n 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 1 of 25 

UNITED STATES DISTRICT COURT 

DISTRICT OF COLORADO 

__________________________________________ 

FEDERAL TRADE COMMISSION, ) 

 ) 

Plaintiff, )

 ) Civil Action No. 1:19-cv-3423 

v. )

 ) 

A.S. RESEARCH, LLC, also d/b/a ) COMPLAINT FOR 

ASR and APPLIED SCIENTIFIC ) PERMANENT INJUNCTION AND 

RESEARCH LABS, ) OTHER EQUITABLE RELIEF 

a limited liability company, ) 

 ) 

STEPHEN J. YOUNG, individually ) 

 and as an owner and officer of ) 

 A.S. RESEARCH, LLC, and ) 

 ) 

MICHAEL K. LEDEBOER, individually ) 

 and as an owner and officer of ) 

 A.S. RESEARCH, LLC, ) 

 ) 

Defendants. ) 

__________________________________________) 

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

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

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

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

monies, and other equitable relief for Defendants’ acts or practices in violation of Sections 5(a) 

and 12 of the FTC Act, 15 U.S.C. §§ 45(a), 52, in connection with the advertising, labeling, 

promotion, offering for sale, sale, or distribution of Synovia. 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 2 of 25 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 

1337(a), and 1345. 

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

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

PLAINTIFF 

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

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

45(a), which prohibits unfair or deceptive acts or practices in or affecting commerce. The 

FTC also enforces Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false 

advertisements for food, drugs, devices, services, or cosmetics in or affecting commerce. 

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

attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as may be 

appropriate in each case, including rescission or reformation of contracts, restitution, the refund 

of monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. § 53(b). 

DEFENDANTS 

6. Defendant A.S. Research, LLC (“Corporate Defendant” or “A.S. Research”), also 

doing business as ASR and Applied Scientific Research Labs, is a limited liability company 

registered in Colorado with its principal place of business at 7750 North Union Boulevard, Suite 

205, Colorado Springs, Colorado. A.S. Research transacts or has transacted business in this 

District and throughout the United States. 

2 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 3 of 25 

7. Defendant Stephen J. Young is a 50% owner, officer, and director of A.S. 

Research. Defendant Michael K. Ledeboer is a 50% owner, officer, and director of A.S. 

Research. Stephen J. Young and Michael K. Ledeboer (together, “Individual Defendants”) split 

the day-to-day management and operating responsibilities for the Corporate Defendant. They 

share all duties related to the business, including selection of products to sell, what ingredients to 

include in those products, the review of scientific research, and the approval of advertising. At 

all times material to this Complaint, acting alone or in concert with others, the Individual 

Defendants have formulated, directed, controlled, had the authority to control, or participated in 

the acts and practices of the Corporate Defendant, including the acts and practices set forth in 

this Complaint. The Individual Defendants reside in this District and, in connection with the 

matters alleged herein, transact or have transacted business in this District and throughout the 

United States. 

COMMERCE 

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

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act, 

15 U.S.C. § 44. 

DEFENDANTS’ BUSINESS ACTIVITIES 

9. Defendants advertise, label, promote, offer for sale, sell, and distribute Synovia 

and other health-related products. Consumers can purchase Synovia by calling a toll-free 

number or by ordering through websites operated by Defendants, including: 

http://store.asresearchlabs.com/synovia, www.synoviaplus.com/joint-pain-relief, and www.jointsolutions.com/relief-from-pain. 

3 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 4 of 25 

10. Synovia is sold in a 30-capsule bottle bearing the label “Synovia+.” According to 

the product label, each capsule contains 750 mg Balanced Kollagen®, 75 mg hyaluronic acid, 

5 mg piperine 95%, and 4 mg astaxanthin 1%. The product label advises consumers to take one 

capsule of Synovia daily. 

DEFENDANTS’ ADVERTISING AND MARKETING 

11. To induce consumers to purchase their products, Defendants have disseminated or 

caused to be disseminated advertisements and promotional materials, including, but not limited 

to, the attached Exhibits A through G. These advertisements and promotional materials have 

contained the following representations or statements, among others: 

A. Newspaper advertisement 

Costly Joint-Pain 

Injections Replaced 

By New $2 Pill 

New pill boosts the same lubricating joint fluid as expensive and painful 

injections – without using a needle. Users report dramatic relief from 

swelling, pain and stiffness without side effects and expense. 

* * * 

A popular needle injection for people with joint pain is now available in an 

inexpensive nonprescription pill. 

* * * 

The new pill, called Synovia, delivers the same “relief molecule” as the 

injections. . . . Also, relief is delivered to every joint in the body because it enters the 

bloodstream through the digestive system. 

This gives it the ability to reduce a much wider variety of pain. Users report 

greater flexibility and less stiffness in their knees. Hands and shoulders move pain-free 

for the first time in years. Even neck and lower back pain improve dramatically. 

All this without spending over $600 on needle injections and taking trips to the 

doctor every week. 

* * * 

The medical community is very excited about this new breakthrough. Dr. Jacob 

Moss says, “Synovia is a great option for those suffering from joint pain. Injections are 

4 
 

 

 

~r 

• natural relief from stiff, swollen, painful 

OPEN NOW If you want fast, long-lasti·ng, 

, • .Knees • Hips • Back • Neck • Shoulders 

• Fingers and Hanas • Wrists • Joints 

New $1.33 Pill 

Replaces $1,000 

Joint Pain Injections? 

New pill naturally delivers ''relief molecules" 

and boosts the same lubricating joint fluid 

as injections ... without needles! 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 5 of 25 

usually a last resort because of the pain and expense. However, Synovia should be taken 

at the first sign of discomfort.” 

* * * 

Doctors use the shots to boost a critical element of the joint called synovial fluid. 

This lubricating fluid is found between the cartilage and bones of every joint. 

* * * 

Leading clinics use injection therapy because it works. Recent clinical trials show 

the pill form also delivers major relief. 

One example is a landmark study out of Europe. In the study the active ingredient 

in Synovia was compared to a popular NSAID pain reliever. The goal was to see if it 

could reduce pain and swelling around the knee. The results were incredible! 

After just 30 days, more than 8 out of 10 people who took Synovia’s active 

ingredient had NO swelling. . . . 

The study also looked at cases of severe swelling. Amazingly, zero cases of 

severe swelling were detected in the group taking the active ingredient found in Synovia. 

This means it was 100% effective for the cases of severe swelling! 

-Exhibit A, disseminated Nov. 3, 2017 to 

July 3, 2018 in markets nationwide 

B. Direct Mailing 

* * * 

It’s . . . a pill called Synovia that’s been a life-restorer for people all across America 

5 
A broad SP.ectrum, patented Ko"f!agen: Tlie only collagen clinically proven to reduce pain by 95%. 

Restores and rebuilds your joints at the molecular level to wipe out pain . 

. . . patented Balanced 

Kollagen that makes your 

joints virtually pain free 

Whatmakes Balanced 

Kollagen superior to typical 

collagen? Three things ... 

1) More pain relief than 

any other collagen 

-95% less pain, 

clinically proven 

fve known about collagen 

for decades, but I've never seen 

a collagen deliver pain relief like 

Balanced Kollagen. 

In a landmark clinical study, 

people suffering from joint pain 

and cartilage injuries took 750 mg 

of Balanced Kollagen every day 

for 120 days. 

The results? Stunning! 

» After just 7 days, their joint 

flexibility increased nearly 

30%! 

» After 30 days, 85% of their 

pain was gone! 

» After 120 days, a fall 95% of 

thcir _p8lll hl\d vanisbedtl1

) 

Great news! Each pill of 

Synovia includes 750 mg of 

Balutced :Kolla#n- the ,exact 

same dos~ used in this studyt 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 6 of 25 

* * * 

If you want flexible, pain-free knees, hips, shoulders, back and joints, you must have 

healthy levels of collagen. 

* * * 

. . . Synovia . . .includes. . . 

* * * 

6 
Amazing 85% Relief in just 30 daysl 

10 • e 11 ~ 

, 0.., ~ I, f~ avei-"'le poi., score ~ 10. u u I t 

:,,.,_,roves ;=on the quality I 

of cartilage repal r 

after micro fracture... 

and was superior to that after 

microfradure alone." 

- Amoi<on .Jwmal <(Sp,,ru Maluine 

No more painful injections for Lisa 

Lisa T~ age 53, from North Carolina was at her wit's end. 

Shcsufl'ered from disc issues and se--cre 

knee and back pain. Doctors told her 

she needed a double knee rcplacemenL 

She writes, "1\-e tried shots in my 

back and both knees .... but they require 

taking time off work ... thcy can be 

painful ... and sometime don't work. Not 

to mention the ob,ious cost. 

"Sym,via is wonderful. It has worked to greatly lessen my pain and 

impro1'C flexibility through my whole body. I can touch my toes again! 

With Synovia, I'm er,joying life again. Thank you so much!" __ ._..,, 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 7 of 25 

* * * 

* * * 

7 
Hyaluronic acid 

paves the ''o<?t !toles" 

m damageajomts 

When 10ur syno,ial fluid dries 

up cartilage in your joints 

erod - creating pot hol . 

111ese rough patch make 

bending and fle.,ingdifficult, if not 

impossible-and painful. 

But when you restore hyaluroni 

acid with S!Jn<Wia, it's like repa\ing those pot hol . You rebuild 

cartilage and restore lubricationfor easy mo\ing, pain-free joints. 

Foryear, William 8.of Tenn ee, age 7, uffered 

from bone-on-bone ankle 

problems. 

The pain was o bad, he had lo 

get injection e ery two months. 

But ince taking Syrwvia, 

reli fhas been, in hi words 

MAbsolutely wonderful! The 

pain and swelling had 

disappeared with no ide 

effects. Thankyou-1 am 

back living normal again! 

L tm ll ou '° Balanced Kollagen reduces aboutahiM n acidity 

of joint 1M 1."11 7 I 

pa.in con ntional 

solutions fail t.o I : 

pain-causing 

u 

add 1 : 

lt's high acidity 

m ured b a J i ' ' 

low pll. 1n fact, 

many chroni pain 0 -'-"T'"-"T'"

0oy, o.r _"T'"_"T'"_"T'"_,_..,.... ....... -,-10 °"I' 20 o.y 30 o., co o.,, ao o.y 110 

prob) n are linked oti:i..,ocw,'IHll(Teludl 

8al,rced Kolagen In S)Jl(Wfallduced pain-causing acidity to a id/alkaline by 67%. pit was ramd from U ID 7.51. 

imbalance. 

What Great news! Balanced caus too ollagcn found in yrwvi,a is much acid in the body? clinically proven to reduce Primarilyadi Lof acidity b 57%. much mat, , 

dairy, whi flour, In a clinical study, 

coffe , soft drinks and Balanced Kalla n rai 

artificial l>'\ • teners. pH from 4.7( 'die) to a pH 

of7.3 (mo alkalin ).OO 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 8 of 25 

* * * 

* * * 

8 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 9 of 25 

* * * 

. . . Synovia includes . . . astaxanthin . . . 

* * * 

Astaxanthin has . . . been proven to slash inflammation and pain. 

* * * 

In addition, Astaxanthin alone or as part of a combination of nutrients has been 

proven to . . . 

 Effectively relieve severe joint pain . . . 

 Relieve pain caused by Carpal Tunnel Syndrome . . . 

 Alleviate pain and improve strength grip of tennis elbow . . . 

 Help reduce muscular atrophy . . . 

This is why you’ll be glad to know Synovia includes 4 mg of Astaxanthin in each pill. 

* * * 

Here's the kind of 

pain relief Synowa 

offers, based on 

clinical studies and 

customer commen1s., 

* * * 

9 
Synovia is the onJ.x painrelieving formula I've found with 

nutrients clinically proven or 

shown to ... 

» Reduce pain by 95% 

» Reduce pain-causing acidty 

by57% 

> > Deliver ''relief mdec!Jes" 

deep within your joints 

> > Restore yow body1s natural 

lubricatlng fluids 

> > Restore and repar damaged 

joint cartilage 

>> Defuse pain-causing free 

radicals better than any other 

antioxidants 

> > Relieve pain In your knees, 

hips, shoulders, back, neck 

and joints 

Clinically proven and patented. 

95% pain relief so good, 

he gave away his walker! 

Aclinical study was conducted in Ontario, Canada to test the effectivenes.s 

of thP. FIRST nf a. wfmlP. TIP.W da."-."- of painkiller.. whic:h works in a 

completely different way to relieve you, pain. 

The results? Otfthe chans! 

» Gn,g saw sucl, a decreas,, lo pain, he no longer needs Im walker!• \ 

Overall. rosults fi>r 

poople suff er!ng from Joint 

pain and canilage injuries 

were stunning: 

✓ 8.'i% of pa.in gone in 30 days~ 

✓ Nemy a 30% iocrease In fie>ibllity 

in just 7 da)~! 

✓ 95-,. ofpaln ,-.ntshed In 120 days! 

Now, lh1s breakthrough is a key "active" 

Ingredient In a new pW that helps banish )'Our 

pain without needles, surgery or side effects. 

~ "Being able to get pain relief 

1 without rieedles, surgery or 

~ ~ medications is remarkable. 

'

' I'd recommend this pill at the 

first sign of pain." 

- Jtrdtl ... MJJ,r"_,.,~~-'~ef 

;uRmk,IP..w:sA<iW'l'&11llrtniaP4mlftdQ'IJ;ll(lloo ••* 

Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 10 of 25 

-Exhibit B, disseminated Sept. 2017 to June 2018 

C. Direct Mailing 

-Exhibit C, disseminated Sept. and Nov. 2017 

10 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 11 of 25 

D. Newspaper advertisement 

Now those who suffer from )Of'lt pain 

can get reoof without painful 11]ectoos. 

At less than $2 per d;r/, early users Ike 

Steve Yoong ~ m~~- He says, 

·rvc tnoo mae ~ls than I can ccut. vtittnrt ~ luck. ~la ddferent. 

My knees ald haoos haven't feft tf'5 

good rt yea rst· 

BIFOIRJE: No Jubrlcati ttg flu Id ot A FT .ER: S,'DOvia's acti'lle, ~ la,ts 

cartilage tead.s to paJnful bonr:.. 1ub.rlcat.o r,ointi aoo nourW 

on-bo.n~ rllbb-ing. ~i! .sa it ,;,.'an re-grow! 

Approved By Leading 

Doctors 

The new delivery system for this molecule has caught the attention of leading 

medical doctors. 

“Needle injections for joint pain have been around for years because they work. 

Being able to get the same relief molecule through a pill is amazing. Injections may be a 

last resort, but I’d recommend Synovia at the first sign of pain,” said Dr. Marie Laguna. 

Dr. Gerardo Pereira, a renowned surgeon from Florida says, “Injections aim to 

boost synovial fluid, which lubricates the joint. Those suffering from joint pain usually 

have very little of this fluid. Synovia helps relieve pain by boosting this key lubricant 

without needles.” 

11 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 12 of 25 

Dr. Moss adds, “The research behind the active ingredient in Synovia is very 

exciting. This product is a great choice for those who haven’t had success with other 

joint pain treatments.” 

 -Exhibit D, USA Today, March 21, 2018 

 E. Newspaper advertisement 

Costly Joint-Pain Injections 

Replaced By New $2 Pill 

New pill boosts the same 

lubricating joint fluid as 

expensive and painful injections without using a 

needle. Users report dramatic relief from swelling, 

pain and stiffness without 

side effects and expense. 

Now those who suffer from joint 

pain can get relief without 

painful injections. /\t less than 

$2 per day, early users like Steve 

Vounr. arl' imprl'sst'd. He-says, 

"I've tried more pills than I can 

cowtt, without any luck. Synovia 

is differl'nr . .My knl'l's and hands 

have-n't felt this good in ye.irs!" 

 

* * * 

 -Exhibit E, Chicago Sun-Times, Feb. 14, 2019 

F. Website 

From cortisone shots to almost zero pain! 

For Pam S., severe shoulder pain made life difficult for the 61-year-old. So she 

tried Synovia. After taking the first bottle, she reports, “What a difference 

12 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 13 of 25 

Synovia has made in my life. My pain has improved to the point I hardly notice 

that I have it.” 

-Exhibit F, https://www.joint-solutions.com/relieffrom-pain, Feb. 27, 2019 

G. Newspaper advertisement 

Chronic Joint Pain Sufferer 

Reveals How He No Longer 

Needs His Walker At Age 74 

Iowa man, Harold Jenkins, swears a new $2 pill relieved his pain and 

stiffness in 14 days without side effects – the active ingredient in the pill is 

the same as a very popular German needle-injection treatment. 

* * * 

-Exhibit G, disseminated Feb. 16, 2018 to Feb. 27, 

2018 in markets nationwide 

13 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 14 of 25 

12. Defendants’ advertisements feature numerous consumer testimonials attesting to 

the benefits of Synovia for relief of joint pain, stiffness, and swelling. Defendants solicited most 

consumer testimonials with the offer of free product in exchange for “especially positive and 

inspiring” reviews of Synovia. The persons who responded to this offer had used a prior version 

of Synovia that contained substantially different ingredients. Defendants fabricated the 

remaining consumer testimonials. For example, Defendants’ newspaper advertisements have 

featured “Iowa man, Harold Jenkins” who “no longer needs his walker at age 74.” Defendants 

invented this person, whom they also portrayed in their newspaper and direct mail 

advertisements as “Greg,” the individual who purportedly experienced “95% pain relief so good, 

he gave away his walker.” In addition, many advertisements feature Individual Defendant 

Stephen Young as a testimonialist, though he is identified only as “Steve Young,” an “early 

user” of Synovia, not an owner and officer of A.S. Research. 

13. Defendants’ advertisements for Synovia also feature expert endorsements from 

medical doctors, including Drs. Marie Laguna-Bedia, Jacob Moss, and Gerardo Pereira. None of 

these doctors has expertise in joint pain relief, nor did they review or examine the advertised 

formulation of Synovia. 

14. Consumers who call to order Synovia reach Defendants’ telemarketers, who are 

directed to adhere to a script word-for-word. The script prompts Defendants’ telemarketers to 

ask at the beginning of every call, “After reading the ad, what is it you were hoping Synovia 

could help you with?” Consumers have responded with ailments such as “severe osteoarthritis,” 

“arthritis” in knees, hands, neck, shoulders, and hips, “swelling and joint pain,” “sciatica,” “spine 

problems,” “difficulty walking,” and “herniated discs.” Regardless of the consumers’ responses, 

14 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 15 of 25 

Defendants’ telemarketers, as directed by the script, have stated, “We’ve been getting amazing 

feedback from people with similar issues which tells me Synovia is going to be a great fit for 

you!” 

15. Next, the telemarketer attempts to persuade the consumer to purchase a six-month 

supply of Synovia for a total of $239.70. If the consumer does not accept this offer, the 

telemarketer attempts to sell her a three-month supply for $149.85. There is no shipping and 

handling charge for the multiple-bottle purchases. If the consumer refuses these offers, the 

telemarketer urges her to purchase a one-month supply for $59.95, plus $8.95 shipping and 

handling, for a total of $68.90. After a consumer has agreed to order a one-, three-, or six-month 

supply of Synovia, the telemarketer strongly encourages the consumer to instead purchase 

Synovia “Plus” for an additional $9.95 per bottle. The telemarketer advises the consumer that 

Synovia “Plus” contains “one additional ingredient designed to increase the overall relief and 

speed the repair.” Some consumers agree to this upsell, and some do not. Regardless of the 

consumer’s decision, the product that is shipped to them contains the additional ingredient. 

16. Based on the facts and violations of law alleged in the Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission. Defendants have engaged in their unlawful acts and practices repeatedly over the 

course of two years and continue to disseminate deceptive claims over the internet and through 

newspaper advertising, despite their knowledge of the Commission’s investigation. 

15 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 16 of 25 

VIOLATIONS OF THE FTC ACT 

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

acts or practices in or affecting commerce.” 

18. Misrepresentations or deceptive omissions of material fact constitute 

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

19. Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the dissemination of any 

false advertisement in or affecting commerce for the purpose of inducing, or which is likely to 

induce, the purchase of food, drugs, devices, services, or cosmetics. For the purposes of 

Section 12 of the FTC Act, 15 U.S.C. § 52, Synovia is either a “food” or “drug” as defined in 

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

COUNT I 

False or Unsubstantiated Efficacy Claims 

20. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 to 

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

a. Synovia dramatically relieves swelling, pain, and stiffness in every joint in 

the body, including in the knees, hands, neck, shoulders, hips, and the 

lower back; 

b. Synovia provides relief from severe joint pain and severe joint swelling; 

c. Synovia reduces arthritis pain by 95%; 

d. Synovia provides the same joint pain relief as injected medications; 

e. Synovia rebuilds damaged cartilage; 

16 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 17 of 25 

f. Synovia reverses narrowing of joint space caused by arthritis; 

g. Synovia relieves pain by increasing synovial fluid within joints; 

h. Synovia reduces pain-causing acidity by 57%; 

i. Synovia relieves pain caused by Carpal Tunnel Syndrome; and 

j. Synovia alleviates the pain and loss of strength caused by tennis elbow. 

21. The representations set forth in Paragraph 20 are false or misleading, or were not 

substantiated, at the time the representations were made. 

22. Therefore, the making of the representations as set forth in Paragraph 20 of this 

Complaint constitutes a deceptive act or practice and the making of false advertisements in 

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

COUNT II 

False Claims About Tests and Ingredient 

23. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 to 

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

a. Synovia is clinically proven to reduce arthritis pain by 95%; 

b. Synovia is clinically proven to reduce pain-causing acidity by 57%; 

c. Synovia is clinically proven to restore and repair damaged joint cartilage; 

and 

d. Synovia contains 4 mg of astaxanthin. 

17 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 18 of 25 

24. In truth and in fact: 

a. Synovia is not clinically proven to reduce arthritis pain by 95%; 

b. Synovia is not clinically proven to reduce pain-causing acidity by 57%; 

c. Synovia is not clinically proven to restore and repair damaged joint 

cartilage; and 

d. Synovia does not contain 4 mg of astaxanthin. 

25. Therefore, the making of the representations as set forth in Paragraph 23 of this 

Complaint constitutes a deceptive act or practice and the making of false advertisements in 

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

COUNT III 

False and Misleading Testimonial Claims 

26. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 and 

12, Defendants have represented, directly or indirectly, expressly or by implication, that 

consumer testimonials appearing in their advertising represent the actual experience of 

consumers who have used the advertised product. 

27. In truth and in fact, in many instances, consumer testimonials appearing in 

Defendants’ advertising do not represent the actual experience of consumers who have used the 

advertised product, because: 

a. Many of the testimonials appearing in Defendants’ advertising for Synovia 

represent purported experiences of consumers of a prior version of the product, which 

contained substantially different ingredients; and 

18 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 19 of 25 

b. In other instances, Defendants fabricated testimonials for fictitious Synovia 

consumers. 

28. Therefore, the making of the representation as set forth in Paragraph 26 

constitutes a deceptive act or practice and the making of false advertisements in violation of 

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

COUNT IV 

False or Misleading Claims That Consumer Testimonials Reflect Independent Opinions 

29. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 and 

12, Defendants have represented, directly or indirectly, expressly or by implication, that 

consumer testimonials appearing in their advertising reflect the independent experiences or 

opinions of impartial users. 

30. In truth and in fact, in numerous instances, consumer testimonials appearing in 

Defendants’ advertising do not reflect the independent experiences or opinions of impartial users 

because: 

a. Testimonialist Steve Young, who is frequently quoted in Defendants’ 

advertisements as an “early user,” is Individual Defendant Stephen Young, the 

50% owner and officer of A.S. Research; and 

b. In many other instances, Defendants had offered and provided consumer 

endorsers with free product in exchange for “especially positive and inspiring” 

reviews of Synovia. 

19 
Case 1:19-cv-03423 Document 1 Filed 12/05/19 USDC Colorado Page 20 of 25 

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

constitutes a deceptive act or practice and the making of false advertisements in violation of 

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

COUNT V 

Failure to Disclose Material Connections with Consumer Testimonialists 

32. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 and 

12, Defendants have represented, directly or indirectly, expressly or by implication, that 

consumer testimonialists appearing in their advertising recommend Synovia. 

33. In numerous instances in which Defendants have made the representation set forth 

in Paragraph 32, Defendants have failed to disclose that the consumer endorsers had material 

connections with Defendants, including: 

a. That testimonialist Steve Young, who is frequently quoted in Defendants’ 

advertisements as an “early user,” is Individual Defendant Stephen Young, the 

50% owner and officer of A.S. Research; and 

b. That in many other instances, Defendants had offered and provided 

consumer endorsers with free product in exchange for “especially positive and 

inspiring” reviews of Synovia. 

This additional information would be material to consumers in evaluating the endorsement in 

connection with a decision to purchase Synovia. 

34. In light of the representation described in Paragraph 32, Defendants’ failure to 

disclose the material information as set forth in Paragraph 33 constitutes a deceptive act or 

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practice and the making of false advertisements in violation of Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a), 52. 

COUNT VI 

False and Misleading Expert Endorsements 

35. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraphs 11 and 

13, Defendants have represented, directly or indirectly, expressly or by implication, that the 

doctors identified as Dr. Laguna, Dr. Moss, and Dr. Pereira endorsed the use of Synovia for joint 

pain relief based on an exercise of their purported expertise in joint pain in the form of an 

examination or testing of Synovia at least as extensive as an expert in the field would normally 

conduct. 

36. In truth and in fact, the doctors identified as Dr. Laguna, Dr. Moss, and Dr. 

Pereira did not exercise their purported expertise in joint pain relief in the form of an 

examination or testing of Synovia at least as extensive as an expert in that field would normally 

conduct to support their endorsements. Among other things: 

a. They authorized the use of their quoted statements in connection with a 

prior version of the product containing substantially different ingredients; and 

b. The only documentation they reviewed was a list of the ingredients in the 

prior version of the product; they did not conduct any additional research on the 

product or its ingredients, or engage in further examination or testing of the 

product. 

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37. Therefore, the making of the representations as set forth in Paragraph 35 

constitutes a deceptive act or practice and the making of false advertisements in violation of 

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

COUNT VII 

Deceptive Pricing Claim 

38. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of Synovia, including through the means described in Paragraph 15, 

Defendants have represented, expressly or by implication, that for an additional $9.95 per bottle, 

consumers can purchase Synovia “Plus,” which contains an additional ingredient designed to 

increase overall relief and speed the repair, that is not included in the Synovia product they 

agreed to purchase. 

39. In truth and in fact, in numerous instances in which Defendants have made the 

representation set forth in Paragraph 38, consumers did not receive a product with an additional 

ingredient in return for the additional $9.95 per bottle to obtain the Synovia “Plus” product. In 

fact, Defendants ship the same product to all consumers, whether or not they pay an additional 

$9.95 per bottle. 

40. Therefore, the making of the representation as set forth in Paragraph 38 

constitutes a deceptive act or practice and the making of false advertisements in violation of 

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

CONSUMER INJURY 

41. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act. In addition, Defendants have been 

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

Court, Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm 

the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

42. Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC. The Court, in the exercise of its equitable 

jurisdiction, may award ancillary relief, including rescission or reformation of contracts, 

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

remedy any violation of any provision of law enforced by the FTC. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), 

and the Court’s own equitable powers, requests that the Court: 

A. Enter a permanent injunction to prevent further violations of the FTC Act by 

Defendants; 

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

resulting from Defendants’ violations of the FTC Act, including rescission or reformation of 

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

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

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

 Respectfully submitted, 

 ALDEN F. ABBOTT

 General Counsel 

Dated: December 5, 2019 /s/ Elizabeth K. Nach 

 JANET M. EVANS 

ELIZABETH K. NACH 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Telephone: (202) 326-2125 (Evans), -2611 (Nach) 

Facsimile: (202) 326-3259 

Email: jevans@ftc.gov; enach@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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CERTIFICATE OF SERVICE 

I hereby certify that on December 5, 2019, I caused the foregoing Complaint for 

Permanent Injunction and Other Equitable Relief to be served via electronic mail and overnight 

mail upon the following: 

Albert S. Watkins, Esq. 

Kodner Watkins, LC 

7733 Forsyth Blvd., Suite 600 

St. Louis, MO 63105 

Dated: December 5, 2019 /s/ Elizabeth K. Nach 

ELIZABETH K. NACH 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Mail Drop CC-10528 

Washington, D.C. 20580 

Tel: (202) 326-2611 (Nach) 

Fax: (202) 326-3259 

Email: enach@ftc.gov 

 ATTORNEY FOR PLAINTIFF