30, 

2014) (dismissing six of seven counts, including two on which the ALJ found liability); Benco 

Dental, No. 9379 (Oct. 15, 2019) (ALJ finding that Complaint Counsel failed to prove case 

against one respondent; Complaint Counsel did not appeal). 

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As discussed below, the absence of unequivocal admissions to material facts makes 

Respondents’ motion insufficient under 16 C.F.R. § 3.12(b)(2).2 

LEGAL STANDARDS 

Unlike Federal Rule 15, “which requires that leave to amend be freely granted, FTC Rule 

3.15(a) provides that ‘appropriate’ amendments ‘may’ be allowed, upon such conditions as will 

avoid prejudice to the parties and the public interest, if the amendments will facilitate a 

determination on the merits.” Daniel Chapter One, 2009 WL 871702, *2 (Mar. 9, 2009) 

(quoting 16 C.F.R. § 3.15(a)(1)). Answers may contain affirmative defenses if the respondent 

contests the Complaint’s allegations. See Rule 3.12(b)(1)(i). However, Rule 3.12(b)(2) concerns 

circumstances in which the “allegations of complaint are admitted,” and contains no provision 

permitting defenses. 

Regarding Complaint Counsel’s proposed amendment, the ALJ may allow amendments 

that will facilitate this matter’s determination and are “reasonably within the scope of the original 

complaint.[]” 16 C.F.R. § 3.15(a)(1). Amendments that do not add new legal theories are 

“reasonably within the scope[.]” See, e.g., Century 21 Commodore Plaza, 89 F.T.C. 238, *1 

(1977) (amendments permissible if they “clarif[y] allegations of the complaint or add[] examples 

of practices already alleged”) (citation omitted); Capitol Records Distrib. Corp., 58 F.T.C. 1170, 

*3 (1961) (amendments likely appropriate when they “relate only to details” and do not “cover 

any new or different practices”). 

 2

 Additionally, on February 23, Respondents filed a “corrected” meet-and-confer 

compliance certificate that effectively concedes they failed to meet-and-confer. Specifically, at 

1:20 PM on Friday, February 12, before President’s Day weekend, Respondents asked to confer 

about this motion. CCX-B. Complaint Counsel offered to confer immediately after the 

holiday—on the next business day—but Respondents filed on February 12 anyway. See id. 

Respondents subsequently offered to confer about their already-filed motion, but counsel must 

certify that he has already conferred before filing. See Rule 3.22(g) (counsel must represent that 

she “has conferred”); Scheduling Order ¶ 4 (same). 

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ARGUMENT 

I. Respondents’ Motion Should Be Denied or, Alternatively, Granted Conditionally. 

A. Respondents Have Improperly Asserted Affirmative Defenses Rather Than 

Unequivocally Admitting All Material Facts. 

1. Respondents Improperly Assert Affirmative Defenses. 

Rule 3.12(b) only permits respondents to assert affirmative defenses if the “allegations of 

complaint are contested.” See 16 C.F.R. § 3.12(b)(1) (permitting affirmative defenses); id. at § 

3.12(b)(2) (making no provision for defenses). Because the proposed Answer asserts defenses 

that Rule 3.12(b)(2) does not authorize, the Respondents’ motion must be denied. 

2. Respondents Deny Material Facts. 

Respondents have not satisfied Rule 3.12(b)(2)’s requirement that the answer admit “all 

of the material allegations [in the Complaint] to be true” because their affirmative defenses 

challenge at least two critical facts. First, Respondents deny that this action “is in the public 

interest,” Proposed Answer at 2—a jurisdictional fact. See 15 U.S.C. § 45. Second, as noted 

above, Respondents contend that this matter is moot. See Proposed Answer at 2. Alleged 

mootness is always material because the Commission cannot order any relief if the matter is truly 

moot, see, e.g., TRW, Inc. v. FTC, 647 F.2d 942, 954 (9th Cir. 1981), and mootness is a fact 

question, see, e.g., South Carolina State Bd. of Dentistry, No. 9311, 2004 WL 1814165, *18 

(July 28, 2004) (“The issue of whether this case is moot raises a question of disputed fact[.]”). 

Accordingly, Respondents have not admitted all material facts. 

3. Respondents Have Not Unequivocally Admitted That the Complaint’s 

Allegations Are True. 

Rule 3.12(b)(2) requires judicial admissions, or declarations “for the purpose of 

dispensing with proof of formal matters or of facts about which there is no real dispute.” 

U.S. Energy Corp. v. Nukem, Inc., 400 F.3d 822, 833 n.4 (10th Cir. 2005); see also Heritage 

Bank v. Redcom Labs., 250 F.3d 319, 329 (5th Cir. 2001) (defining the elements of a judicial 

admission generally consistent with Rule 3.12(b)(2)’s requirements, including that the admission 

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concern “facts essential to the theory of recovery” and upon “which a judgment for the opposing 

party can be based”). Importantly, such admissions must be unequivocal. See, e.g., In re 

Teleglobe Commc’ns Corp., 493 F.3d 345, 377 (3d Cir. 2007) (citation omitted) (“[A]dmissions 

must be unequivocal.”); Meehancombs Glob. Credit v. Caesars Entm’t Corp., 162 F. Supp. 3d 

200, 212 (S.D.N.Y. 2015) (statement not a judicial admission when not “unequivocal[]” in part 

because party also made contrary statements). However, the proposed Answer’s constitutional 

and statutory affirmative defenses preserve Respondents’ ability to challenge factual findings 

based on the Complaint that they nominally suggest they no longer contest. Opting not to 

contest facts now while preserving the ability to challenge them later is not an admission at all, 

let alone an “unequivocal” one. Furthermore, Respondents accompany their proposed Answer 

with a brief “explain[ing]” their admissions in a manner that suggests their nominal admissions 

are insincere. See Motion. at 2. Because Respondents’ strategic nolo contendre approach admits 

nothing unequivocally, the ALJ should deny their motion for this reason as well. 

B. Alternatively, the ALJ Should Impose Conditions on Respondents’ 

Amendment. 

1. Complaint Counsel Should Also Receive Leave To Amend. 

If Respondents were permitted to amend, which the law does not allow, Complaint 

Counsel should be allowed to amend as well. See 16 C.F.R. § 3.15(a)(1) (ALJ may impose 

conditions). Importantly, Respondents reserve their right to submit proposed findings of fact and 

law—and, as explained above, Respondents assert affirmative defenses. Thus, if Respondents 

are allowed to amend, considerable litigation regarding potential findings and relief remains. Cf. 

Mutual Constr., 87 F.T.C. 621, *10 (1976) (after respondent stipulated that complaint’s 

allegations were true, the issue of “the scope of the remedy” remained). Complaint Counsel’s 

amendment contains additional factual allegations and detail relevant to the remaining factual 

disputes—the public interest at issue, alleged mootness, and the scope of relief. See CCX-A. In 

short, because these factual issues remain if Respondents’ motion is granted, Complaint Counsel 

should be permitted to amend the Complaint to address these issues. 

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2. Respondents Should Be Required To Identify Which Allegations They 

Admit. 

Because Respondents’ proposed Answer states only that Respondents no longer contest 

“material” facts without answering the Complaint paragraph-by-paragraph, it is impossible to 

determine which allegations Respondents no longer contest. This, in turn, will complicate the 

continuing litigation over proposed findings and the scope of relief as the parties inevitably 

dispute whether Respondents have admitted particular facts. Accordingly, if Respondents were 

allowed to amend, such permission must be conditioned on Respondents resubmitting a proposed 

Answer specifying which facts they no longer contest. 

3. Discovery Should Be Permitted Regarding the Remaining Issues. 

Finally, Complaint Counsel must be granted discovery concerning all remaining issues 

(public interest, alleged mootness, scope of relief). As discussed above, it is unclear which facts 

Respondents no longer contest, and Respondents intend to propose findings of fact. As 

Complaint Counsel’s pending motions to compel make clear, Respondents have stone-walled 

discovery. It is impractical and unfair to permit Respondents to propose findings concerning 

remaining issues without affording Complaint Counsel the opportunity to take discovery on the 

subjects those findings address. Such a position essentially allows any Respondent to block 

discovery and cross examination, while continuing to contest the facts alleged. Accordingly, the 

ALJ should permit discovery to continue concerning all remaining issues. 

II. The ALJ Should Grant Complaint Counsel Leave To Amend. 

Regardless of how the ALJ resolves Respondents’ pending motion, the parties will 

litigate the public interest at stake, alleged mootness, and the scope of relief—including facts that 

support the broad relief Complaint Counsel seeks. Accordingly, Complaint Counsel seeks leave 

to file an Amended Complaint, which adds factual allegations related to these issues. See CCXA. These new allegations derive substantially from information (albeit limited) that Respondents 

have disclosed within the past month. CCX-B. Importantly, the amendment will “facilitate a 

determination on the merits,” see Rule 3.15(a)(1), by providing greater notice regarding what 

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Complaint Counsel will prove.3 Additionally, the amendment falls “within the scope of the 

original complaint,” id., because it only adds details, not new theories or practices, see, e.g., 

Century 21, 89 F.T.C. 238 at *1, Capitol Records, 58 F.T.C. 1170 at *3. 

Notably, Respondents have served no discovery to Complaint Counsel or third parties, 

CCX-B, and more than nine weeks remain before fact discovery closes. See, e.g., Nat’l Rifle 

Ass’n v. Cuomo, 480 F. Supp.3d 404, 413 (N.D.N.Y. 2020) (no undue prejudice where “the 

cross-motion to amend has been made . . . approximately three months after the filing of the 

original complaint and before discovery has commenced”); Fulk v. Hartford Life Ins., 839 F. 

Supp. 1181, 1184 (M.D.N.C. 1993) (no prejudice where “motion to amend was filed before 

discovery had begun and plaintiff [was] not alleging any new causes of action”).4 Because 

Respondents have not served discovery and ample time remains to do so, and because the 

amendment adds no new theories, there is no undue prejudice to Respondents. 

Conclusion 

 For all the aforementioned reasons, the ALJ should deny Respondents’ motion and grant 

Complaint Counsel’s cross-motion. 

 3 Additionally, the amendment adds facts related to the scope of relief. As Complaint 

Counsel has already informed Respondents, Complaint Counsel will seek to ban Respondents 

from the supplement industry. 

4

 The fact that Respondents have already moved to terminate this matter (on terms they 

dictate) is immaterial to whether the proposed amendments are unduly prejudicial—they are not. 

See, e.g., Miramontes v. Mills, No. 11-cv-8604, 2015 WL 13609449, *10 (C.D. Cal. May 18, 

2015) (fact that motion to amend followed motion for summary judgment “does not weigh 

against granting leave to amend”). 

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Respectfully submitted, 

s/ Jonathan Cohen 

 Elizabeth J. Averill 

 Jonathan Cohen 

 Federal Trade Commission 

 600 Pennsylvania Ave, NW, CC-9528 

 Washington, DC 20580 

 (202) 326-2993 (Averill); -2551 (Cohen) 

 Eaverill@ftc.gov; Jcohen2@ftc.gov 

 (202) 326-3197 (facsimile) 

 Complaint Counsel 

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CERTIFICATE OF COMPLIANCE 

 Pursuant to Paragraph 4 of the ALJ’s December 14, 2020 Scheduling Order, the 

undersigned counsel represents that he and co-counsel Elizabeth Averill met and conferred on 

February 23, 2021 with Respondents’ counsel, Joel Reese, in a good faith effort to seek 

Respondents’ agreement to the proposed Amended Complaint. 

 

 s/ Jonathan Cohen 

 Jonathan Cohen 

 Federal Trade Commission 

 600 Pennsylvania Ave, NW, CC-9528 

 Washington, DC 20580 

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CERTIFICATE OF SERVICE 

I certify that I served a copy of Complaint Counsel’s Opposition and Cross-Motion on 

counsel for the Respondents on February 24, 2021 via electronic mail. 

Joel Reese 

Joshua Russ 

Reese Marketos LLP 

750 N. Saint Paul St., Suite 600 

Dallas, TX 75201 

Joel.reese@rm-firm.com 

Josh.russ@rm-firm.com 

I also served one electronic copy via the Administrative E-Filing System and one electronic 

courtesy copy to the Office of the Secretary via email to ElectronicFilings@ftc.gov. 

I served one electronic courtesy copy via email to the Office of the Administrative Law Judge: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

600 Pennsylvania Ave, N.W., Room H-110 

Washington, DC 20580 

 s/ Jonathan Cohen 

 Jonathan Cohen 

 Federal Trade Commission 

 600 Pennsylvania Ave, NW, CC-9528 

 Washington, DC 20580 

 (202) 326-2551; jcohen2@ftc.gov 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

________________________________________________ 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

______________________________________________ 

[PROPOSED] ORDER GRANTING COMPLAINT COUNSEL’S 

CROSS-MOTION TO AMEND THE COMPLAINT 

This matter having come before the Chief Administrative Law Judge on February 24, 

2021, upon Complaint Counsel’s Cross-Motion To Amend the Complaint, it is hereby 

ORDERED that: 

1. The Motion is GRANTED; and 

2. Complaint Counsel’s proposed Amended Complaint is accepted. 

ORDERED: ______________________ 

D. Michael Chappell 

Chief Administrative Law Judge 

Date:

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

________________________________________________ 

In the Matter of

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC.

______________________________________________ 

COMPLAINT COUNSEL’S EXHIBIT A (CCX-A)

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Rebecca Kelly Slaughter, Acting Chair 

Noah Joshua Phillips 

Rohit Chopra 

Christine S. Wilson 

________________________________________________ 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

________________________________________________ 

COMPLAINT 

 The Federal Trade Commission, having reason to believe that Health Research 

Laboratories (“HRL”), a limited liability company, Whole Body Supplements (“WBS”), a 

limited liability company, and Kramer Duhon, individually and as an owner and officer of HRL 

and WBS (collectively, “Respondents”), have violated the provisions of the Federal Trade 

Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges: 

1. Respondent HRL is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

2. Respondent WBS is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

3. Respondent Kramer Duhon is the Chief Operating Officer and managing member of HRL 

and the Chief Operating Officer and managing member of WBS. Individually or in concert with 

others, he controlled or had the authority to control the acts and practices of HRL and WBS, 

including the acts and practices alleged in this complaint. His principal office or place of 

business is 16250 Knoll Trail Drive, Dallas, TX 75248. 

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4. The FTC and Respondents HRL and Kramer Duhon signed a Stipulated Final Judgment 

and Order (“Order”) entered by U.S. District Judge Jon D. Levy on January 16, 2018 in FTC and 

State of Maine v. Health Research Laboratories, et al., 2:17-cv-00467 (Dkt. 15). Section III of 

the Order prohibits Respondents from making “any representation about the health benefits, 

safety, performance, or efficacy” of a dietary supplement, food, or drug “unless the 

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

and rely 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.” Section III further 

provides that “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.” 

5. Following entry of the Order, Respondents advertised, labeled, offered for sale, sold, and 

distributed, or caused to be distributed a number of dietary supplement products to consumers. 

HRL sold, among other products, Black Garlic Botanicals, The Ultimate Heart Formula, and 

Neupathic. WBS sold BG18, among other products. Black Garlic Botanicals, BG18, The 

Ultimate Heart Formula, and Neupathic are “food” and/or “drugs” within the meaning of 

Sections 12 and 15 of the Federal Trade Commission Act. 

6. Respondents’ advertisements for Black Garlic Botanicals, BG18, The Ultimate Heart 

Formula, and Neupathic included representations that the products would effectively prevent, 

reduce the risk of, cure, treat, or mitigate cardiovascular disease, atherosclerosis, hypertension, or 

diabetic neuropathy without adequate substantiation to support the representations. 

7. The acts and practices of Respondents alleged in this complaint have been in or affecting 

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

Black Garlic Botanicals 

8. HRL began selling Black Garlic Botanicals in November 2016 and continued to sell it 

following entry of the Order and after the filing of a contempt motion against Respondents in 

FTC and State of Maine v. Health Research Laboratories, LLC, et al., 2:17-cv-00467-JDL. HRL 

continued to sell the product to consumers through at least January 2021, despite the filing of the 

contempt motion and the Complaint in this administrative proceeding. 

9. Each capsule of Black Garlic Botanicals contains 600 mg of the active ingredient black 

garlic, and the recommended dosage is two capsules a day. HRL sells a one-month supply of 

Black Garlic Botanicals for $39.95, plus shipping and handling. HRL also sold the product to 

consumers in other quantities and at different prices. 

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10. HRL has disseminated or has caused to be disseminated advertising and promotional 

materials for Black Garlic Botanicals in multi-page mailers sent to consumer residences and on 

company websites. Following entry of the Order, HRL disseminated or has caused to be 

disseminated more than 800,000 mailers to consumer residences in the United States and 

Canada. HRL continued to disseminate these mailers as late as August 2019 despite 

Respondents’ awareness that the FTC was investigating whether advertising for Black Garlic 

Botanicals violated the Order. 

11. The Black Garlic Botanicals mailer attached as Exhibit A opens with the following 

representations and depictions: 

 Exhibit A (Black Garlic Botanicals mailer) 

This front-page content is followed by additional descriptions of the dangers of 

cardiovascular disease. For example, the second and third pages display a banner across 

the top, which states, “Cardiovascular Disease: #1 cause of Death in the world, especially 

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the U.S.!” A banner at the bottom states, “There’s a miraculous natural solution that can 

help – find out what it is!!” 

The mailer continues with the following statements about the efficacy of black garlic in 

reducing arterial plaque, blood pressure, and cholesterol: 

 

 BLACK GARLIC WORKS WITH YOUR BODY 

 Cholesterol: Black Garlic helps maintain healthy cholesterol 

levels. 

 Clotting: Black Garlic supports healthy platelet aggregation, 

which can help to keep blood circulating and works against 

clotting. 

 Supports and helps maintain healthy blood pressure levels to 

combat risks. 

 Healthy Arteries 

Plaque build-up in arteries can lead to unhealthy heart conditions. Black 

Garlic helps keep blood vessels barrier-free to create smooth flow, which 

could address symptoms of fatigue. It may also inhibit calcium binding, 

which is responsible for arterial plaque formation. 

 Want Healthy Blood Pressure & Cholesterol? Black Garlic helps maintain 

healthy blood pressure, cholesterol and triglyceride levels. 

 BLACK GARLIC 

A BREAKTHROUGH FOR 

 Cholesterol 

 Blood Sugar 

 Blood Pressure 

 The Heart 

 The Brain 

 “I made the switch to Black Garlic Botanicals and within the span of 3 

months my LDL levels have reduced from 300 to 150. This product 

works!” ~ Gerald W. 

 “I now have my blood pressure under control with Black Garlic 

Botanicals. This is a quality product!” ~ Rolf M. 

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BG18 

12. WBS began selling BG18 in August 2017 and continued to sell it after entry of the Order 

and after the filing of a contempt motion against Respondents in FTC and State of Maine v. 

Health Research Laboratories, LLC, et al., 2:17-cv-00467-JDL in December 2019. 

13. BG18 has identical ingredients to Black Garlic Botanicals. Each capsule contains 600 

mg of the active ingredient black garlic, and the recommended dosage is two capsules a day. 

WBS sells a one-month supply of BG18 for $44.95, plus shipping and handling. WBS also sold 

the product to consumers in other quantities and at different prices. 

14. WBS has disseminated or has caused to be disseminated advertising and promotional 

materials for BG18, including multi-page mailers and content on company websites. Following 

entry of the Order, WBS disseminated or caused to be disseminated more than 400,000 mailers 

to consumer residences in the United States and Canada. WBS continued to disseminate these 

mailers as late as June 2019 despite Respondents’ awareness that the FTC was investigating 

whether advertising for BG18 violated the Order. 

15. An example of a mailer for BG18 is attached as Exhibit B. 

The front page of the attached BG18 mailer features an image of a caduceus and, a 

photograph of a doctor in a white coat, and states “Black Garlic has shown an amazing 

power to improve heart and cardiovascular health, maintain normal cholesterol levels, 

boost your immune system. And MUCH MORE!” The mailer continues with the 

following representations: 

 Black Garlic is a proven miracle for . . . Cholesterol . . . Hypertension . . . 

Your Heart. 

 [Black Garlic] can help reverse plaque build-up in arteries – not just slow 

it down. Black Garlic keeps blood vessels barrier-free to create a smooth 

blood flow and alleviates symptoms of fatigue. It also strongly inhibits 

calcium binding, which is responsible for plaque build-up. 

 Reduces Blood Pressure and Cholesterol. . . Black Garlic helps reduce 

high blood pressure and lowers high levels of bad cholesterol and 

triglycerides. 

 “My blood pressure has also been lowered. I recommend this product 

because IT WORKS!” ~ Lorraine T. 

 On the following page, the brochure poses this question and answer: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

6 

 Exhibit B (BG18 mailer). 

 Yes, Black Garlic is a true miracle for cardiovascular health! Just 1 

capsule knocks down cholesterol and high blood pressure within days. It 

can also unblock, clean, and strengthen your arteries. 

 The cardio-protective effect of black garlic. . . Black garlic can also 

improve your lipid profile, an important factor in protecting against 

cardiovascular problems. 

The Ultimate Heart Formula 

16. HRL began selling The Ultimate Heart Formula (“UHF”) in November 2008 and 

continued to sell it following entry of the Order and after the filing of a contempt motion against 

Respondents in FTC and State of Maine v. Health Research Laboratories, LLC, et al., 2:17-cv00467-JDL. HRL continued to sell the product to consumers through at least January 2021, 

despite the filing of the contempt motion and the Complaint in this administrative proceeding. 

17. UHF contains Vitamins C, E, and B12 as well as garlic extract (25 mg), Tetrasodium 

EDTA (40 mg), Ubiquinol (CoEnzyme Q-10) (5 mg), and Nattokinase (10 mg). The 

recommended dosage is 20 drops or 1ml, twice per day. HRL sold a one-month’s supply of 

UHF for $39.95, plus shipping and handling. HRL also sold the product to consumers in other 

quantities and at different prices. 

18. HRL disseminated or caused to be disseminated advertisements for UHF, including 

multipage mailers and company websites. Following entry of the Order, HRL disseminated or 

caused to be disseminated more than 200,000 mailers to consumer residences in the United 

States and Canada. 

19. An example of a mailer for UHF is attached as Exhibit C, which contains the following 

statements and depictions on its first and second pages: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

7 

 Exhibit C (The Ultimate Heart Formula mailer). 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

8 

 Exhibit C (The Ultimate Heart Formula mailer, p.2) 

 These depictions and representations are followed by a number of additional claims, 

 including: 

 Instead, right before you is a simple, safe, inexpensive, non-painful and 

preventative option that could help you say goodbye to your heart surgeon 

and avoid an angioplasty. 

 Our Ultimate Heart Formula can help support a healthy heart, healthy 

cholesterol and healthy blood pressure. As blockages in your veins and 

arteries become clear, you can experience better blood circulation – 

resulting in more energy, better sleep, sharper mental clarity and better 

health. 

 The Ultimate Heart Formula also contains a powerful, clot-busting agent! 

 The Ultimate Heart Formula is an all-natural combination of 19 powerful 

herbs and essential nutrients that counter the causes of poor cardio health. 

The Ultimate Heart Formula’s unique “Senior Formula” is made with 

ingredients specifically shown to help improve the effects of a weakened 

heart, clogged arteries, high blood pressure and high cholesterol for older 

people! 

 With our Ultimate Heart Formula ...You get it ALL ... Amazing heart and 

artery protection ... without side effects! 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

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 Yes, with the Ultimate Heart Formula, a lifetime of plaque build up could 

disappear before you know it! The artery-flushing power of this formula 

does not even require a doctor’s visit or stay in the hospital! 

Neupathic 

20. Beginning in August 2016, HRL also sold a dietary supplement called Neupathic. HRL 

continued to sell the product following entry of the Order and after the filing of a contempt 

motion against Respondents in FTC and State of Maine v. Health Research Laboratories, LLC, 

et al., 2:17-cv-00467-JDL. Neupathic contains the following active ingredients: Vitamins E (30 

IU), B1 (33.3 mg), B6 (33.3 mg), B12 (16.7 mcg), and folate (266.7 mcg), and Evening Primrose 

Oil (666.7 mg). The recommended dosage is two capsules per day. HRL sold a one-month’s 

supply of Neupathic for $39.95, plus shipping and handling. HRL also sold the product to 

consumers in other quantities and at different prices. 

21. HRL has disseminated or caused to be disseminated advertising and promotional 

materials for Neupathic, including multi-page mailers and content on company websites. 

Following entry of the Order, HRL disseminated or caused to be disseminated more than 

400,000 mailers to consumer residences in the United States and Canada. HRL continued to 

disseminate these mailers as late as June 2019 despite Respondents’ awareness that the FTC was 

investigating whether their advertising for Neupathic violated the Order. 

22. An example of a mailer is attached as Exhibit D, which contains the following depictions 

and statements on the first page: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

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 Exhibit D (Neupathic mailer). 

 The mailer continues inside with additional claims: 

 If you have diabetic nerve pain, you could suffer with any or all of the 

symptoms below. 

 Shooting pain 

 Burning 

 Pins and needles 

 Electric shock-like pain 

 Extra sensitivity 

 Numbness 

 Throbbing 

 Tingling 

 Stinging 

 Stabbing 

 Radiating 

 Neupathic was specifically formulated with 6 distinct nutrients to help 

 address ALL these issues and more. 

 A “perfect” nerve pain supplement that was formulated from the ground 

up to improve your circulation and ease the numbness, tingling, itching, 

burning and swelling from excess fluid trapped in your legs. 

 Take this easy step towards normal, pain free legs and feet again! Nondrug ... proven ingredients. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

11 

Exhibit D (Neupathic mailer, p. 11). 

 Respond now if your nerve pain is driving you crazy! You’ll get 

completely natural, real relief from your discomfort. All natural 

Neupathic is 100% effective and safe to use every day! Remember, it has 

[sic] shown to help reverse damaged nerves to help you feel great all day 

and all night. 

 

 “Great reduction of pain. No more nerve pain in my feet. I also hardly 

notice any leg cramps. This product is great!” — Ruth J. 

 “Neupathic is a great ‘miracle-like product’ which starts working the very 

first day you use it. Then it continues to control your pain every day. My 

feet have began [sic] to feel normal. Neupathic has improved my life. My 

nerve pain is gone and I will continue to take Neupathic until my 

numbness is gone too!” — Gloria R. Id. 

23. Respondents did not have competent and reliable scientific evidence to support the 

representations in their advertisements. Further, they relied in part on advice from consultants 

and/or advisors who did not have appropriate qualifications or expertise to evaluate 

substantiation for the representations. 

Count I 

Respondents’ Unsubstantiated Claims Related to Black Garlic Botanicals 

(HRL and Duhon) 

24. In connection with the advertising, promotion, offering for sale, or sale of Black Garlic 

Botanicals, HRL and Kramer Duhon have represented, directly or indirectly, expressly or by 

implication, that Black Garlic Botanicals: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

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b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque; 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

25. The representations set forth in Paragraph 24 were not substantiated at the time the 

representations were made. 

Count II 

Respondents’ Unsubstantiated Claims Related to BG18 

(WBS and Duhon) 

26. In connection with the advertising, promotion, offering for sale, or sale of BG18, WBS 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

BG18: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

27. The representations set forth in Paragraph 26 were not substantiated at the time the 

representations were made. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

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Count III 

Respondents’ Unsubstantiated Claims Related to UHF 

(HRL and Duhon) 

28. In connection with the advertising, promotion, offering for sale, or sale of UHF, HRL 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

UHF 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

29. The representations set forth in Paragraph 28 were not substantiated at the time the 

representations were made. 

Count IV 

Respondents’ Unsubstantiated Claims Related to Neupathic 

(HRL and Duhon) 

30. In connection with the advertising, promotion, offering for sale, or sale of Neupathic, 

HRL and Kramer Duhon have represented, directly or indirectly, expressly or by implication, 

that Neupathic: 

a. Cures, treats, or mitigates diabetic neuropathy including by improving blood 

circulation, or eliminating or alleviating diabetic nerve pain and discomfort. 

31. The representations set forth in Paragraph 30 were not substantiated at the time the 

representations were made. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

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Violations of Sections 5 and 12

32. The acts and practices of Respondents as alleged in this complaint constitute unfair or 

deceptive acts or practices, and the making of false advertisements, in or affecting commerce in 

violation of Sections 5(a) and 12 of the Federal Trade Commission Act. 

NOTICE 

You are notified that on July 13, 2021, at 10:00 a.m., at the Federal Trade Commission 

offices, 600 Pennsylvania Avenue, NW, Room 532-H, Washington, DC 20580, an 

Administrative Law Judge of the Federal Trade Commission will hold a hearing on the charges 

set forth in this Complaint. At that time and place, you will have the right under the Federal 

Trade Commission Act to appear and show cause why an order should not be entered requiring 

you to cease and desist from the violations of law charged in this Complaint. 

You are notified that you are afforded the opportunity to file with the Federal Trade 

Commission (“Commission”) an answer to this Complaint on or before the 14th day after service 

of the Complaint upon you. An answer in which the allegations of the Complaint are contested 

must contain a concise statement of the facts constituting each ground of defense; and specific 

admission, denial, or explanation of each fact alleged in the Complaint or, if you are without 

knowledge thereof, a statement to that effect. Allegations of the Complaint not thus answered 

will be deemed to have been admitted. 

If you elect not to contest the allegations of fact set forth in the Complaint, the answer 

should consist of a statement that you admit all of the material facts to be true. Such an answer 

will constitute a waiver of hearings as to the facts alleged in the Complaint and, together with the 

Complaint, will provide a record basis on which the Commission may issue a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. In 

such answer, you may, however, reserve the right to submit proposed findings of fact and 

conclusions of law under FTC Rule § 3.46. 

Failure to answer timely will be deemed to constitute a waiver of your right to appear and 

contest the allegations of the Complaint. It will also authorize the Commission, without further 

notice to you, to find the facts to be as alleged in the Complaint and to enter a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. 

The Administrative Law Judge will hold an initial prehearing scheduling conference not 

later than 10 days after the answer is filed by the last answering Respondent. Unless otherwise 

directed by the Administrative Law Judge, the scheduling conference and further proceedings 

will take place at the Federal Trade Commission, 600 Pennsylvania Avenue, NW, Room 532-H, 

Washington, DC 20580. Rule 3.21(a) requires a meeting of the parties’ counsel as early as 

practicable before the prehearing scheduling conference, but in any event no later than 5 days 

after the answer is filed by the last answering Respondent. Rule 3.31(b) obligates counsel for 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

15 

each party, within 5 days of receiving a Respondent’s answer, to make certain initial disclosures 

without awaiting a formal discovery request. 

 Moreover, the Commission has reason to believe that, if the facts are found as alleged in 

the Complaint, it may be necessary and appropriate for the Commission to seek relief to redress 

injury to consumers. Such relief could be in the form of restitution for past, present, and future 

consumers and such other types of relief as are set forth in Section 19(b) of the Federal Trade 

Commission Act. The Commission will determine whether to apply to a court for such relief on 

the basis of the adjudicative proceedings in this matter and such other factors as are relevant to 

consider the necessity and appropriateness of such action. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

16 

NOTICE OF CONTEMPLATED RELIEF 

 Should the Commission conclude from the record developed in any adjudicative proceedings 

in this matter that Respondents have violated or are violating Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a) and 52, the Commission may order such relief against Respondents as is 

supported by the record and is necessary and appropriate, including but not limited to: 

a. A prohibition on any representation that Respondents’ products cure, treat, mitigate, 

prevent, or reduce the risk of any disease. 

b. A prohibition on representations about the health benefits, safety, efficacy, or the 

performance of Respondents’ products unless those representations are supported by 

competent and reliable scientific evidence. 

c. A prohibition on misrepresentations regarding tests, studies, or other research. 

d. A requirement that Respondents preserve records relating to competent and reliable 

clinical tests or studies. 

e. A requirement that Respondents send appropriate notification of the order to all affected 

customers. 

f. A requirement that Respondents cancel any automatically recurring orders for Black 

Garlic Botanicals, BG18, UHF, or Neupathic for any existing customer who was first 

charged before the issuance of the Complaint. 

g. A requirement that Respondents will not use, sell, rent, lease, or transfer any identifying 

information related to any customer who paid money to any Respondent for Black Garlic 

Botanicals, BG18, UHF, or Neupathic prior to the issuance of the Complaint. 

h. A requirement that, for a period of time, Respondents send acknowledgments of the order 

to the Commission. 

i. A requirement that, for a period of time, Respondents create and preserve certain records 

demonstrating compliance with the order. 

j. A requirement that, for a period of time, Respondents provide notice of all new business 

activity to the Commission. 

k. A requirement that Respondents file periodic compliance reports with the Commission. 

l. A requirement that Respondents’ compliance with the order be monitored for a term to be 

determined by the Commission. 

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17 

m. Any other relief appropriate to correct or remedy the effects of Respondents’ deceptive 

practices or of any or all of the conduct alleged in the complaint. 

 

IN WITNESS WHEREOF, the Federal Trade Commission has caused this complaint to be 

signed by its Secretary and its official seal to be hereto affixed at Washington, DC, this 24th day 

of February 2021. 

By the Commission. 

 April J. Tabor 

 Acting Secretary 

SEAL: 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Exhibit A 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
IMPORTANT ISSUE: DON’T MISS THIS HEART HEALTH NEWS!

Every 90 seconds, someone 

dies from heart disease in 

the U.S. — are you next?

1 in 7 people die from heart disease. 

Only 10% of people survive cardiac arrest if treated by 

emergency medical services. What are you waiting for? 

GOOD NEWS: Everything you need to 

know about your heart health is in this issue!

HEALTH RESEARCH LABS – Breaking News Cardiovascular Issue

In This Heart Health Breaking News Issue: 

Cardiovascular disease — #1 cause of death in the world! . . . . . . . 2 

Diabetes & venous insufficiency are additional risks . . . . . . . . . . . . 6 

Overweight? Belly fat creates new risk factors . . . . . . . . . . . . . . . . 7

Why don’t people suffer from high cholesterol in Japan? . . . . . . . . . 8 

One Man’s Personal Journey Created an Empire of Good Health . . 10 

Black Garlic all over the news!....

PRODUCT 

NOW 

AVAILABLE

HRL004984 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
2 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Cardiovascular Disease: #1 cause of 

635,000 people in the U.S. have 

their first heart attack each year! 

Cardiovascular disease is the leading cause of 

global death, causing 17.3 million deaths per 

year — a number that’s expected to grow to 

more than 23.6 million by 2030. 

The American Heart Association, the Centers 

for Disease Control and Prevention, the 

National Institutes of Health, and many 

government sources keep trying to save lives, 

but this global affliction seems to spare only the 

Japanese! 

Despite smoking and blood pressure levels 

comparable to that in Western countries, what 

are the Japanese doing differently? 

Black Garlic. 

This discovery in 2001 has turned out to be 

a really powerful elixir for the heart and the 

whole cardiovascular system.

LIFESTYLE CHOICES THAT INCREA 

Unhealthy 

Diet

3 High in saturated 

fat, trans fat, and 

cholesterol

3 Too much sodium 

can raise blood 

pressure levels

Physical 

Inactivity

3 Not getting enough 

physical activity can 

increase the

chances of obesity, 

high blood pressure, 

high cholesterol, 

and diabetes

Obesity

3 Excess body fat 

is linked to higher 

“bad” cholesterol 

& triglyceride 

levels, and can 

lead to high blood 

pressure and 

diabetes

HEART ATTACK WARNING SIGNS

1 Pain or Discomfort in Chest

2 Lightheadedness, Nausea, Vomitting

3 Jaw, Neck, or Back Pain

4 Pain or Discomfort in Arm or Sholder

5 Shortness of Breath

Characteristics you can’t control: 

age, sex, race, or ethnicity. All of these 

affect your risk for heart disease.

There’s a miraculous natural solution 

HRL004985 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 3

 Death in the world, especially the U.S.!

Watch Out for Damage & Death to Heart Tissue 

Atherosclerosis is the hardening of arteries and formation of 

plaque, caused by LDL Cholesterol. 

This deadly plaque grows silently & slowly. 

Are your arteries getting more clogged every minute? 

Slow-growing cholesterol plaque may never cause any symptoms — 

even with severely blocked arteries — and can suddenly rupture!

SE YOUR RISK FOR HEART ATTACK.

Too Much Alcohol

3 Drinking too much alcohol 

can raise blood pressure 

levels & the risk for heart 

disease. It increases

levels of triglycerides, 

a form of cholesterol, 

that can harden your 

arteries

Tobacco Use

3 Cigarette smoking can damage the heart & blood 

vessels, which increases your risk for heart conditions 

such as atherosclerosis and heart attack. Nicotine

raises blood pressure, and carbon monoxide reduces 

the amount of oxygen that your blood can carry

3 Exposure to other people’s secondhand smoke 

can increase the risk for heart disease even for 

nonsmokers

Where does plaque come from? 

Excess cholesterol can form plaque between layers of artery walls, making it 

harder for your heart to circulate blood. Plaque can break open and cause clots. 

• If a clot blocks an artery that feeds the brain, it causes a stroke.

• If a clot blocks an artery that feeds the heart, it causes heart attack. 

What Cholesterol Do I 

Have to Worry About? 

Cholesterol can’t dissolve in the 

blood. It must be transported 

through your blood by carriers 

called lipoproteins. There are 2 

types: 

LDL (Bad) Cholesterol 

• Contributes to plaque (a 

thick, hard deposit that can 

clog arteries & make them 

less flexible). If a clot forms 

and blocks a narrowed artery, 

heart attack or stroke can 

result. 

• Plaque buildup can also 

narrow an artery supplying 

blood to the legs. 

HDL (Good) Cholesterol 

• Helps remove LDL cholesterol 

from the arteries, carrying

it back to the liver, where it’s 

broken down and passed from 

the body. 

 that can help – find out what it is!! 

HRL004986 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
4 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Diabetes is a major risk factor for heart disease. 

2 out of 3 people with diabetes die of heart disease or stroke. 

What truths do you need to know? 

• 47% of Americans are unaware that diabetes can 

lead to heart disease. 

• 58% don’t know that it can affect one’s sex life. 

• 28% don’t believe diabetes is a serious disease. 

• 35% don’t believe diabetes can affect the eyes. 

• Having high amounts of sugar in the bloodstream 

develops into fat that clogs, narrows, and 

inflames the blood vessels, causing

them to wear and tear. 

Diabetes or prediabetes puts you at inc

58% of patients 

with diabetes 

have erectile 

dysfunction

What is venous insufficiency — and 

why do you need to worry about it? 

Leg and foot ulcers in diabetic patients have a common 

underlying cause: venous insufficiency. 

Chronic venous insufficiency occurs when the leg veins do 

not allow blood to travel back to the heart. These valves that 

are not working properly can cause blood in the legs to pool. 

If left untreated, chronic venous insufficiency can cause pain, 

swelling, and leg ulcers. The condition can be disabling. 

Venous insufficiency is most commonly caused by a blood 

clot. Alert a healthcare provider as soon as possible for certain 

symptoms. Do not wait!

1. Coronary Artery Disease: Sudden 

cholesterol plaque ruptures and clotting 

causes blocked arteries. Heart muscle 

dies. A heart attack happens. 

2. Cerebrovascular Disease: Plaque ruptures 

in one of brain’s arteries causing stroke. 

3. Peripheral Arterial Disease: Blocked 

arteries in the legs causes pain walking & 

can lead to amputations. 

 3 main kinds of 

 cardiovascular disease :

HRL004987 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 5

NERVOUS SYSTEM 

— Lethargy

— Stupor 

With Black Garlic you achieve healthy blood 

pressure levels, enhancing your energy, and 

governing the regulatory system.

EYES 

— Blurred vision 

Black Garlic keeps the blood 

vessels healthy, including the 

tiny blood vessels that nourish 

the retina.

LIVER & KIDNEYS 

— Liver toxins

Black Garlic supports a healthy 

liver, to enhance detoxification 

capabilities that are essential 

when taking medications. 

GASTRIC 

— Nausea

— Vomiting

— Abdominal pain 

— Obesity 

Black Garlic helps protect your digestive system.

reased risk for heart disease & stroke.

Diabetes and cardiovascular disease go hand-in-hand.

Black Garlic is the all-natural maintenance plan for your heart and all of your vital functions.

68% of people with diabetes die of heart disease or stroke.

Maintaining healthy blood sugar and glucose levels can be a 

constant struggle. Lowering blood sugar levels helps to prevent 

damage to your kidneys, blood vessels, skin, and eyes. 

BLACK GARLIC WORKS WITH YOUR BODY: 

•	Cholesterol: Black Garlic helps maintain healthy 

cholesterol levels.

•	Clotting: Black Garlic supports healthy platelet 

aggregation, which can help to keep blood 

circulating and works against clotting. 

•	Supports and helps maintain healthy blood 

pressure levels to combat risks. 

MAIN SYMPTOMS OF DIABETES

HEART 

— People with diabetes have conditions 

which exacerbate risk for developing heart 

disease, including high blood pressure, abnormal 

cholesterol levels, and lack of physical activity. 

Black Garlic nourishes your heart muscle. 

FEET & LEGS 

— Circulation difficulties

can cause neuropathy (nerve 

damage) and poor circulation 

can lead to ulcers, bone loss, 

and deformity. 

Black Garlic helps maintain 

healthy blood sugar levels 

and supports vital circulation 

throughout your body.

SEXUALITY 

— Men with erectile 

dysfunction often later learn 

they have diabetes. Sexual 

problems can indicate nerve 

damage, blocked arteries, and 

even imbalanced hormones. 

Black Garlic supports a healthy circulatory system to 

encourage a vibrant sex drive and erections.

“I feel energized. I feel 

like I have a whole new 

body! I can now climb steps 

the normal way, I am no 

longer tired all the time, 

and my mind seems clearer. 

Black Garlic Botanicals 

really does MAKE YOU 

FEEL GREAT! I really 

think it should be part of 

your everyday regimen for 

wellness.” ~ Delores L.*

HRL004988 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
6 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

The Miraculous Solution in Japan: 

Black Garlic

The Aomori prefecture is the garlic capital of Japan, producing 

as much as 80% of the total garlic in the nation. What it’s really 

famous for is the fermented Black Garlic. 

Popular in Asian cuisine, Black Garlic is fermented under 

highly controlled conditions for 3-4 weeks, which is what gives 

it its black color. While many are hesitant to try it because of its 

color, it is actually easy to digest and odorless, can be enjoyed 

as a preserved fruit, used as a spice or condiment, and the 

garlic skin can be used to brew tea. 

A Natural Supplement Improving Lives

Black Garlic gained popularity after Hirosaki University 

professor, Jiniti Sasaki, showed that Black Garlic had a 

beneficial effect on harmful cells in the body — the same 

research was conducted using white garlic and did not yield the 

same results. 

The Japanese Smoke & Have High Bl

Japanese have lowest incidence of heart 

What are your treatment options 

for heart disease?

SENSIBLE DIET 

Being overweight is just 1 factor that puts you 

at risk for heart disease. Losing weight doesn’t

guarantee lowering cholesterol, blood pressure, 

or triglycerides (a type of fat in your blood)

• Ornish Diet: Very little wiggle room for food 

choices, only 10% of calories can come from 

fat, & can be pricey for produce, whole grains, 

and fish

• Mediterranean Diet: Not a structured 

diet, so it’s up to you to figure out on your own 

how many calories you need to eat to lose or 

maintain weight & how active you’ll be

• Vegan Diet: No animal products allowed, 

even dairy and eggs. Takes work to ensure

you get sufficient amounts of key nutrients

Limited options for eating out, may require a 

lot of time to prep for meals

PHYSICAL ACTIVITY 

Recommended exercise at least 30 minutes a 

day, 5 days a week in order to improve heart 

health

GENETICS

Many heart conditions are passed on from 

generation to generation. While you can’t change

your genes, you can learn your family history 

and prepare your body and your mind for any 

potential upcoming challenges with natural 

preventative solutions

STATINS 

Medications with possible side effects: muscle 

pain, liver damage, kidney failure, even death

Black Garlic is studied for: 

3 Increasing energy

3 Strengthening the immune 

system

3 Promote anti-aging effects

3 Enhancing recovery from 

fatigue

3 And, improving restfulness

HRL004989 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 7

ood Pressure — Yet, Low Cholesterol!

 attacks in the world. Why? 

Black Garlic is the...

“perfect human health food.”

Black Garlic antioxidant capacity is the 

best in more than 300 kinds of food!

Black Garlic must be fermented in precise conditions for over 60 days

with increasing efficacy the longer it ferments. It contains 18 kinds of 

amino acids needed by the human body. 

Healthy Arteries

Plaque build-up in arteries can lead to unhealthy heart conditions.

Black Garlic helps keep blood vessels barrier-free to create smooth flow, 

which could address symptoms of fatigue. It may also inhibit calcium 

binding, which is responsible for arterial plaque formation.

Prevent Health Crises Before They Take Hold

Black Garlic is being tested in both population studies and clinical trials 

to see how effective it is at preventing and treating the root cause of many 

key health issues.

Want Healthy Blood Pressure & Cholesterol?

Black Garlic helps maintain healthy blood pressure, cholesterol and 

triglyceride levels.

Overweight? Belly Fat Creates New Risk Factors

Some fat is a normal function of the human body and helps to regulate 

blood sugar. But belly fat in particular loses sensitivity to insulin, and can 

often trigger the body’s natural function of pumping insulin. This can 

cause metabolic syndrome, which may further develop into high blood 

pressure, excess bad cholesterol, and even type 2 diabetes.

Lowest Heart Disease in Japan

Rate per 100,000 

population

Fermentation Process of Garlic

BLACK GARLIC

A BREAKTHROUGH FOR:

3 Cholesterol

3 Blood Sugar

3 Blood Pressure

3 The Heart

3 The Brain

HRL004990 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
8 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Letter from the Owner of Health Research Labs

I’m Jesse Duvell, and I live with my wife and daughter in Dallas, Texas. Four years ago, 

I was diagnosed with two types of cancer. I feared my life being cut short, and I wasn’t 

ready to go.

The doctors prescribed a number of strong medications before I even started radiation 

treatment, which left me sicker than I had ever been in my life. My body started to shut 

down. I was in my early fifties and couldn’t figure out where I went wrong. 

Growing up, my dad told me every day that if I can’t change my circumstances, I could 

always change my mind. 

So I read books, I talked with experts and learned everything I could to stay at the cutting 

edge of supplements, where modern science meets the old ways of healing. I changed 

what I ate, though I still enjoyed some pizza and beer on the weekends. I started walking 

around outdoors again. I changed my work schedule to allow more time to relax and 

spend time with my family. I sought out the best supplements I could find to help my 

healing journey. 

Today, my cancer is in complete remission. 

My results may not be your results, but it changed my life. I knew 

I had to do something to help other people around me suffering. 

I was in a unique position. I had already created Health Research 

Labs, but now, I wanted to ensure we source top quality 

supplements, then price them so that everyone has access 

to them. 

Yet, we needed to get the word out for real preventative care!

I wanted to now make sure people knew how they could change their lives for the better. 

I’m so convinced our products work, I offer a 100% money back guarantee if you don’t 

love the product, no questions asked. 

I only hope I can be of service and that my products can help you spend your time 

here on earth living comfortably with the people you love. 

With warm regard,

Jesse Duvell, Owner of Health Research Labs

HRL004991 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 9

Move from the fear of dying to the joy of living!

People with heart failure take an average of 7 prescription medications a day. 

Each additional medication increases the risk of side effects or dangerous drug interactions. 

Some may be serious enough to require going to the hospital. Some 

can even bring on heart failure! 

What types of drugs can exacerbate heart failure? 

• Used to treat diabetes, pain, psychiatric conditions, cancer, and 

other conditions. 

Natural heart regimens can help to balance cholesterol levels and 

blood pressure, and maintain a healthy heart: 

• Mayo Clinic notes that cholesterol-lowering supplements and 

natural remedies can be helpful for heart disease factors. 

• Natural remedies can be accessed without a prescription! 

More than 100 drugs pose extra dangers 

if you’re at risk for heart failure.

NATURAL BLACK GARLIC IS ALL OVER THE NEWS!

“The evidence is ‘quite compelling’ 

that the supplement seems to help 

mitigate cardiac risk factors, such as 

high cholesterol and blood pressure.” 

~ David L. Katz, director of Yale 

University’s Yale-Griffin Prevention 

Research Center

“[Black Garlic is] high in 

S-allyl cysteine, or SAC, a 

sulfur-based compound that 

dissolves in water and is easy 

for the body to metabolize. SAC is an antioxidant, a type 

of molecule believed to reduce damage to cells.” 

~ Wall Street Journal

“Black Garlic helps to repair age damaged 

skin. Uniquely colored due to its fermentation 

process, Black Garlic contains twice the 

antioxidants as regular garlic... and 

restores skin cells damaged by the 

aging process.” ~ Dr. Oz

“Newly developed Black garlic has 

made a sensational debut with a 

strong immune system enforcement... 

anti-oxidant activity”

~ Journal of Life Sciences

“I feel very good since I started Black 

Garlic about 3 months ago. My energy 

level has improved very much to the 

point that I feel I can do so much 

more than I used to.” ~ R. Mcneil*

“I told my church friends about 

Black Garlic — it makes me feel 

so much better and helps keep 

my blood circulation at super 

healthy levels.” ~ Milan L.*

“I am now more alert 

and have a better sense 

of well-being. I know 

that I have a good 

product!” ~ Victor P.*

* These are Real Results from Real Users of Black Garlic Botanicals! Individual results may vary. We guarantee you will love this product or your money bac

HRL004992 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
10 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Black Garlic Can Impr

People just like you are thriving like never before!

“I made the switch to Black Garlic Botanicals 

and within the span of 3 months my LDL levels 

have reduced from 300 to 150. This product 

works!” ~ Gerald W.*

Black Garlic

has all the essentials

to help your heart.

MINERAL CONTENT:

Sodium (Na) 

Potassium (K) 

Magnesium (Mg)

Calcium (Ca) 

Iron (Fe) 

Zinc (Zn) 

AMINO ACID CONTENT:

Isoleucine 

Luecine

Lysine

Methionine 

Histidine 

Phenylalanine 

Tryptophan 

Valine 

Arginine 

Alanine 

Asparagine 

Glutamine 

Glysine 

Proline 

Serine 

Tyrosine 

Cystine 

From 

Fatigue to 

Fitness

Results may vary depending on your 

body type. We are excited to see what 

Black Garlic can do for you! 

We guarantee you will love this 

product or your money back.

An

Active Sex

Life

READY TO KEEP YOUR

BLOOD SUGAR LEVELS HEALTHY? 

“My doctor told me to come back when 

I’m sick. I feel great and I no longer 

need to run to the doctor! Thank you 

Health Research Labs!” 

~ Lloyd G.*

“My blood sugar numbers are 

now close to normal and I 

haven’t had a headache since 

I started using Black Garlic 

Botanicals” ~ Gus H.*

“I am no longer as tired and I 

can even climb the stairs much 

easier. My mind also seems 

clearer. Black Garlic Botanicals 

really does make you feel great! 

I really believe that you should 

take this product every day for 

your well being!” ~ Delores S.*

HRL004993 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 11

Qualities of Black Garlic

3 Antioxidants

3 Helps Maintain Healthy 

Blood Pressure 

3 Heart Protection

3 Supports Healthy & 

Balanced Cholesterol

3 Anti-Bacterial

3 Circulation Support

3 Strong Immunity 

ove Your Entire Life...

You can improve your life now, too!

Try it free risk-free today — only 

pay if you see results. 

More Black Garlic Benefits

HEALTHY WEIGHT MANAGEMENT

“A thicker waistline increases heart attack risk,” says 

Nieca Goldberg, MD. Stomach fat is linked to high 

blood sugar, increased blood pressure, and raised levels 

of triglycerides, all of which are major risk factors for 

heart disease. Belly fat is also called visceral fat, which is 

closer to internal organs, and can be related to hormones 

— that’s why many women start seeing their tummies 

thicken during menopause. 

Black Garlic is an excellent addition to a healthy diet 

and exercise for overall health. Sustainable weight 

management is the most sensible and practical option for 

anyone concerned about heart health. 

IMMUNITY BOOSTER

Black Garlic addresses inflammation, boosts immune 

function, and is toxic to invading bodies. The allicin in 

garlic, a sulfur-rich compound, is a powerful weapon 

against harmful conditions and promotes overall health. 

Black Garlic contains twice the antioxidant punch of fresh 

garlic, because of the fermentation process. This makes it 

an ideal health booster for every season.

AGE DEFYING 

Black Garlic is a great energizer and helps prolong

a healthy lifestyle! It also helps repair damaged skin 

with double the amount of antioxidants than regular 

garlic. Like rust attacking metal, free radicals eat away 

at cells and destroy them, causing the aging effect. 

Black Garlic positively impacts cellular immunity, 

causing a rejuvenated appearance.

DETOX

Black Garlic acts as a blood purifier and cleanses 

the body in general. It has antibacterial, anti-fungal 

properties that create a hostile environment for 

Candida albicans and can decrease bacteria linked to 

stomach ulcers. Your gut is also known as your second 

brain, because the health of your gastrointestinal 

system is extremely important to your overall 

wellbeing. Black Garlic supports cell regeneration 

and alkalinizes your body to form a habitat resistant 

to takeover. It also features abundantly rich oxygen for 

healthy cell activity, so you can discover even more 

wonderful overall health with just 2 capsules per day! 

Finally Get 

the Rest You 

Deserve

“Black Garlic helps 

me sleep better at 

night — I can’t believe 

how rested I feel in 

the mornings now!” 

~ Michelle M.*

“Black Garlic 

Botanicals 

relieved the 

pain in my legs 

and feet. My 

circulation is 

better than it 

has been in 

a long time. 

This product is 

amazing and I 

can’t live without it.” ~ John I.*

Just 2 capsules 

a Day!

HRL004994 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
12 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

“Research has proven garlic has powerful health benefits, 

but you must take it in high concentrations to have a 

noticeable effect. 

That’s why Black Garlic Botanicals supplement is such a 

miraculous solution. Rather than eat 8-12 cloves per day, 

you simply need to take 2 capsules per day.

If you’re serious about protecting your heart and arteries 

with a natural solution, it’s important to act now, because 

there really is no time to waste. 

I believe your life is important, which is why I’ve arranged 

for you to try premium quality Black Garlic Botanicals – 

free of risk – for 60 days, so you can see for yourself how it 

can improve your entire well-being and appearance almost 

instantly. 

As a health professional, I highly recommend 

you try Black Garlic Botanicals today.

To your wellness, 

Richard Cohen, MD, Anti-Aging Specialist

American Academy for Advancement in Medicine

The products offered in this publication are not intended to cure or diagnose health problems. These statements have been evaluated by the Food & Drug 

Administration. If you are currently on cardiovascular medication, do not discontinue. Speak to your physician before changing any medical regimen.

 PREMIER BLACK GARLIC FROM JAPAN

Richard Cohen, M.D.

 Anti-Aging Specialist

“Over 50? Black Garlic Botanicals is a daily essential supplement.”

60 Days

Customer

Satisfaction

Guarantee

We promise you’ll be satisfied with 

your purchase — or you don’t pay. 

Health Research Labs products are made 

with premium quality standards and the 

latest scientific research to ensure you’re 

happy with the results. 

Here’s what we promise:

• Premier natural products developed by the best international 

scientific team of experts, doctors, 

and health professionals that meet 

rigid quality specifications.

• Unparalleled rebates to ensure the 

smartest investment in your health. 

•An opportunity to try our products 

FREE, so that you can experience 

life-changing results firsthand. 

Call 1-888-461-0599

NOW to order

For the next 7 days, you can SAVE UP TO $289 on a powerful 

natural booster that may change your life. 

Health Research Labs 

“I now have my 

blood pressure 

under control 

with Black Garlic 

Botanicals. This is 

a quality product!” 

~ Rolf M.*

“Black Garlic 

gives me more 

energy, more boost, 

and less stress. 

This product is 

excellent!!” 

~ Bobby Mitchell*

“My acid 

reflux is a 

thing of the 

past!” 

~ Eldon K.*

HRL004995 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 13

1 person in the U.S. dies every 40 seconds from these factors!

YOUR RISK-FREE TRIAL OFFER GUARANTEE

Get up to $289 in savings! 

Through this RISK FREE TRIAL GUARANTEE, HRL undertakes to send you the 

Black Garlic Botanicals regimen of your choice with the assurance you can try it for 

2 full months without any financial risk on your part. 

As such, you can freely judge for yourself, for 2 months, the exceptional natural benefits

of Black Garlic Botanicals on your entire body. If by some extraordinary reason, during 

this trial period of 2 months, you felt that the benefits of Black Garlic Botanicals was 

disappointing, you simply return your order (even if the bottles are empty) along

with your invoice, within 60 days of your order and return it to the address on this 

order form. In this case, HRL undertakes to reimburse you the full purchase amount by 

mail, less shipping and handling, regardless of the duration of the treatment chosen and 

without asking any questions. 

With such a RISK-FREE TRIAL GUARANTEE, you can order the treatment of Black Garlic Botanicals

of your choice without hesitation: in case of dissatisfaction on your part, you don’t risk losing a single 

penny by ordering your RISK-FREE TRIAL of Black Garlic Botanicals. 

1 person in the U.S. dies every 40 seconds from these factors!

Are you at risk? 

o	You’re over 50.

o	You’re 10-20 lbs. overweight.

o	You smoke.

o	You drink 2 or more glasses of wine or beer per day.

o	You have a parent who has cardiovascular disease.

o	You have high LDL cholesterol or a total 

cholesterol higher than 200 mg/DL.

o	You have diabetes.

o	You do not exercise regularly.

o	You have a diet of rich foods.

o	You don’t sleep well.

DID YOU ANSWER “YES” to even one of these questions?

By answering “yes” to even one of these questions, your risk for heart disease 

is real and imminent.

If you fall into any of these categories, your risk is even higher!

o	You are a woman.

o	You are White, African-American, Hispanic, or Asian-American.

o	You have had cardiac arrest or experienced a heart attack before.

o	You live in the Southern part of the U.S.

HRL004996 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
14 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Choose from 4 Black Garlic Botanicals Value Packages: 

We at Health Research Labs believe your 

heart is of the utmost importance. That’s

why we’re offering incredible options for 

you to thrive like never before — at no risk! 

You receive an entire year’s supply of 

supplements and only pay if you’re 

completely satisfied

But, the only way you can benefit is if you 

take advantage of this offer now. After

seven days, we may not have it available 

anymore. Call to place your order now and

be sure you don’t miss out on unbelievable 

savings on this proven, best-in-class 

natural supplement

SUPER-INTENSIVE

6 Bottles ...

plus 6 Bottles FREE!

Save a TREMENDOUS $440!

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3 Bottles,

plus 3 Bottles FREE!

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ULTRA-INTENSIVE

2 Bottles,

plus 1 Bottle FREE!

Save $80!

INTENSIVE

1 Bottle 

Save $10!

3 FREE

6 FREE

1 FREE

Health 

Research 

Labs 

Diabetes Can Cause Nerve Pain & Tingling Numbness

Maintaining healthy blood sugar levels can help to stabilize conditions that in a diabetic state might 

damage your kidneys, blood vessels, skin, and eyes.

Common diabetic nerve pain symptoms include: shooting burning, pins and needles, numbness, 

electric shock-like throbbing, tingling, stinging, stabbing, radiating, and sensitivity to touch. 

Nurohealth features a groundbreaking formula that can dramatically: 

3 Promote healthy blood sugar

3 Promote increased wound healing

3 Promote healthy insulin sensitivity & production 

3 Promote healthy heart and blood vessels

3 Healthy blood sugar levels

3 Vigor and alertness

3 Healthy blood circulation

3 Healthy nerve endings

HUGE

SAVINGS

WHEN YOU ORDER

BOTH

Hurry! Limited-time offer for Black Garlic Botanicals customers 

only! Call 1-888-461-0599 to qualify or send in the order form.

CLAIM YOUR ULTIMATE DIABETIC NEUROPATHY STRATEGY

NEUPATHIC SUPPLEMENT — THE PERFECT COMPANION TO BLACK GARLIC BOTANICALS

FOR FASTEST 

SERVICE 

CALL TODAY!

1-888-461-0599

HRL004997 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 15

BLACK GARLIC BOTANICALS RISK-FREE REPLY FORM

Health Research Labs

165 Pleasant Avenue

South Portland, ME 04106

3 YES!I’m ready to live better and enjoy a higher quality of life 

with a healthy heart! Please send me the supply indicated below. 

❒ SUPER-INTENSIVE I get a 6 month supply, plus a 6 month bonus 

supply absolutely FREE! I pay only $189.95 plus $8.95 S&H (total of $198.9

That’s a total 12 month supply for only $198.90! That’s only 52¢ per day!

❒ MEGA-INTENSIVE I get a 3 month supply, plus a 3 month bonus 

supply absolutely FREE! I pay only $119.95 plus $7.95 S&H (total of $127.9

That’s a total 6 month supply for only $127.90! That’s only 65¢ per day

❒ ULTRA-INTENSIVE I get a 2 month supply, plus 1 month bonus 

supply absolutely FREE! I pay only $79.95 plus $6.95 S&H (total of $86.9

That’s a total 3 month supply for only $86.90! That’s only 88¢ per day

❒ INTENSIVE I get a 1 month supply at the very lowest price available! 

I pay only $39.95 plus $5.95 S&H (total of $45.90) for a 1 month sup

❒ BLACK GARLIC BOTANICALS TOTAL PACKAGE WITH 

NEUOPATHIC The “Complete” package for those people also concerned about 

overall health. Get everything in the “MEGA-INTENSIVE” package plus FREE S&H,

plus buy 3 months of Neuopathic for only $119.95 and get another 3 months FREE!

You save an incredible 50% off the regular price. Total price only $239.

Quantities Are Limited. 

Please Order By Next Tuesday! 1-888-461-0599

3 Ways to Place Your Order:

1. BY MAIL: Place your order with 

cash, check or credit card. Simply

detach this form and place it into the 

enclosed mailing envelope

2. BY PHONE: 

1-888-461-0599

3. ONLINE:

www.HRLsupplements.com

CALL

NOW

ORDERED BY: (PLEASE PRINT)

______________________________________________________________

Name

__________________________________________________________________________

Address

__________________________________________________________________________

City State Zip

__________________________________________________________________________

Email 

PAYMENT METHOD

❑ I have enclosed a check or money order payable to “HRL” for the amount of $_____________

❑ Please charge the full amount to my credit card

Credit Card Account Number Expiration Date (MO/YR) 

__________________________________________________________________________

Signature Daytime Phone

100% RISK FREE GUARANTEE Health Research Labs promises to provide you with only Pharmaceutical Grade supplements, doctor-formulated and manufactured in FDA Approved

Certified Good Manufacturing Process (CGMP) Labs in the USA. If you are not for any reason satisfied with the quality of any of our supplements, simply return the unused portion

within 60 days of receipt for a prompt, no questions asked full refund, less S&H. Pharmaceutical Grade, FDA Approved Laboratory CERTIFIED By Health Research Lab

$479 .90 $189.95

$239 .70 $119.95

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SAVE $289.45!

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SAVE $39.95!

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❒ RUSH PROCESSING: Add $4.95

❑ Please remove my name from future mailings

Subtotal

S&H

*RUSH Processing + $4.95

TOTAL

PRODUCT 

NOW 

AVAILABLE

HRL004998 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Healt

h Rese

c

Lab

BREAKING NEWS: The Amazing Discovery

from Japan That’s Improving Lives

3 See how this powerhouse directly affects your cells!3 Cleanse your body of unwanted toxins.3 Why you need to know about this 

“perfect human health food”.

2 easy capsules – 

big health benefits.

BLACK GARLIC

:

The Most Incredible 

‘Food’ For Your Body!

Worried about your blood sugar 

levels and cholesterol?

BGB4-US-A

Health Research Labs

165 Pleasant Avenue

South Portland, ME 04106

LIMITED TIME OFFER — ORDER TODAY!

LEARN MORE INSIDE 

PRODUCT 

NOW 

AVAILABLE

HRL004999 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Exhibit B

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0001 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0002 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0003 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0004 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
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FTC0006 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0007 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0008 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0009 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FTC0010 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
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FTC0015 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Exhibit &

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
“When it comes to a 

sudden heart attack...

What You 

Don’t Know 

CAN Hurt You!” Richard Cohen, M.D.

Scientific Advisor

Do you KNOW what YOUR arteries look like right now?

HEART HEALTH SAFETY UPDATE l SPECIAL HEART ATTACK RISK EDITION

Keeping your risk low and your HEART healthy is all about 

keeping your arteries CLEAR! See inside for help from a 

revolutionary, new, heart-helping liquid drop formula... 

SEE INSIDE to discover a natural nutrient that is up to 95% EFFECTIVE 

at maintaining clear arteries and reducing risk of a heart problem!

All Clear!

Uh Oh!

DANGER!

HRL005068 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
“If you want to AVOID it, I have 

good news about a revolutionary 

NEW and NATURAL treatment 

that can help keep your arteries 

clear and your mind at ease.”

If you don’t think a Heart Attack... Stroke... High Blood Pressure or other 

life threatening issues could ever happen to you... Please, think again.

Dear Friend,

I

’m sure you’d agree, there’s nothing funny 

about a heart attack.

As the #1 killer of men AND women in the 

U.S., if you haven’t given any thought to heart 

attack prevention, it’s time to get on board!

Unlike other common health problems 

related to aging, like low energy, sore joints, bad 

memory, an enlarged prostate or menopause... 

you can’t always FEEL or SEE a heart attack or 

stroke coming.

It can come out of nowhere, at any time.

And you don’t even have to be older. While it is

more common for people age 55+, the reality is it 

can happen to anyone, at any age.

As a medical doctor, I routinely encounter 

people who don’t fully understand that a heart 

attack or stroke is not all about their heart. It is 

more about their arteries. Your heart is not

usually the problem. You can have a strong, 

healthy heart and STILL suffer a serious, 

sudden heart attack or stroke.

Avoiding a heart 

attack is all about 

keeping your arteries 

clear, your cholesterol 

in check, your blood 

pressure low and your 

risk of a blood clot 

low... so accumulated 

plaque does not close 

off an artery or break 

off and cause a stroke.

Now there’s a new, improved twist 

on our most effective natural, 

heart-helping treatment.

Before I tell you what this amazing treatment 

is, I just want to mention that of course you can 

always undergo a medical procedure to clear out 

your arteries mechanically.

In fact, heart-related treatments are a huge 

profit center for hospitals and doctors. But like 

any procedure, they are expensive, invasive, 

time-consuming and risky.

2 l Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386

“It’s no secret... Heart Attack is the 

#1 killer of men and women.”

HRL005069 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Richard Cohen, M.D. is a 

nationally-recognized 

medical expert. As a specialist 

in nutritional medicine, he brings 

over two decades of experience in 

treating age-related illness.

He completed his undergraduate 

degree at Duke University with 

honors. And received his medical 

degree from Hahnemann Medical 

University in Philadelphia. Dr. Cohen 

is a member of the American College 

for the Advancement of Medicine.

Dr. Cohen’s expertise has earned him the 

attention of physicians and health 

professionals across the U.S. 

He has trained the American 

medical community on dietary 

issues for over 20 years. And 

recently, he was recognized as 

a leading authority in using 

diet, nutritional supplements 

and lifestyle to enhance 

well-being.

In recent years, he has helped 

develop a number of successful, 

innovative treatments like the Ultimate Heart 

Formula to help his patients eliminate a 

variety of health problems.

Meet Dr. Richard Cohen, M.D.

Instead, right before you is a simple, safe, 

inexpensive, non-painful and preventative 

option that could help you say goodbye to your 

heart surgeon and avoid an angioplasty.

As a doctor, I’ll never recommend surgery 

if I think there is a better way. And in this 

case, I do firmly believe there is a better, more 

natural and gentler way to help keep your 

heart strong and your arteries free and clear 

for greater peace of mind.

If you take this easy and safe step, and 

keep the blood inside your arteries moving 

fast and easy like it should...

n The risk of heart-related issues can be 

minimized and give you greater peace of mind.

n You could reduce your risk of surgery.

Be sure to take advantage of this

GREAT COMBO OFFER 

on page 15...

Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 l 3

(continued on page 5)

Hydroxin is a 3-in-1 anti-aging miracle 

that quickly regenerates every cell in 

your body and can help you 

live longer and healthier.

It will help you begin to 

eliminate premature aging and 

promote wellness everywhere in 

your body! You’ll slow the aging 

process, restore energy, improve 

cardiovascular health, help 

with great looking skin, relieve 

discomfort, and healthy brain 

function. And more!

It is the perfect companion product to Ultimate 

Heart Formula and offered 

at a deep discount!

Keep Reading for an Exclusive, 

Doctor-Approved Clear 

Artery Support Formula!

Great 

Combo 

Offer!

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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Even though it’s called a “Heart 

Blockage,” this term is commonly 

used to refer to coronary artery disease, 

a build up of plaque that “narrows” the inside of 

the arteries that supply your heart with blood.

An artery blockage, if severe enough can 

prevent your heart from getting the blood it needs 

to function, especially when more blood flow is 

required, such as during exercise. This can lead 

to chest pain and shortness of breath.

Tests can be used to see if there are sections 

of arteries that are so blocked that blood flow is 

at risk. However, these tests are not perfect, and 

in people known to be at high risk, the best way 

to directly assess a blockage is to look at a blood 

vessel or artery itself with an angiogram.

A moderate amount of blockage is in the 

40-70% range. Usually heart blockage in the 

moderate range does not cause significant 

limitation to blood flow or cause symptoms.

Severe heart blockage is typically greater 

than 70%. This degree of narrowing results in 

significantly reduced blood flow to the heart and 

can cause chest pain and shortness of breath.

And if there is 

a 100% blockage, 

this can stop blood 

flow and lead to 

a heart attack! If a 

heart attack victim is 

treated quickly, the 

blockage can be 

addressed surgically 

with a stent to allow 

blood flow to resume. 

However, if this 

treatment isn’t done within a few hours, then the 

heart can die, and cannot usually recover.

The other fatal risk is if part of a 

blockage breaks off and travels into the 

brain to cause a stroke.

A stroke occurs when the blood supply to 

your brain is interrupted or reduced and deprives 

your brain of oxygen and nutrients, which can 

cause brain cells to die.

A stroke can be caused by a blocked artery 

or the leaking or bursting of a blood vessel under 

pressure.

When it comes to your heart, as they 

say, an ounce of prevention goes a long 

way! You can do A LOT to support your 

heart health by taking the Ultimate Heart 

Formula! So don’t wait any longer.

Our Ultimate Heart Formula can help 

support a healthy heart, healthy cholesterol 

and healthy blood pressure.

As blockages in your veins and arteries become 

clear, you can experience better blood circulation 

— resulting in more energy, better sleep, 

sharper mental clarity and better health.

Inside a Blocked Artery...

A very dangerous situation to be in!

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n You could help maintain normal cholesterol 

and blood pressure.

n You could improve your circulation.

n You could reduce shortness of breath.

Now, I’m sure you’d agree, that is A LOT of 

worry and health risk you can leave behind!

And here’s how you can do it... By using 

our flagship heart health formula called the 

Ultimate Heart Formula.

I’ve seen for myself the powerful effect of 

the ingredients I’m about to show you. And 

as you’ll read on further pages, our Ultimate 

Heart Formula has had a huge effect on people 

like you, even some who thought they might 

die when conventional medicine could not 

help them...

And our Ultimate 

Heart Formula did!

Now, if you’re going 

to use this formula to 

help keep your heart 

strong and your arteries 

clear, then you should 

know a little bit about 

how it can help you. 

Take a look...

CoQ10 is the world’s 

most 

proven-powerful, heart-helping nutrient.

This heart and artery friendly miracle 

was first discovered in 1957. It’s called 

CoenzymeQ10 – or CoQ10 for short, and 

it is made naturally in your body.

To date, there have been more than 60 studies 

showing CoQ10’s beneficial effect on heart health, 

the results of which, were incredible!

Taking this powerful, natural nutrient every 

day can help significantly strengthen your heart 

Why Our Revolutionary 

Drop Formula Will Serve 

Your Heart Better.

(continued)

Cances are you 

may have taken a 

heart health formula 

in the past...

And chances are that 

formula was in the form of 

a pill or capsule.

However, our leading, 

Ultimate Heart Formula

is in the form of a drop that goes under 

your tongue. Here’s why...

Instant absorption... That’s what makes 

our formula so effective for so many people!

You see, when you take a capsule or pill, it 

has to pass through your stomach acid, which 

is strong enough to dissolve a razor blade!

So most pills and capsules don’t stand a 

chance to get into your blood stream where 

they can be carried to where they need to be.

Our liquid drops go right under 

your tongue to be instantly absorbed 

into your body, and can get right to work 

strengthening your heart and 

maintaining clear arteries.

Like so many thousands of 

others, you’ll love our Ultimate 

Heart Formula to not only help 

you feel better, but to also give 

you invaluable peace of mind.

You’ll know you are 

doing all you can to 

keep your cardio system 

running well! Reply now 

100% risk free for Ultimate 

Heart Formula instant 

absorption drops!

A “Heart 

Strong” 

Formula!

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and help prevent an unexpected heart attack.

For example, in one study, 100% of cardiologists, treating 806 patients for weakening hearts 

and loss of blood flow to the heart, reported 

“significant improvements” in their patients’ 

symptoms.

Two studies reported in the medical journal,

Pharmacotherapy, that 51% and 43% of people were 

able to get off blood-pressure and cardiovascular 

medication with the help of CoQ10 treatment.

In another CoQ10 study, reported in the 

medical journal, Clinical Investigator, 100% 

of patients with serious heart problems experienced an improvement in their symptoms. 

And 80% experienced beneficial bloodpressure levels.

Furthermore, in yet another study involving 

2,664 heart patients over a 3-month period, the 

results showed that 75% of people experienced 

The Ultimate Heart Formula also 

contains a powerful, clot-busting agent!

The Ultimate Heart Formula gives you 

the power of a Japanese soy plant 

called Natto, with a 1,000-year-old 

medicinal history! And recent scientific 

studies have shown it has the uncanny 

ability to liquefy blood-clots and help 

prevent them from occurring at all!

This is so important because 

even a blood-clot the size of a 

pin-head can be deadly!

Like EDTA and CoQ10, the 

results from the clinical studies carried 

out on Natto have been remarkable! For 

example, researchers from JCR Pharmaceuticals, 

Oklahoma State University, and Miyazaki Medical 

College, gave people 200-grams of Natto before 

breakfast. The result...

Natto was able to reduce the time it took 

their bodies to dissolve a dangerous blood-clot 

by 48% within just two hours of treatment. 

Plus, their bodies retained this enhanced ability 

to dissolve blood-clots for up to eight hours. 

And that’s not all...

In another study, performed by Miyazaki 

Medical College, people were given Natto. 

Within just two hours, their systolic blood 

pressure decreased, on average, from 

173mmHg to 155mmHg. And their diastolic blood 

pressure decreased from 101mmHg to 91mmHg.

And according to Dr. Martin Milner, a 

researcher of cardiology and pulmonary 

medicine at the Center for Natural 

Medicine in Oregon...

“Natto represents the most exciting development in the prevention and treatment of cardiovascular related problems. We have finally found 

a potent natural agent that can help thin and 

dissolve clots effectively, without side-effects.”

The bottom line is: According to the 

American Thrombosis Association, up to 

20-million cases of blood clot-related illnesses 

are reported each and every year. But now, 

thanks to Natto in the Ultimate Heart Formula, 

you have a proven safe way to help your body 

support healthy arteries.

(continued on page 8)

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We have been flooded with testimonials 

for our Ultimate Heart Formula!

“My blood pressure 

is normal.. Tastes good. 

I also have more energy 

and a more stable pulse.”* 

—John A. Jones

“Excellent Results. No Pain! Easy to Take! 

Thank you for the Ultimate Heart Formula. 

It gives me more energy. It’s easy to take, 

has no unwanted side effects. It makes life 

easier with no pain in my heart. I highly 

recommend the Ultimate Heart Formula 

to anyone who has heart problems.”* 

—Dawn Simoneau

“I have no heart problems 

since starting Ultimate 

Heart Formula many years 

ago. Thank God for the ad I 

read years ago. I am now 81 

and going strong. Sorry I’m 

bragging now.”* —Vicki Miles

“Most products that we send for through the mail 

do not do what is claimed. I had PVC’s which 

I hated so much. After using the Ultimate 

Heart Formula I feel great and am so 

happy.”* —Darlene H. Juhl

“I had occasional rapid heart 

beats and irregular heart beats. 

After taking Ultimate Heart 

Formula I feel great and 

have felt great since. I have 

been taking this product almost 

12 months. It’s easy to take and quick to work. 

Convenience. Taste. Results.”* 

—Fred Memmer

“Met my expectations. I like 

that it is taken orally. I have 

been free from chest pains 

since the start. It gives me 

confidence when I go to bed 

at night that I will awake to 

see another day. I am 85 and was diagnosed 

with mitral valve prolapse many years ago.”* 

—Diana Lessard

“Peace of mind. I no longer 

have to worry 

about heart 

problems.

My father 

did chelation for 

the heart.”* 

—Christine Robbins

“I feel more positive and more 

active. My arteries and veins 

are clear. I feel 50 years old.”* 

—Joan E. Johnson

Call Toll-Free 888-462-9386 for Ultimate Heart Formula instant absorption drops! 

*These are real results from real users of the Ultimate Heart Formula. Individual results may vary. We guarantee you will love this product or your money back.

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fewer skipped heartbeats and 63% experienced a 

reduction in irregular heartbeats.

And according to studies reported in the 

Cardiovascular Drugs Therapy medical journal, 

CoQ10 can improve the condition of 91% 

of patients who have suffered a disastrous 

interruption of blood-flow to the heart.

In even MORE studies, heart patients taking 

CoQ10 were found to have less than one-third 

as much chest pain and 75% fewer heart rhythm 

problems than those not taking CoQ10.

Best of all: There have been more than 1,000 

published papers that PROVE CoQ10 is completely safe. Long term trials have even shown 

that supplementing with CoQ10 is absolutely 

safe and non-toxic even after 8-years of use.

That’s why CoQ10 researchers were awarded 

the Nobel Prize for Science, the Priestly Medal 

from the American Chemical Society, and the 

National Medal of Science presented by The 

President of The United States.

It’s absolutely amazing! And that is just 

the start of our Ultimate Heart Formula. 

There’s much more!

EDTA is up to 95% effective at maintaining 

clear arteries and helping to reduce 

the risk of a heart problem!

It’s true, Ethylene Diamine Tetraacetic Acid – or EDTA has shown to 

be 95% effective in helping maintain 

(continued on page 10)

There are few medical 

conditions that can kill an 

unsuspecting person more 

suddenly than a stroke or 

heart attack... caused in part 

by HIGH BLOOD PRESSURE.

Make no mistake, your 

blood pressure is a KEY 

indicator of your heart health.

That’s why it’s the FIRST thing they do when 

you visit your doctor. It’s an instant indicator of 

your heart health. If it’s too high, or too low, and 

you could be in danger.

It’s not always clear you have high blood 

pressure. But don’t be mistaken, it’s a very 

serious condition that can lead to heart failure. 

So what exactly is high blood pressure...

Blood pressure is the force of blood pushing 

against your artery walls as your 

heart pumps it through your 

body, usually caused by blocked 

arteries. If this pressure rises, 

and stays high over time, you 

have High Blood Pressure.

This makes your 

heart work harder 

to pump blood to your body, and 

contributes to hardening of the arteries 

and heart failure. If the pressure gets 

too great inside your artery, it can 

actually burst or leak.

Our Ultimate Heart Formula

can help support your artery health 

and healthy blood pressure to reduce 

much of this risk! Don’t wait. Reply 

now for heart help.

CONSTRICTED ARTERIES:

Lead to high blood pressure... 

Which is also a huge risk to your health.

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“It is great! I am now having much better 

blood circulation to my hands and feet. 

I am 96 years old.”* —Roy Feather

“I do not have chest pains. 

the Ultimate Heart Formula

keeps my heart working 

with no stress. Thank you so 

much. I just feel so good that I 

got on with loving life.”*

—Dawn Simoneau

“My irregular heart beat episodes are a 

thing of the past. Don’t quit producing this 

product ever!”* —Fred Memmer

“I ordered the Ultimate Heart 

Formula and have been using 

it for about 2 years. My cholesterol levels have been 

around 167 or less.”* 

—Billy J. Huffman

“My heart is steadier now. My chest 

doesn’t hurt or ache and my general 

health and circulation is better.”* 

—Dean Tollefson

“My cardiologist says I have a thickened heart 

and I’ve had a stint put in my right leg. After 

taking the Ultimate Heart 

Formula my legs are no longer 

causing me any discomfort. I 

feel so much better. I have 

lots more pep.”*

—Sheila Brothers

“I went to a cardiologist. They 

said I have 2 plugged arteries 

and since they are close to the 

heart surgery can’t be done. I am 

92 years old and I was having 

trouble breathing even when 

washing dishes. The cardiologist gave me two 

drugs that didn’t help. When I received the ad 

for the Ultimate Heart Formula I decided 

to give it a try. It has helped me to breath 

better and I can walk slowly and not huff 

and puff.”* —Mary A. Lopez

“This product is a life saver. I am so glad I 

ordered Ultimate Heart Formula. Please don’t 

ever run out of it!”* —Ron Bryant

“I feel more alert and have more energy.”*

—Andrew Nero

“I had a stroke in 2011. In 2013, 

I was diagnosed with Atrial 

Fibrillation. This caused me 

heart palpitations and shortness 

of breath with episodes of light 

headedness. After trying different 

things, I tried the Ultimate Heart Formula 

which worked great. Of course the doctors 

don’t want to hear about how good the natural 

stuff can be, but for me I’m sticking with it. Thank 

you!”* —Dorothy Davis

“Stops the pounding in 

my heart. I feel much 

safer without chest 

discomfort.”*

—Ava Zimmerman

MORE praise for Ultimate Heart Formula 

from people just like you...

Call Toll-Free 888-462-9386 Today 100% Risk-Free!

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arteries in over 1,823 scientific 

studies.

EDTA is a natural aminoacid that eliminates dangerous 

blockages from your veins and 

arteries – blockages that prevent 

blood and oxygen from reaching 

your heart and brain – helping to 

reduce your risk of a heart attack.

In a study conducted by 

Dr. Norman Clarke M.D., a 

cardiologist and Chief of Research 

at the Providence Hospital Detroit, 

several hundred patients with 

chest pains and plaque-filled 

arteries were given EDTA.

The results were absolutely amazing: 

95% of them made a dramatic recovery and 

experienced remarkable improvements in 

their health.

In another study, published in

the Journal of Chronic Diseases, 100% 

of patients who used EDTA for

90-days saw a reduction in

their blood-pressure levels. In 

addition, 70% experienced reductions in their cholesterol levels too.

According to a study published 

in the British medical journal, 

Lancet, common anti-clotting drugs 

such as aspirin and coumadin are 

effective against only one-third of 

blood clot cases. None of them help 

the whole problem. EDTA, on the 

other hand, can fight blood-clots 

by keeping the blood thin, thereby 

reducing your risk of an attack.

Furthermore, according to Dr. Michael 

Janson, who’s been treating heart patients with 

W ith or without obvious symptoms... 

every year more and more people 

are choosing to be safe instead of sorry... 

and maintaining their heart health with 

all natural, side-effect-free Ultimate Heart 

Formula!

The Ultimate Heart Formula is an 

all-natural combination of 19 powerful herbs 

and essential nutrients that counter the causes 

of poor cardio health.

The Ultimate Heart Formula’s unique 

“Senior Formula” is made with ingredients 

specifically shown to help improve the effects 

of a weakened heart, clogged arteries, 

high blood 

pressure and 

high cholesterol for older 

people!

Many 

people experience remarkable results 

in just a matter of days! And you’ll always 

know it is working in the background of your life 

to help and protect you. The Ultimate Heart 

Formula also comes with an unconditional 

60-day guarantee. If you don’t see and feel 

remarkable differences in your health, you 

don’t pay.

(continued on page 12)

I feel that it has 

given me some extra 

strength in my daily 

routine. I do not get 

as tired as I used 

to in a day’s work. 

I have more energy.*

—William Wiebe

“

”

Let Ultimate Heart Formula

Protect YOUR 

arteries and heart!

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You won’t believe how much 

MORE powerful heart help is 

in our Ultimate Heart Formula!

Vitamin C is known to 

help blood vessels relax, which 

can be beneficial for heart 

health. Damage to the heart 

caused by a heart attack 

are related, in part, to the 

inability of blood vessels 

to dilate enough to allow 

blood flow.

Vitamin E improves 

vascular function... Has 

anti-clotting properties... Defends against 

oxidative damage that can cause heart 

disease... And reduces CRP, a blood protein 

linked to heart disease.

Vitamin B12 can lower homocysteine levels, 

which is an indicator of increased risk for heart 

disease, compared to people with average or low 

levels of homocysteine.

Aloe Vera supports healthy cholesterol levels 

and blood pressure... Can help regulate 

heart rhythm... 

Bilberry can help with 

LDL (bad) cholesterol 

levels, and help improve platelet 

function and blood pressure.

Cayenne can help 

prevent blood clots to help 

reduce the risk of a heart blockage.

Garlic is used for many conditions related 

to the heart and blood system. These conditions 

include high blood pressure, low blood pressure, 

high cholesterol, inherited high cholesterol, 

reduced blood flow due 

to narrowed arteries, and 

hardening of the arteries.

Ginger is linked to healthier 

hearts and may reduce the risk 

of many chronic conditions, 

including high blood 

pressure and 

coronary 

heart disease.

Kelp is naturally 

high in antioxidants and helps to combat 

oxidative stress and may offer benefits to 

cardiovascular health.

Mistletoe is used for heart and blood 

vessel conditions including high blood 

pressure and hardening of the arteries. 

Onion encourages 

a healthy heart in many 

ways, including 

healthy blood pressure 

and lowering heart attack risk.

Bromelain supports a 

healthy heart by helping to reduce 

inflammation and reducing 

triglycerides.

These health benefits have been seen in both human and experimental studies.

Support your heart 

100% with our powerful 

Ultimate Heart Formula!

 Ultimate Heart Formula 

contains 19 

heart helping 

nutrients!

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EDTA for many years, 90% of his 

patients report remarkable relief 

from chest discomfort as a result 

of EDTA treatment. 

And according to Dr. Gary 

Null, Ph.D., founder and director 

of the Nutritional Institute of 

America, “EDTA brought relief 

to more than 93% of patients 

suffering from heart disease and 

it can help avoid bypass surgery 

in 85% of cases. Thousands 

of stories from patients 

and physicians support its 

effectiveness and safety.”

As a result of these remarkable 

findings, massive multi-million 

dollar EDTA research grants have been given to 

many of America’s most respected health organizations, such as 

the National Institutes of Health, the U.S. Public 

Health Service, and The Mayo Foundation.

Now, those are just 2 of the 19 

heart-friendly nutrients you’ll find 

in the Ultimate Heart Formula! 

It contains the ingredients you 

need to support and strengthen 

your heart and to maintain your 

healthy arteries, cholesterol, and 

blood pressure levels!

Now you just need to take 

action before it’s too late!

With our 

Ultimate Heart Formula... 

You get it ALL... Amazing heart 

and artery protection... 

without side effects!

Ultimate Heart Formula is 

100% safe and can only help you improve your 

heart health!

The natural ingredients will work hand-inhand to have a positive effect on your body, only 

safely, naturally and without side effects.

You could increase your life span and 

quality of life by flushing your arteries 

free of life threatening plaque!

Yes, with the Ultimate Heart Formula, 

a lifetime of plaque build up could disappear 

before you know it!

The artery-flushing power of this formula does 

not even require a doctor’s visit or a stay in the 

hospital!

You simply take 20 drops of our Ultimate 

Heart Formula 2 times a day, that only costs 

pennies a day, and 

is as safe as baby 

food.

Soon the plaque 

stuck in your arteries can begin to 

dissolve, and be 

naturally passed 

out of your body!

Paired with a healthy heart, you could 

add decades of healthy, active living to 

your life. Reply now!

My heart 

palpitations have 

been cut way down. 

At the age of 82 

I don’t get the 

feeling that my heart 

is going to pump out 

of my chest!*

—Dorothy Davis

“

”

If you can keep YOUR arteries clear, 

and YOUR heart strong, 

there’s no telling how long your heart can work hard for you!

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On the other hand, heart/cardio medications 

are notorious for their ugly side effects, because 

those chemicals just aren’t good for your body.

Naturally protect and strengthen 

your heart and arteries... 

Reply now 100% risk free for all-natural 

Ultimate Heart Formula!

If you knew how truly debilitating a heart 

attack or stroke would be for you, taking away 

your ability to walk, talk, eat by yourself, or 

even move... You would take this matter very 

seriously.

It would make your decision to reply now 

for our Ultimate Heart Formula a no-brainer. 

It is simply among the most potent, natural heart 

formulas on the market today! As a medical 

doctor, I’m 100% confident it can support your 

heart and artery health to help lower your cardio 

health risk. So you don’t have to worry about 

the damage it will do to your body.

Don’t wait... Reply now to join our 

thousands of satisfied users and get special, 

first time-buyer-only low pricing. You can also 

get a greatly discounted price on the perfect 

companion product, and FREE Shipping!

Don’t roll the dice on your good health 

or your life! Take this easy step now to keep 

your heart strong and your arteries clear.

Reply now for the Ultimate Heart 

Formula... America’s #1 natural treatment to 

help maintain cardio health... doctor-recommended and formulated... and already used by 

thousands of people just like you! Call now!

With daily use, it can rejuvenate your heart 

and arteries with needed nutrients to give you 

many years of trouble-free support!

Your reply is 100% risk free... If you’re 

not 100% satisfied with your improvement 

after using Ultimate Heart Formula, simply 

send it back for a full refund of your purchase 

price within 60 days. No questions asked.

I look forward to hearing from you!

Sincerely,

Richard Cohen, M.D. 

Health Research Labs, Scientific Advisor

P.S. Our Ultimate Heart Formula can help 

keep your heart strong and arteries clear, so 

you can feel great and worry less! Respond 

now if you want your healthiest heart possible! 

You’ll get completely natural, real support for 

complete heart protection. All natural Ultimate 

Heart Formula is 100% effective and safe to use 

every day! Remember, thousands of people have 

already used it to help keep troubling heartrelated problems out of their life! Call now 

risk free 888-462-9386.

P.P.S. Sign up for our FREE weekly email 

newsletter! It’s called Dr. Cohen’s Healthy News 

Now... and it discusses many different health 

issues. Our customers love it! Just give us your 

email address when you place your order.

You can enjoy a healthy 

trouble-free heart and 

arteries, naturally, with an 

effective formula used by 

thousands of people across 

America! Reply now for the 

Ultimate Heart Formula.

FREE SHIPPING!

Richard Cohen

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14 l Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386

Support your cellular hydration with 

this premium formula that contains 

14 vitamins and minerals to help keep your cells 

100% healthy and hydrated... and you looking 

and feeling young!

You’ll also give your body the combined 

antioxidant activity of 29 vitalizing superfruits, 

phytonutrients, herbs and vegetable extracts to 

hydrate your dried out cells!

Improve heart health, boost energy, 

improve sexual health, beat stress, 

improve performance and reduce 

wrinkles... These are just a few of the 

benefits found in each bottle of Hydroxin.

It can fill in your cells’ nutrient gaps to give 

your health a quick and lasting jumpstart. Which 

is especially important if your healthy has been 

suffering as a result of poor digestion.

Try the amazing powers 

of Hydroxin for yourself. 

You deserve the opportunity to 

SEE and FEEL the difference 

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Exhibit '

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
NATURAL NERVE PAIN RELIEF l SPECIAL EDITION

RICHARD COHEN, M.D., SCIENTIFIC ADVISOR

Put Out the on 

Diabetic Nerve Pain and...

Walk, Stand and 

Sit Comfortably Again!

Studies show that there IS a natural, 

effective treatment for diabetic nerve pain!

OPEN NOW to Ease These Issues:

4 Burning

4 Itching

4 Tingling

4 Numbness

4 Constant cold

4 Swelling and heaviness

4 Cramps and restlessness...

And SO MUCH MORE!

This “Perfect” Nerve Pain easing 

pill combines special nutrients 

to restore circulation and soothe 

nerve pain associated with diabetes! 

See inside how it can help you...

HRL005036 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Dear Friend,

I’ve had patients describe their nerve pain as:

“Pins and needles”

“A hot, burning feeling” 

“Like walking on hot coals” 

“Like walking on balloons” 

“Tingling and itchy”

If any of this sounds familiar, my guess is 

that you too have diabetic nerve pain and/or 

neuropathy.

So I hope you’ll keep reading this 

important report...

Because what most people don’t know, is how 

to get rid of it.

The pain is so bad for many people they can’t 

stand for long. They have trouble walking. And 

their hands and feet are always cold and numb.

2 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

“That’s why I helped create a 

‘perfect’ nerve-pain-relieving 

formula that puts the ‘fire out’

in your legs, hands and feet, so you can move 

easily again, without pain and numbness.”

“Diabetic nerve pain is affecting more and more people like you, 

causing them 24/7 discomfort and making them unstable on their feet...

Once you get your blood moving freely again in 

your hands and feet, you will enjoy a world of 

improvement while standing, sitting or walking!

85% of people with diabetic nerve pain say it affects 

them daily... according to a Pfizer-sponsored survey.

HRL005037 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Richard Cohen, M.D. is a nationally recognized medical expert. 

As a specialist in nutritional medicine, he brings over two decades 

of experience in treating age-related illness.

He completed his undergraduate degree at Duke University with 

honors. And received his medical degree from Hahnemann Medical 

University in Philadelphia. Dr. Cohen is a member of the American 

College for the Advancement of Medicine.

Dr. Cohen’s expertise has earned him the attention of 

physicians and health professionals across the U.S. He has trained 

the American medical community on dietary issues for over 20 years. 

And recently, he was recognized as a leading authority in 

using diet, nutritional supplements and lifestyle to enhance 

well-being.

In recent years, he has helped develop a number of successful, 

innovative treatments to help his patients eliminate a variety of 

health problems.

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.

Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 3

If you ask me, that’s no way to enjoy life. 

And your legs and feet are too important to 

your mobility and quality of life to ignore this 

problem!

What you really have is a severe

circulation problem that is 

damaging nerves, and causing 

further complications...

People suffering 

with diabetes often have 

elevated blood sugar 

levels, and over time these 

elevated levels can cause 

permanent damage to the 

nerves in their feet and 

hands.

Not only that, this can lead to excess fluid in 

the legs, and swelling that puts further pressure 

on your nerve endings and causes even MORE 

pain, and MORE problems.

This nerve damage causes a very distinct 

type of pain — diabetic nerve pain. Which is 

different from the pain you may experience from 

a headache, a sprained ankle, or arthritis.

Some people with diabetic nerve pain 

experience shooting, burning, pins and needles 

or itching, while others may have only mild 

symptoms. I have found that the type and 

intensity of the pain varies greatly from 

person to person.

Diabetic nerve pain is most commonly 

felt in the feet and hands, and although it can 

come and go, the damage that caused nerve pain 

is permanent.

So what can you do about it?

Meet Dr. Richard Cohen, M.D.

(continued)

HRL005038 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
4 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

If you do in fact have diabetes, you 

need to take care of that by managing 

your blood sugar with your doctor’s 

help.

As I mentioned, the bad news is, 

once this nerve damage is done, you 

can’t undo it.

But, fortunately scientists have 

discovered that you can definitely 

help it improve, so you are not in 

constant discomfort.

And in my medical opinion, this is the best 

way to help address your issues — with a natural 

supplement that helps your body FIX the 

problem on its own. And doesn’t just 

mask the pain.

That is what we have in 

Neupathic... A “perfect” nerve pain 

supplement that was formulated from 

the ground up to improve your circulation and ease the numbness, tingling, 

itching, burning and swelling from 

excess fluid trapped in your legs.

Neupathic contains 6 known 

nerve pain soothers and lower leg 

health-improving nutrients that can 

help you see a change for the better in just 

days. You won’t just hope it’s working, you 

can actually feel a difference.

I’d like to tell you briefly about each one. As I 

believe, just like for my own patients, you should 

know how and why each nutrient can help you... 

and see the clinical proof of effectiveness for 

yourself.

Vitamin E helps protect 

and restores health to your 

damaged nerves...

One of your body’s most 

valuable, natural antioxidants, 

Vitamin E, improves glucose 

balance and helps protect 

blood vessels and nerves from 

free radical damage which is 

accelerated by diabetes.

This makes it one of the best 

vitamins for blood sugar issues 

AND diabetic nerve pain. Studies 

have shown that high doses of 

vitamin E may even reverse damage to nerves caused by diabetes.

Reduced levels of vitamin E are also seen 

in people with diabetic neuropathy. Vitamin E 

supplementation alone has been found to 

Symptoms of 

Diabetic Nerve Pain:

I

f you have diabetic nerve 

pain, you could suffer 

with any or all of the 

symptoms below.

4 Shooting pain

4 Burning

4 Pins and needles

4 Electric shock-like pain 

4 Extra sensitivity

4 Numbness

4 Throbbing

4 Tingling

4 Stinging

4 Stabbing

4 Radiating

Neupathic was specifically formulated 

with 6 distinct nutrients to help address 

ALL these issues and more.

HRL005039 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 5

improve signs of neuropathy, and can also 

improve nerve conduction in people with 

type 2 diabetes.

One study found that an antioxidant like 

vitamin E can help control neuropathy. In 

the study, 92 people with diabetic neuropathy 

took a standard pain and blood sugar medication, 

with or without 400 IU of vitamin E per day. 

After 12 weeks, blood sugar levels had declined 

nearly three times MORE for those taking 

vitamin E.

For their neuropathic pain, those over age 

50 in the vitamin E group had TWICE the pain 

relief as a placebo. Discussing their findings, 

doctors said that while there is no cure for 

neuropathy, vitamin E can help ease pain and 

improve quality of life.

Vitamin B1 can help stop that prickly 

feeling in your feet.

Taking Vitamin B1

(Thiamine) combined with 

vitamin B6 (also found in 

Neupathic!) can improve 

symptoms of diabetic 

neuropathy.

Your body uses 

thiamine to break down sugars that you eat, turn 

carbohydrates into energy, and help in nervous 

system functions.

Diabetic neuropathy,

 including nerve pain, 

often starts five to ten years 

after a person starts having 

blood sugar issues. It is a 

progressive degeneration 

of the nerves caused by 

diabetes.

Symptoms of neuropathy include

numbness or pain, tingling, burning or 

swelling in the feet and legs, and coldness 

in your hands.

The most common type of neuropathy 

is peripheral neuropathy. This damages 

the nerves of your feet especially. The foot 

often becomes wider and shorter. Your stride 

becomes longer or shorter. Foot ulcers can 

appear as pressure is put on parts of the foot 

that are less protected.

Because of the loss of 

sensation, injuries can go 

unnoticed and often become 

infected. If ulcers or foot 

injuries go untreated, the 

infection may affect the bone 

and require amputation. 

However, 

problems 

caused by minor injuries 

can usually be controlled 

IF they’re caught in time.

Living with this 

condition long term 

is both unhealthy and 

painful! Neupathic 

was designed 

specifically to deal 

with these unique 

health problems.

(continued)

Understanding Diabetic Nerve 

Pain From the Inside...

HRL005040 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
6 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

For people with diabetes, the risk of thiamine 

deficiency increases because your body does not 

always absorb this vitamin properly, causing it to 

pass out of your body in your urine.

Without 

enough thiamine, 

you’ll experience 

pain, prickly 

sensations, nerve 

deadening, and 

other symptoms 

related to nerve 

damage.

Studies have 

shown that 

thiamine, either 

from your diet 

or in supplement 

form, plays a key 

role in vascular 

(relating to the nerves in your arms and legs) health.

And some of the latest research has focused 

on using thiamine therapy to prevent and treat 

early-stage diabetic neuropathy.

In recent clinical trials, experts found 

that thiamine supplements can prevent 

the development of neuropathy...

A landmark trial in Africa found that 

supplementing with both vitamin B1 and 

vitamin B6 led to significant improvement of 

symptoms of diabetic neuropathy after four 

weeks.

Another trial found that combining vitamin 

B1 and vitamin B6 plus vitamin B12 in high 

amounts led to improvement in diabetic 

neuropathy in only 12 weeks.

As a result, doctors recommend that 

people with diabetic neuropathy supplement 

with vitamin B1.

Vitamin B6 can help keep your 

nerve endings healthy.

The main job of Vitamin B6 is to help your 

body process and use proteins and glycogen. 

It also helps form hemoglobin, which 

carries blood in your body.

One of the best diabetic vitamin 

supplements, Vitamin B6 supports 

nerve health, which is critical in 

addressing neuropathy.

And some cases of neuropathy have 

been linked to vitamin B6 deficiency.

Take this easy step 

towards normal, 

pain free legs and 

feet again!

Non-drug... proven ingredients!

CALL NOW toll free to soothe your 

diabetic nerve pain and more...

888-761-5495

HRL005041 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 7

While neuropathy causes numbness and 

tingling in the hands and feet, it is thought that 

vitamin B6 can aid in reducing neuropathy 

symptoms by maintaining the covering on 

nerve endings.

However, at doses higher than 200mg, it 

actually has the opposite effect, and can make 

neuropathy worse!

That’s why we put a 33.3mg dose in 

Neupathic, an ample amount to help with 

your symptoms of neuropathy, but not so 

much it has the opposite effect.

Folic acid helps ward off nerve pain.

Folic acid is a more 

stable form of folate found 

in dietary supplements and 

added to vitamin-fortified 

foods.

It’s a vital nutrient for 

people with neuropathy and 

chronic pain. That’s because a folic acid deficiency can directly influence the development of 

neuropathy.

Your body requires adequate levels of folic 

acid to synthesize the amino acid methionine 

from homocysteine. When folic acid is lacking, 

methionine is not produced and your levels of 

homocysteine rise.

A 2001 clinical study published in “Diabetic 

Medicine” found a correlation between elevated 

levels of homocysteine and the development of 

diabetic neuropathy symptoms.

And a deficiency in folic acid can have 

an impact on developing the symptoms of 

diabetic neuropathy.

You likely need more Vitamin B12, 

to protect your nerves...

Neuropathy can also occur as a result of 

(continued)

“I don’t have diabetes, but I 

definitely have lower leg issues.”

Lower leg issues, or neuropathy 

is also very common among 

NON-diabetics.

Even if you have a blood sugar 

imbalance, or some extra weight, your 

legs and feet may feel burdened, heavy 

and uncomfortable.

The dynamics are the same, your legs 

for several reasons, may be retaining fluid, 

that can make your legs heavy, tired and 

bulge with veins.

And unfortunately, this can eventually 

also do nerve damage as that extra fluid 

puts pressure on those nerves and causes 

damage.

Take a look... If your own legs and 

feet are swollen, inflamed, heavy, tired, 

achy or numb — regardless of anything else, your 

legs need some help 

from Neupathic.

And I’d advise, don’t 

ignore it, it will only get 

worse!

Neupathic is ready 

to help you NOW!

HRL005042 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
8 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

malnutrition, for which there are many causes... 

And, a clear link has been made between a lack of 

vitamin B12 and neuropathy.

Vitamin B12 deficiency is common in 

the United States, especially among seniors.

It’s estimated that between 10% and 25% 

of people over 80 years of age may have a 

B12 deficiency.

You see, a lack of B12 damages the myelin 

sheath that surrounds and protects 

nerves. Without this protection, nerves 

don’t function properly and neuropathy 

can occur.

Even a B12 

deficiency that 

is relatively mild 

can affect the nervous system. The nerve damage 

caused by a lack of B12 can become permanently 

debilitating, if the underlying condition is 

not treated. Symptoms and signs of a B12 

deficiency include:

n Lack of coordination

n Pain and numbness

n Tingling in hands or feet

n Sensory loss 

n Weakness

Luckily, we added a 

healthy dose of Vitamin B12 

so you will be fully covered.

Evening Primrose oil contains a 

unique acid that can improve 

nerve pain symptoms...

The oil from this flowering plant 

contains gamma-linolenic acid, 

and has been found helpful 

in numerous conditions 

including eczema, rheumatoid 

arthritis, and the nerve issues 

that can come with diabetes.

Evening primrose oil has long been 

associated with improved diabetic 

As lower leg health becomes a larger problem in 

the U.S., several formulas have come about to 

address this unique problem.

But few live up to the hype. Neupathic, having been 

carefully doctor-formulated with nutrients that are known to 

help this situation, makes it a clear winner!

If relief you can rely on long term is what you need, reply 

now for Neupathic. See how wonderful it can make your 

legs and feet feel again!

Neupathic is a Leading Choice for Americans 

Who Need Nerve Pain and Neuropathy Help!

CALL NOW toll free to soothe your diabetic 

nerve pain and more... 888-761-5495

HRL005043 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 9

neuropathy... Supplementing with evening 

primrose every day for six months has been 

found in research studies to improve nerve 

function and relieve pain symptoms in people 

with diabetic nerve damage.

For people with diabetic nerve pain, a major 

problem is that nerves can stop functioning. This 

can lead to damage to the feet and other parts of 

the body, which significantly reduces the person’s 

quality of life.

Defects with essential fatty acid metabolism 

appear to contribute to this, leading to a number 

of studies of evening primrose.

The most recent appeared in the Journal of 

Diabetes Care. Over 100 patients with mild 

nerve damage were given six capsules of 

gamma-linolenic acid twice a day for a year, 

the others, placebo. Sixteen measures of nerve 

function were followed over the year.

Every measure improved in the group on 

gamma-linolenic acid compared to the placebo 

group. For thirteen of the sixteen measures, the 

improvement was statistically significant.

The treatment 

was also more 

effective in those 

people who were 

better at keeping 

their blood sugar 

normal.

There you have it, 6 powerful nutrients that 

give you the perfect solution to your nerve pain 

and other neuropathy symptoms! Now...

It’s time to ease the discomfort in 

your legs, feet and hands, and feel 

normal and comfortable again!

Of course, I know there are other formulas 

available with different, ingredients for this 

same problem... (continued)

Real Comments 

From Real Nerve 

Pain Sufferers...

Results may vary. These are real users with real results.

“Great reduction of pain.

No more nerve pain in my 

feet. I also hardly notice any 

leg cramps. This product 

is great!”

 —Ruth J.

“My circulation is now much better.”

—Marion M.

“No burning, stabbing 

pain. No more stiffness. 

More energy. Move better. 

Neupathic is fantastic. I 

love it! It should be available 

at the drug store.”

—Naomi R.

“Neupathic is a great 

‘miracle-like product’

which starts working the very 

first day you use it. Then it 

continues to control your 

pain every day. My feet have 

began to feel normal. Neupathic has 

improved my life. My nerve pain is gone 

and I will continue to take Neupathic until 

my numbness is gone too!”

—Gloria R.

“My feet no longer 

burn, especially 

after an hour or 

so of inactivity. 

I definitely feel 

more comfortable.”

—Margaret J.

HRL005044 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
10 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

BUT... I call Neupathic the “perfect” 

solution because it was formulated based on the 

latest medical research, and recent science has 

now shown these 6 ingredients get the job done 

better, and work better together.

The fact is, you need powerful nerve 

treatment at the cellular level to help you. And 

you will NOT find any other formulas, with this 

proven nutrient lineup, or at this precise, high 

dosage. Which leaves all other products lacking 

for effective relief.

Already, thousands of people have tried 

Neupathic and LOVED the soothing results. 

They literally tell stories of amazing relief 

from their agonizing symptoms within just 

days of use.

Don’t wait any longer... 

Stay a step ahead of tingling, 

burning, numbness and more!

The reason why Neupathic is the best choice 

today for long-lasting nerve relief is because it 

contains the 6 KNOWN nerve pain, and lower 

leg health helping nutrients.

You’ll help quiet those agitated nerves, and 

help restore comfort, health and mobility to your 

legs, hands and feet!

YOU are a 

perfect candidate 

for Neupathic if:

n You find it 

difficult to walk 

because you can’t 

feel the ground 

under your feet.

n You can’t stop 

the itching, burning, 

stabbing, pins and 

needles or tingling in 

your legs and feet.

n Your hands, 

feet and legs are 

always cold.

n You don’t get a restful night’s sleep 

because of pain and discomfort.

n It’s hard to keep your balance on unsteady 

legs and feet.

n It’s hard to walk, move, exercise, bend, or 

enjoy your favorite activities.

n You feel trapped and immobile because of 

your unhealthy legs and feet.

n Your condition is worsening... as your pain 

gets worse and your legs become more swollen 

and heavy and tired.

If this describes your life today, I urge 

you to try the soothing relief that comes 

from Neupathic!

Neupathic will go to work fast to settle 

your pain, ease your burning and tingling and 

numbness, and restore health and mobility to 

your legs.

More Comments from 

Happy Neupathic 

Customers...

“I used to feel like 

someone was putting a 

needle in my toes. I no 

longer feel that and I am 

quite happy!”

 —Willard C.

“Neupathic has helped to 

relieve the neuropathy in 

my feet.”

 —Henry F.

Results may vary. These are real users with real results.

HRL005045 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
It can also help address the direct cause 

of nerve pain and neuropathy, damaged 

nerves, excess fluid — and poor circulation. 

Allowing you to:

...Increase your mobility

...Relieve nerve pain

...Reduce swelling and tightness

...Gain back your freedom to move easily 

and enjoy your favorite activities again

Neupathic is different from other nerve 

pain formulas you’ve tried...

Neupathic is recognized as one of the 

more powerful natural nerve pain relief 

options available.

The 6 ingredients, including several 

important B vitamins, are the best known 

nerve-soothing and repair nutrients you

can find.

So if you’re in constant need of relief for your 

feet and legs, and you to want to stop the cold 

feeling in your hands and feet... it really can 

become a “thing of the past” with Neupathic.

Once you try it, you can experience 

soothing relief from long-term aches and 

pains, swelling, burning, coldness, shooting 

pain, leg fatigue, and any issues you have 

with your legs and feet.

Thousands have now 

used Neupathic and 

experienced a rejuvenation 

of their legs! So make the 

decision now to relieve 

your pain troubles!

Neupathic is a 

doctor-formulated, 

100% all-natural, and 100% safe product with 

NO known side effects or harmful ingredients.

Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 11

(continued)

110,000 miles...

CALL NOW toll free to 

soothe your diabetic 

nerve pain and more...

888-761-5495

The average person takes about 

7,500 steps a day... If you maintain 

that average until age 80, you’ll walk about 

216,262,500 steps in your lifetime!

That’s about 110,000 miles of 

travel for your legs and feet... IF you 

stay healthy and active.

So if you’re about age 50, you’ve 

already put on about 50,000 miles!

However, if you suffer 

with poor lower leg health, 

you’ll need some help to stay 

active and hit 110,000! And 

Neupathic stands ready 

to help you!

HRL005046 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
12 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

And you’ll be backed by our 

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HRL005047 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
work. It can help you quickly feel more energetic 

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Scientific Advisor

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Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 l 13

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HRL005048 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
14 l Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

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HRL005049 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
n SUPER-INTENSIVE: I get a 5 month supply, plus a 7 month bonus

supply absolutely FREE! I pay only $199.95 and get FREE SHIPPING!

n MEGA-INTENSIVE: I get a 3 month supply, plus a 3 month bonus

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Neupathic Risk-Free Reply Form

n YES! I’m sick and tired of being limited in what I can do, and the

constant pain, numbness, coldness, tingling and burning. I’m ready to make a 

change with this symptom-relieving formula! I understand it is doctor-formulated and 

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SELECT YOUR PREFERRED METHOD OF PAYMENT:

n I have enclosed my check or money order payable to “HRL” for the

amount of: $ ____________________________________________________

n Please charge the full amount to my credit card:

n n n n

n n n n n n n n n n n n n n n n n n n n

Credit Card Account Number Exp. Date (MO/YR)

Signature:_______________________ Daytime Phone:_________________

ORDERED BY: (PLEASE PRINT)

Name:__________________________________________________________

Address: ________________________________________________________

City: ___________________________ State: _________ Zip: ____________

E-mail: _________________________________________________________

Health Research Labs, 

165 Pleasant Avenue, 

South Portland, ME 04106

1. By Mail: Use the enclosed

envelope or mail to:

Health Research Labs,

165 Pleasant Ave., 

South Portland, ME 04106

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888-761-5495

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www.HRLsupplements.com

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15

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Quantities are limited! Please order by next Tuesday! 

CALL NOW TOLL FREE: 888-761-5495

n Please remove my name from future mailings.

4

n Please send me my FREE tube of soothing Glucophene Cream.

n RUSH PROCESSING: Add $4.95 for the fastest way to receive your order.

3 FREE 3 FREE

+

HRL005050 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
NUP-D1-US

Health Research Labs

165 Pleasant Ave.

South Portland, ME 04106

PRSRT STD

U.S. Postage

PAID

Health

Research Labs

“I have the answer to 

put the ‘spunk’ back 

in your legs!”

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are sitting, standing, sleeping, or doing nothing, you need to read what is inside.”

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pain and lower leg health formula that can help you 

You Need Healthy 

Legs to Enjoy Life...

be comfortable, stable and pain free on your feet again.”

Don’t Let Poor Lower Leg Health or 

Nerve Pain Drag You Down!

Richard Cohen, M.D.,

Scientific Advisor

NATURAL NERVE PAIN RELIEF 

l SPECIAL EDITION

“

See Inside Now...

HRL005051 FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 X180007

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, ChairmanRebecca Kelly Slaughter, Acting 

Chair

Noah Joshua Phillips 

Rohit Chopra 

Rebecca Kelly Slaughter 

Christine S. Wilson 

________________________________________________ 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

______________________________________________ 

________________________________________________ 

COMPLAINT 

 The Federal Trade Commission, having reason to believe that Health Research 

Laboratories (“HRL”), a limited liability company, Whole Body Supplements (“WBS”), a 

limited liability company, and Kramer Duhon, individually and as an owner and officer of HRL 

and WBS (collectively, “Respondents”), have violated the provisions of the Federal Trade 

Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges: 

1. Respondent HRL is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

2. Respondent WBS is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

3. Respondent Kramer Duhon is the Chief Operating Officer and managing member of HRL 

and the Chief Operating Officer and managing member of WBS. Individually or in concert with 

others, he controlled or had the authority to control the acts and practices of HRL and WBS, 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

2 

including the acts and practices alleged in this complaint. His principal office or place of 

business is 16250 Knoll Trail Drive, Dallas, TX 75248. 

Respondents have

4. The FTC and Respondents HRL and Kramer Duhon signed a Stipulated Final Judgment 

and Order (“Order”) entered by U.S. District Judge Jon D. Levy on January 16, 2018 in FTC and 

State of Maine v. Health Research Laboratories, et al., 2:17-cv-00467 (Dkt. 15). Section III of 

the Order prohibits Respondents from making “any representation about the health benefits, 

safety, performance, or efficacy” of a dietary supplement, food, or drug “unless the 

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

and rely 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.” Section III further 

provides that “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.” 

4.5. Following entry of the Order, Respondents advertised, labeled, offered for sale, sold, and 

distributed, or caused to be distributed a number of dietary supplement products to consumers. 

HRL sold, among other products, Black Garlic Botanicals, The Ultimate Heart Formula, and 

Neupathic. WBS sold BG18, among other products. Black Garlic Botanicals, BG18, The 

Ultimate Heart Formula, and Neupathic are “food” and/or “drugs” within the meaning of 

Sections 12 and 15 of the Federal Trade Commission Act. 

6. Respondents’ advertisements for Black Garlic Botanicals, BG18, The Ultimate Heart 

Formula, and Neupathic included representations that the products would effectively prevent, 

reduce the risk of, cure, treat, or mitigate cardiovascular disease, atherosclerosis, hypertension, or 

diabetic neuropathy without adequate substantiation to support the representations. 

5.7. The acts and practices of Respondents alleged in this complaint have been in or affecting 

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

Black Garlic Botanicals 

8. HRL began selling Black Garlic Botanicals in November 2016. and continued to sell it 

following entry of the Order and after the filing of a contempt motion against Respondents in 

FTC and State of Maine v. Health Research Laboratories, LLC, et al., 2:17-cv-00467-JDL. HRL 

continued to sell the product to consumers through at least January 2021, despite the filing of the 

contempt motion and the Complaint in this administrative proceeding. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

3 

6.9. Each capsule of Black Garlic Botanicals contains 600 mg of the active ingredient black 

garlic, and the recommended dosage is two capsules a day. HRL sells a one-month supply of 

Black Garlic Botanicals for $39.95, plus shipping and handling. HRL also sold the product to 

consumers in other quantities and at different prices.

10. HRL has disseminated or has caused to be disseminated advertising and promotional 

materials for Black Garlic Botanicals in multi-page mailers sent to consumer residences and on 

company websites. Following entry of the Order, HRL disseminated or has caused to be 

disseminated more than 800,000 mailers to consumer residences in the United States and 

Canada. HRL continued to disseminate these mailers as late as August 2019 despite 

Respondents’ awareness that the FTC was investigating whether advertising for Black Garlic 

Botanicals violated the Order. 

11. The Black Garlic Botanicals mailer attached as Exhibit A opens with the following 

representations and depictions:

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

4 

 Exhibit A (Black Garlic Botanicals mailer) 

This front-page content is followed by additional descriptions of the dangers of 

cardiovascular disease. For example, the second and third pages display a banner across 

the top, which states, “Cardiovascular Disease: #1 cause of Death in the world, especially 

the U.S.!” A banner at the bottom states, “There’s a miraculous natural solution that can 

help – find out what it is!!” 

The mailer continues with the following statements about the efficacy of black garlic in 

reducing arterial plaque, blood pressure, and cholesterol: 

 

 BLACK GARLIC WORKS WITH YOUR BODY 

 Cholesterol: Black Garlic helps maintain healthy cholesterol 

levels. 

 Clotting: Black Garlic supports healthy platelet aggregation, 

which can help to keep blood circulating and works against 

clotting. 

 Supports and helps maintain healthy blood pressure levels to 

combat risks. 

 Healthy Arteries 

Plaque build-up in arteries can lead to unhealthy heart conditions. Black 

Garlic helps keep blood vessels barrier-free to create smooth flow, which 

could address symptoms of fatigue. It may also inhibit calcium binding, 

which is responsible for arterial plaque formation. 

 Want Healthy Blood Pressure & Cholesterol? Black Garlic helps maintain 

healthy blood pressure, cholesterol and triglyceride levels. 

 BLACK GARLIC 

A BREAKTHROUGH FOR 

 Cholesterol 

 Blood Sugar 

 Blood Pressure 

 The Heart 

 The Brain 

 “I made the switch to Black Garlic Botanicals and within the span of 3 

months my LDL levels have reduced from 300 to 150. This product 

works!” ~ Gerald W. 

 “I now have my blood pressure under control with Black Garlic 

Botanicals. This is a quality product!” ~ Rolf M. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

5 

BG18 

12. WBS began selling BG18 in August 2017. The product and continued to sell it after 

entry of the Order and after the filing of a contempt motion against Respondents in FTC and 

State of Maine v. Health Research Laboratories, LLC, et al., 2:17-cv-00467-JDL in December 

2019. 

7.13. BG18 has identical ingredients to Black Garlic Botanicals. Each capsule contains 600 

mg of the active ingredient black garlic, and the recommended dosage is two capsules a day. 

WBS sells a one-month supply of BG18 for $44.95, plus shipping and handling. WBS also sold 

the product to consumers in other quantities and at different prices.

14. WBS has disseminated or has caused to be disseminated advertising and promotional 

materials for BG18, including multi-page mailers and content on company websites. Following 

entry of the Order, WBS disseminated or caused to be disseminated more than 400,000 mailers 

to consumer residences in the United States and Canada. WBS continued to disseminate these 

mailers as late as June 2019 despite Respondents’ awareness that the FTC was investigating 

whether advertising for BG18 violated the Order. 

8.15. An example of a mailer for BG18 is attached as Exhibit B. 

The front page of the attached BG18 mailer features an image of a caduceus and, a 

photograph of a doctor in a white coat, and states “Black Garlic has shown an amazing 

power to improve heart and cardiovascular health, maintain normal cholesterol levels, 

boost your immune system. And MUCH MORE!” The mailer continues with the 

following representations: 

 Black Garlic is a proven miracle for . . . Cholesterol . . . Hypertension . . . 

Your Heart. 

 [Black Garlic] can help reverse plaque build-up in arteries – not just slow 

it down. Black Garlic keeps blood vessels barrier-free to create a smooth 

blood flow and alleviates symptoms of fatigue. It also strongly inhibits 

calcium binding, which is responsible for plaque build-up. 

 Reduces Blood Pressure and Cholesterol. . . Black Garlic helps reduce 

high blood pressure and lowers high levels of bad cholesterol and 

triglycerides. 

 “My blood pressure has also been lowered. I recommend this product 

because IT WORKS!” ~ Lorraine T. 

 On the following page, the brochure poses this question and answer: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

6 

 Exhibit B (BG18 mailer). 

 Yes, Black Garlic is a true miracle for cardiovascular health! Just 1 

capsule knocks down cholesterol and high blood pressure within days. It 

can also unblock, clean, and strengthen your arteries. 

 The cardio-protective effect of black garlic. . . Black garlic can also 

improve your lipid profile, an important factor in protecting against 

cardiovascular problems. 

The Ultimate Heart Formula 

16. HRL has been selling The Ultimate Heart Formula (“UHF”) since November 2008. HRL 

began selling The Ultimate Heart Formula (“UHF”) in November 2008 and continued to sell it 

following entry of the Order and after the filing of a contempt motion against Respondents in 

FTC and State of Maine v. Health Research Laboratories, LLC, et al., 2:17-cv-00467-JDL. HRL 

continued to sell the product to consumers through at least January 2021, despite the filing of the 

contempt motion and the Complaint in this administrative proceeding. 

9.17. UHF contains Vitamins C, E, and B12 as well as garlic extract (25 mg), Tetrasodium 

EDTA (40 mg), Ubiquinol (CoEnzyme Q-10) (5 mg), and Nattokinase (10 mg). The 

recommended dosage is 20 drops or 1ml, twice per day. HRL sold a one-month’s supply of 

UHF for $39.95, plus shipping and handling. The recommended dosage is 20 drops or 1ml, 

twice per day.HRL also sold the product to consumers in other quantities and at different prices. 

18. HRL disseminated or caused to be disseminated advertisements for UHF, including 

multipage mailers and company websites. Following entry of the Order, HRL disseminated or 

caused to be disseminated more than 200,000 mailers to consumer residences in the United 

States and Canada. 

10.19. An example of a mailer for UHF is attached as Exhibit C, which contains the following 

statements and depictions on its first and second pages: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

7 

 Exhibit C (The Ultimate Heart Formula mailer). 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

8 

 Exhibit C (The Ultimate Heart Formula mailer, p.2) 

 These depictions and representations are followed by a number of additional claims, 

 including: 

 Instead, right before you is a simple, safe, inexpensive, non-painful and 

preventative option that could help you say goodbye to your heart surgeon 

and avoid an angioplasty. 

 Our Ultimate Heart Formula can help support a healthy heart, healthy 

cholesterol and healthy blood pressure. As blockages in your veins and 

arteries become clear, you can experience better blood circulation – 

resulting in more energy, better sleep, sharper mental clarity and better 

health. 

 The Ultimate Heart Formula also contains a powerful, clot-busting agent! 

 The Ultimate Heart Formula is an all-natural combination of 19 powerful 

herbs and essential nutrients that counter the causes of poor cardio health. 

The Ultimate Heart Formula’s unique “Senior Formula” is made with 

ingredients specifically shown to help improve the effects of a weakened 

heart, clogged arteries, high blood pressure and high cholesterol for older 

people! 

 With our Ultimate Heart Formula ...You get it ALL ... Amazing heart and 

artery protection ... without side effects! 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

9 

 Yes, with the Ultimate Heart Formula, a lifetime of plaque build up could 

disappear before you know it! The artery-flushing power of this formula 

does not even require a doctor’s visit or stay in the hospital! 

Neupathic 

11.20. Beginning in August 2016, HRL also sold a dietary supplement called Neupathic. HRL 

continued to sell the product following entry of the Order and after the filing of a contempt 

motion against Respondents in FTC and State of Maine v. Health Research Laboratories, LLC, 

et al., 2:17-cv-00467-JDL. Neupathic contains the following active ingredients: Vitamins E (30 

IU), B1 (33.3 mg), B6 (33.3 mg), B12 (16.7 mcg), and folate (266.7 mcg), and Evening Primrose 

Oil (666.7 mg). The recommended dosage is two capsules per day. HRL sold a one-month’s 

supply of Neupathic for $39.95, plus shipping and handling. The recommended dosage is two 

capsules per day.HRL also sold the product to consumers in other quantities and at different 

prices. 

21. HRL has disseminated or caused to be disseminated advertising and promotional 

materials for Neupathic, including multi-page mailers and content on company websites. 

Following entry of the Order, HRL disseminated or caused to be disseminated more than 

400,000 mailers to consumer residences in the United States and Canada. HRL continued to 

disseminate these mailers as late as June 2019 despite Respondents’ awareness that the FTC was 

investigating whether their advertising for Neupathic violated the Order. 

12.22. An example of a mailer is attached as Exhibit D, which contains the following depictions 

and statements on the first page: 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

10 

 Exhibit D (Neupathic mailer). 

 The mailer continues inside with additional claims: 

 If you have diabetic nerve pain, you could suffer with any or all of the 

symptoms below. 

 Shooting pain 

 Burning 

 Pins and needles 

 Electric shock-like pain 

 Extra sensitivity 

 Numbness 

 Throbbing 

 Tingling 

 Stinging 

 Stabbing 

 Radiating 

 Neupathic was specifically formulated with 6 distinct nutrients to help 

 address ALL these issues and more. 

 A “perfect” nerve pain supplement that was formulated from the ground 

up to improve your circulation and ease the numbness, tingling, itching, 

burning and swelling from excess fluid trapped in your legs. 

 Take this easy step towards normal, pain free legs and feet again! Nondrug ... proven ingredients. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

11 

Exhibit D (Neupathic mailer, p. 11). 

 Respond now if your nerve pain is driving you crazy! You’ll get 

completely natural, real relief from your discomfort. All natural 

Neupathic is 100% effective and safe to use every day! Remember, it has 

[sic] shown to help reverse damaged nerves to help you feel great all day 

and all night. 

 

 “Great reduction of pain. No more nerve pain in my feet. I also hardly 

notice any leg cramps. This product is great!” — Ruth J. 

 “Neupathic is a great ‘miracle-like product’ which starts working the very 

first day you use it. Then it continues to control your pain every day. My 

feet have began [sic] to feel normal. Neupathic has improved my life. My 

nerve pain is gone and I will continue to take Neupathic until my 

numbness is gone too!” — Gloria R. Id. 

23. Respondents did not have competent and reliable scientific evidence to support the 

representations in their advertisements. Further, they relied in part on advice from consultants 

and/or advisors who did not have appropriate qualifications or expertise to evaluate 

substantiation for the representations. 

Count I 

Respondents’ Unsubstantiated Claims Related to Black Garlic Botanicals 

(HRL and Duhon) 

13.24. In connection with the advertising, promotion, offering for sale, or sale of Black Garlic 

Botanicals, HRL and Kramer Duhon have represented, directly or indirectly, expressly or by 

implication, that Black Garlic Botanicals: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

12 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque; 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

14.25. The representations set forth in Paragraph 1424 were not substantiated at the time the 

representations were made. 

Count II 

Respondents’ Unsubstantiated Claims Related to BG18 

(WBS and Duhon) 

15.26. In connection with the advertising, promotion, offering for sale, or sale of BG18, WBS 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

BG18: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

16.27. The representations set forth in Paragraph 1626 were not substantiated at the time the 

representations were made. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
 

13 

Count III 

Respondents’ Unsubstantiated Claims Related to UHF 

(HRL and Duhon) 

17.28. In connection with the advertising, promotion, offering for sale, or sale of UHF, HRL 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

UHF 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

18.29. The representations set forth in Paragraph 1828 were not substantiated at the time the 

representations were made. 

Count IV 

Respondents’ Unsubstantiated Claims Related to Neupathic 

(HRL and Duhon) 

19.30. In connection with the advertising, promotion, offering for sale, or sale of Neupathic, 

HRL and Kramer Duhon have represented, directly or indirectly, expressly or by implication, 

that Neupathic: 

a. Cures, treats, or mitigates diabetic neuropathy including by improving blood 

circulation, or eliminating or alleviating diabetic nerve pain and discomfort. 

31. The representations set forth in Paragraph 2030 were not substantiated at the time the 

representations were made. 

20. Formatted: Normal, No bullets or numbering

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Violations of Sections 5 and 12

21.32. The acts and practices of Respondents as alleged in this complaint constitute unfair or 

deceptive acts or practices, and the making of false advertisements, in or affecting commerce in 

violation of Sections 5(a) and 12 of the Federal Trade Commission Act. 

NOTICE 

You are notified that on _________________, 20__,July 13, 2021, at __________10:00

a.m., at the Federal Trade Commission offices, 600 Pennsylvania Avenue, NW, Room 532-H, 

Washington, DC 20580, an Administrative Law Judge of the Federal Trade Commission will 

hold a hearing on the charges set forth in this Complaint. At that time and place, you will have 

the right under the Federal Trade Commission Act to appear and show cause why an order 

should not be entered requiring you to cease and desist from the violations of law charged in this 

Complaint. 

You are notified that you are afforded the opportunity to file with the Federal Trade 

Commission (“Commission”) an answer to this Complaint on or before the 14th day after service 

of the Complaint upon you. An answer in which the allegations of the Complaint are contested 

must contain a concise statement of the facts constituting each ground of defense; and specific 

admission, denial, or explanation of each fact alleged in the Complaint or, if you are without 

knowledge thereof, a statement to that effect. Allegations of the Complaint not thus answered 

will be deemed to have been admitted. 

If you elect not to contest the allegations of fact set forth in the Complaint, the answer 

should consist of a statement that you admit all of the material facts to be true. Such an answer 

will constitute a waiver of hearings as to the facts alleged in the Complaint and, together with the 

Complaint, will provide a record basis on which the Commission may issue a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. In 

such answer, you may, however, reserve the right to submit proposed findings of fact and 

conclusions of law under FTC Rule § 3.46. 

Failure to answer timely will be deemed to constitute a waiver of your right to appear and 

contest the allegations of the Complaint. It will also authorize the Commission, without further 

notice to you, to find the facts to be as alleged in the Complaint and to enter a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. 

The Administrative Law Judge will hold an initial prehearing scheduling conference not 

later than 10 days after the answer is filed by the last answering Respondent. Unless otherwise 

directed by the Administrative Law Judge, the scheduling conference and further proceedings 

will take place at the Federal Trade Commission, 600 Pennsylvania Avenue, NW, Room 532-H, 

Washington, DC 20580. Rule 3.21(a) requires a meeting of the parties’ counsel as early as 

practicable before the prehearing scheduling conference, but in any event no later than 5 days 

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15 

after the answer is filed by the last answering Respondent. Rule 3.31(b) obligates counsel for 

each party, within 5 days of receiving a Respondent’s answer, to make certain initial disclosures 

without awaiting a formal discovery request. 

 Moreover, the Commission has reason to believe that, if the facts are found as alleged in 

the Complaint, it may be necessary and appropriate for the Commission to seek relief to redress 

injury to consumers. Such relief could be in the form of restitution for past, present, and future 

consumers and such other types of relief as are set forth in Section 19(b) of the Federal Trade 

Commission Act. The Commission will determine whether to apply to a court for such relief on 

the basis of the adjudicative proceedings in this matter and such other factors as are relevant to 

consider the necessity and appropriateness of such action. 

 

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16 

NOTICE OF CONTEMPLATED RELIEF 

 Should the Commission conclude from the record developed in any adjudicative proceedings 

in this matter that Respondents have violated or are violating Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a) and 52, the Commission may order such relief against Respondents as is 

supported by the record and is necessary and appropriate, including but not limited to: 

a. A prohibition on any representation that Respondents’ products cure, treat, mitigate, 

prevent, or reduce the risk of any disease. 

b. A prohibition on representations about the health benefits, safety, efficacy, or the 

performance of Respondents’ products unless those representations are supported by 

competent and reliable scientific evidence. 

c. A prohibition on misrepresentations regarding tests, studies, or other research. 

d. A requirement that Respondents preserve records relating to competent and reliable 

clinical tests or studies. 

e. A requirement that Respondents send appropriate notification of the order to all affected 

customers. 

f. A requirement that Respondents cancel any automatically recurring orders for Black 

Garlic Botanicals, BG18, UHF, or Neupathic for any existing customer who was first 

charged before the issuance of the Complaint. 

g. A requirement that Respondents will not use, sell, rent, lease, or transfer any identifying 

information related to any customer who paid money to any Respondent for Black Garlic 

Botanicals, BG18, UHF, or Neupathic prior to the issuance of the Complaint. 

h. A requirement that, for a period of time, Respondents send acknowledgments of the order 

to the Commission. 

i. A requirement that, for a period of time, Respondents create and preserve certain records 

demonstrating compliance with the order. 

j. A requirement that, for a period of time, Respondents provide notice of all new business 

activity to the Commission. 

k. A requirement that Respondents file periodic compliance reports with the Commission. 

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1.08 li

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17 

l. A requirement that Respondents’ compliance with the order be monitored for a term to be 

determined by the Commission. 

m. Any other relief appropriate to correct or remedy the effects of Respondents’ deceptive 

practices or of any or all of the conduct alleged in the complaint. 

 

IN WITNESS WHEREOF, the Federal Trade Commission has caused this complaint to be 

signed by its Secretary and its official seal to be hereto affixed at Washington, DC, this ___24th

day of ________ 2020February 2021. 

By the Commission. 

 April J. Tabor 

 Acting Secretary 

SEAL: 

 

Formatted: Indent: Left: 0.25", Add space between

paragraphs of the same style

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

________________________________________________ 

In the Matter of

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC.

______________________________________________ 

COMPLAINT COUNSEL’S EXHIBIT B (CCX-B) 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

________________________________________________ 

In the Matter of

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC.

________________________________________________ 

DECLARATION OF JONATHAN COHEN

I have personal knowledge of the facts set forth below. If called as a witness, I could and 

would testify as follows: 

1. I am a United States citizen and am over eighteen years of age. I am employed by 

the Federal Trade Commission (“FTC”) as an attorney in the Division of Enforcement, Bureau of 

Consumer Protection. I am acting as Complaint Counsel in the above-captioned matter. 

2. The allegations in the proposed Amended Complaint derive substantially from 

limited information that Respondents have disclosed within the past month. 

3. Respondents have served no discovery to Complaint Counsel or third parties. 

4. At 1:20 PM on Friday, February 12, before President’s Day weekend, 

Respondents asked to confer about this motion. Complaint Counsel offered to confer 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC
immediately after the holiday, on the next business day, but Respondents filed their motion on 

February 12 anyway. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. 

Executed on: February 24, 2021 /s/ Jonathan Cohen

Washington, D.C. 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/24/2021 | OSCAR NO. 600771 | PUBLIC