Case 8:20-cv-00518 Document 1 Filed 03/05/20 Page 1 of 19 PageID 1 

UNITED STATES DISTRICT COURT 

MIDDLE DISTRICT OF FLORIDA 

FEDERAL TRADE COMMISSION, 

 Plaintiff, 

 v. 

TEAMI, LLC, a limited liability company, 

ADI HALEVY, a/k/a Adi Arezzini, individually 

and as an officer of TEAMI, LLC, and 

YOGEV MALUL, individually and as an officer 

of TEAMI, LLC,

 Defendants. 

Case No. 8:20-cv-518

COMPLAINT FOR PERMANENT 

INJUNCTION AND OTHER 

EQUITABLE RELIEF 

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

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

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

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

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

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

marketing, distribution, and sale of numerous Teami brand tea products that purportedly provide 

various health benefits and Teami brand tea-based skincare products. 

JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1337(a), 

and 1345. 

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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 Teami, LLC (“Teami”) is a Florida limited liability company with its 

principal place of business at 10801 Endeavor Way, Suite A, Seminole, Florida 33777. Teami 

transacts or has transacted business in this District and throughout the United States. 

7. At all times material to this Complaint, acting alone or in concert with others, 

Teami has advertised, marketed, distributed, or sold Teami teas and skincare products to 

consumers throughout the United States. 

8. Defendant Adi Halevy (“Halevy”), also known as Adi Arezzini, is the Chief 

Executive Officer, a co-founder, and a fifty percent owner of Teami. At all times material to this 

Complaint, acting alone or in concert with others, she has formulated, directed, controlled, had 

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the authority to control, or participated in the acts and practices of Teami, including the acts and 

practices set forth in this Complaint. She is responsible for Teami product branding, 

copywriting, and the approval of each product page on Defendants’ website, 

www.teamiblends.com (the “Teami website”). Defendant Halevy has appeared in Teami product 

advertising. She also personally evaluates the ingredients that compose each of Teami’s 

products to determine what benefits each ingredient has alone or in conjunction with other 

ingredients, reviews literature related to each ingredient, and creates samples of each product, 

which she tests herself for taste and efficacy. In addition, Defendant Halevy is responsible for 

the development and approval of Teami’s social media policy, disseminating the social media 

policy throughout the company, and providing instructions to staff on its implementation. 

Defendant Halevy resides in this District and, in connection with the matters alleged herein, 

transacts or has transacted business in this District and throughout the United States. 

9. Defendant Yogev Malul (“Malul”) is the Creative Director, a co-founder, and a 

fifty percent owner of Teami. At all times material to this Complaint, acting alone or in concert 

with others, he has formulated, directed, controlled, had the authority to control, or participated 

in the acts and practices of Teami, including the acts and practices set forth in this Complaint. 

He is responsible for the development and selection of each product Teami offers, as well as the 

Teami website and graphic design of each product page. He also personally evaluates the 

ingredients that compose each of Teami’s products to determine what benefits each ingredient 

has alone or in conjunction with other ingredients, reviews literature related to each ingredient, 

and creates samples of each product, which he tests himself for taste and efficacy. Defendant 

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Malul resides in this District and, in connection with the matters alleged herein, transacts or has 

transacted business in this District and throughout the United States. 

COMMERCE 

10. 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 

11. Since 2014, Defendants have advertised, offered for sale, sold, and distributed 

Teami tea products. These include Teami Profit tea, Teami Alive tea, Teami Relax tea, Teami 

Skinny tea, and Teami Colon tea. Teami Skinny tea and Teami Colon tea are sold together in a 

bundle called the Teami 30 Day Detox Pack. Defendants have also advertised, offered for sale, 

sold, and distributed Teami skincare products including the Teami Green Tea Blend Detox Mask 

and Teami Soothe Tea Infused Facial Oil. In addition to advertising Teami products on the 

Teami website, Defendants have paid celebrities, including Kylie Jenner and Demi Lovato, and 

other influencers to promote them on Instagram and other social media. 

12. Teami Profit tea contains green tea, peppermint leaf, goji berries, red dates, 

roselle, nettle leaf, and lingzhi ganoderma. Teami Alive tea contains green tea, lemongrass, 

honey, and ginger. Teami Relax tea contains peppermint, yarrow, lemongrass, lavender flower, 

chamomile, orange peel, and valerian root. Teami Skinny tea contains oolong tea, yerba mate, 

lotus leaf, lime leaf extract, ginger root, rhubarb root, and jiao gulam. Teami Colon tea contains 

sienna leaf and root, hawthorn berry extract, lotus leaf, lime leaf and extract, psyllium husk seed, 

phaseolus calcaratus seed, rhubarb root, poria cocos stem bark, and valerian root. 

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13. Defendants sell their Teami teas and skincare products on the Teami website. On 

the website, packages of Teami Profit tea, which contain thirteen servings, cost $29.99; packages 

of Teami Alive tea, which contain fifteen tea bags, cost $19.99; packages of Teami Relax, which 

contain thirteen servings, cost $29.99; Teami 30 Day Detox Packs cost $49.99; jars of Teami 

Green Tea Blend Detox Mask cost $29.99; and bottles of Teami Soothe Tea Infused Facial Oil 

cost $39.99. Defendants sell most of their Teami teas and skincare products on 

www.amazon.com. Selected Teami products are also available at retailers nationwide, including 

Vitamin World and Ulta Beauty. 

14. Defendants disseminate or cause to be disseminated advertisements for Teami 

Profit tea, Teami Alive tea, Teami Relax tea, and the Teami 30 Day Detox Pack. Advertisements 

for Teami products include, but are not necessarily limited to, the attached Exhibits 1 through 14. 

These materials contain the following statements and depictions, among others: 

A. Teami Profit Tea 

1. Excerpts from the Teami Profit product page of the Teami website; 

captured on November 6, 2018 

Teami Profit 

DESCRIPTION 

Your body is your temple and deserves to profit from all that nature has to offer. 

Natural tea allows the body to rejuvenate from the inside out, gaining a strong 

internal foundation. For centuries, tea has been used in alternative medicine to 

treat everything from cancer to constipation. The human body needs to have all 

the necessary vitamins and minerals in order to protect itself from infection 

and illness. 

The ingredients in Teami Profit have been shown to: 

.... 

 Fights [sic] against cancerous cells 

(Exhibit 1, portion of Teami Profit product page on the Teami website). 

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2. Excerpts from the 30~7 Best Detox product page of the Teami website; 

captured on November 6, 2018 

The ingredients in Teami Profit have been shown to: 

.... 

 Helps [sic] unclog arteries ... 

(Exhibit 2, portion of Teami 30~7 Best Detox Plan page on the Teami website). 

B. Teami Alive Tea 

Excerpts from the Teami Alive product page of the Teami website; 

captured on November 6, 2018 

Teami Alive 

DESCRIPTION 

Have you ever found yourself feeling “dead”, with zero energy to get motivated in 

your day to day life? Do you get sick on and off, not finding a permanent solution 

to your physical issues? 

.... 

Teami Alive was developed with 3 main ingredients to directly target your bodily 

issues, and solve them! The unique and delicious combination of Ginger Honey - 

Lemongrass - Green Tea can help with: 

The ingredients in Teami Alive have been shown to: 

.... 

 Decreasing [sic] Migraines 

(Exhibit 3, portion of Teami Alive product page on the Teami website). 

C. Teami Relax Tea 

Excerpts from the Teami Relax page of the Teami website; captured on 

November 6, 2018 

Teami Relax 

DESCRIPTION 

.... 

Teami Relax contains potassium, calcium and vitamin B which strengthen the 

immune system, prevent colds, flus and a variety of other illnesses. 

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.... 

The ingredients in Teami Relax have been shown to: 

.... 

 Antibacterial effects can help prevent and treat colds 

(Exhibit 4, portion of Teami Relax product page on the Teami website). 

D. Teami 30 Day Detox Pack 

1. Excerpt from the Teami Detox 30 Day Pack product page of the Teami 

website; captured on November 6, 2018 

Teami Detox 30 Days Pack 

DESCRIPTION 

If you are looking for an amazing detox tea that you can incorporate into your daily 

routine, this is the one for you! The Teami 30 Day Detox Tea will help you 

feel better from the inside out! Getting rid of the toxins that your body is holding 

on to will allow it to function properly, burn the correct amount of calories and 

have natural energy levels every day! 

Our Teami 30 Day Detox Pack includes: 

 30 day supply of our Skinny loose-leaf tea 

 15 colon cleanse tea bags 

The ingredients in our 30 Day Detox Program have been show [sic] to: 

 Boost your metabolism 

 Start burning stored fat 

(Exhibit 5, portion of Teami Detox 30 Day Pack page on the Teami website). 

2. Excerpts from video of Defendant Halevy appearing on the Detox 30 Day 

Pack product page of the Teami website; captured on December 13, 2018 

Our 30 Day Detox program is made up of two teas, our Teami Skinny which you drink 

every single day before breakfast, best recommended time, and our Teami Colon which 

you drink every other night before bed. 

The reason why people need to detox is because of the insane amount of processed foods 

that you’re either eating right now or have eaten in the past and believe me I’ve had a lot 

of pizza in my life so I needed to detox. What it does is it puts in nutrients and vitamins 

in the body. 

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With the Teami Skinny that you drink every single day and then at night time with the 

Teami Colon, you’re actually getting rid of the toxins that are holding your body back 

from being able to digest food properly, from having low metabolism, from having really, 

really sluggish energy throughout the day and by doing this program, all you have to do 

is drink tea and you’ll start seeing results right away. 

Our 30 Day Detox comes with this little cute calendar. On the inside it actually gives you 

tips. Over here you actually have a little calendar that reminds you in the morning to 

drink your Teami Skinny and in the night to drink your Teami Colon. And then we 

definitely want to make sure that you take before and after pictures because we love to 

share your successes and to share your Teami transformations. 

Here are some frequently asked questions about our 30 Day Detox. How much weight 

will I lose when I’m doing the 30 day detox? Great question. The first thing to know is 

that everyone’s different. Everybody has a different amount of weight that they need to 

lose. So not everybody is the same, but the usual average is five to twenty pounds every 

time you do the detox. 

(Exhibit 6). 

3. Excerpt from the Weight Loss page of the Teami website; captured on 

November 6, 2018 

Teami Tea Detox for Weight Loss 

All what [sic] You Need to Know about Detox Tea 

If you [sic] goal is to lose weight quickly, without using teami 

DETOX 

30 DAYS PACK 

[pictures of Teami Skinny 

and Teami Colon and their

Nutrition Facts panels] 

[pull down menu and button 

to add one or more packs to 

cart for $49.99 each] 

any chemicals, 100% natural and safe diet, Reduce 

bloating, burning stored fat and cleaning your body 

from inside outside, you are definitely at the right 

place. 

... 

Grean [sic] Tea ... has been shown to increase fat 

burning and boost the metabolic rate. 

... 

What are the detox tea benefits ? 

Using detox tea for weight loss makes a lot of sense, especially in a world where so many 

diets relies [sic] on weight loss unhealthy diet pills and diet shakes. 

There are lots of benefits using a detox Teas [sic] as your method for losing weight. ... 

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We have selected some of the benefits you can expect to receive when you use detox tea 

as part of your weight loss strategy 

 Boost your metabolism 

 Start burning stored fat 

 Suppress appetite and cravings 

 Naturally raise energy levels 

... 

How to lose weight with detox tea ? 

Did also You tried [sic] different weight loss methods, but without any result? Moving 

forward from one diet to another without reaching your goals might be Frustrating! 

When our body is full of toxins, it is difficult to losing [sic] weight. While detoxifying 

your body get rid of those toxins and results [sic] of weight loss are unbelievable. 

... Detox teas contain specific blends of natural ingredients which flush these toxins and 

chemicals we are consuming out of our vital organs. Those herbs are extremely effective 

for reducing ..., body fat, ... and help our body losing [sic] weight. 

... 

How to Detox your Body with Tea ? How to Use Daily Detox Tea for Weight Loss ? 

For best slimming results we are highly recommending using our 30 Days detox Pack. 

The Teami Detox diet plan includes: 

 30 day supply of our Skinny loose-leaf tea 

 15 colon cleanse tea bags 

TeaMi [sic] Detox will completely change how your body looks and feels in just 30 

days! 

(Exhibit 7, portion of Weight Loss page on the Teami website). 

4. Excerpt from the Colon Cleanse page of the Teami website; captured on 

November 6, 2018 

Colon Cleanse Weight Loss Results 

Colon Cleansing has quickly become one of the Top Trends all over the world and this is 

why. 

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Have you ever started a [sic] dieting, exercising and living a healthier lifestyle but STILL 

don’t see results in your weight?? One of the best health benefits of colon cleansing is 

seeing rapid weight loss that occurs naturally. The toxins in the body that prevent you 

from losing weight easily are now removed by the detox tea and your body can 

FINALLY lose weight on its’ [sic] own! 

Most people that do cleansing programs or detox tea programs do not change their 

exercise or diet habits during the program, but see unbelievable results. Below are some 

Before & After Testimonials from regular people that decided to do a colon cleanse: 

[before and after pictures] 

(Exhibit 8, portion of Colon Cleanse page on Teami website). 

5. Excerpt from September 5, 2018 Instagram post from the official Teami 

account, which has one million Instagram followers 

[Before and after photos appearing teamiblends We’re shouting out our girl 

to depict dramatic weight loss] @qb.love for her amazing 

#TeamiTransformation ☕🍃! She’s down 

TWENTY pounds from doing our 30 Day 

Detox and continues to use it to maintain 

her weight loss! 

 (Exhibit 9). 

6. Excerpts from May 7, 2018 Instagram post by Kathlyn Celeste, a lifestyle, 

family, beauty, and fashion influencer with 187,000 Instagram followers 

kathlynceleste ... 

I made a commitment to myself to stick to 

my @teamiblends Detox program everyday 

for the entire month of May! Every time I’m 

consistent with it, I lose at least 8 LBS. 

(Exhibit 10). 

7. Excerpt from August 15, 2018 Instagram post by Patti Stanger, a reality 

television personality with 920,000 Instagram followers 

pattistanger As I’ve gotten older (and 

much wiser 😉), staying in shape isn’t as 

easy. I love my body, but everyone has 

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problem areas they want to work on. I did 

some research on the @teamiblends 30 

day detox and decided to give it a try, 

because nothing else I’ve used throughout 

the years really worked. I’m two weeks into 

this detox and I can’t believe I’m saying this 

but I’ve already lost 8 pounds! 

(Exhibit 11). 

8. Excerpt from June 5, 2018 Instagram post by Brittanie Evans, a beauty 

influencer with 505,000 Instagram followers 

brittanie_evans My summer body is not 

exactly where I said it would be in 

Fall...whoops😅. Luckily, I started up my 

@teamiblends 30 day detox again to help 

me jumpstart losing a few pounds for 

summer. This detox is my all time 

FAVE...especially because I see a difference 

within like 3 days, and mostly in my tummy 

area. I take it everywhere with me which 

makes it super easy and practical for days 

where I’m crazy busy! I’ve been drinking it 

now for a week and I’ve already lost about 

3 pounds...insane. 

(Exhibit 12). 

9. Excerpts from June 20, 2018 Instagram post by Rasheeda Buckner, a 

rapper, television personality, and fashion designer with 8.4 million 

Instagram followers 

rasheedadabosschick ... 

@teamiblends 30 day detox is where it’s at 

for kickstarting weight loss. I’ve only been 

drinking this detox now for a week and 

already lost over 5 pounds and my bloating 

is gone. Paired with my 21 day 

transformation, I’m feeling amazing and I 

want you guys to do this detox with me to 

get right for summer! Trust me, I’ve tried 

other products like this and wasted my 

money and time, this is the real deal. 

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(Exhibit 13). 

10. Excerpt from an October 8, 2018 Instagram post by Molly Hopkins, a 

reality television personality with 161,000 Instagram followers 

liviraebras1 Since becoming a 

#teamipartner, I can’t shut up about this 

tea !! Any chance I get to tell people about 

it, I talk their ear off. I’m honestly addicted, 

I have it on an automatic renewal😂 I’ve 

lost almost 40 freaking pounds with 

@teamiblends 30 day detox ....and this was 

before I was committed to working out and 

eating healthier ! I used to struggle with 

different weightloss techniques and 

nothing ever seemed to work for my body. 

I was so bloated after I ate, I was sluggish 

and believe me, I really tried everything. 

Obviously, I’m a little more health 

conscious now, but seems like the only 

thing that I see REAL results with.

 (Exhibit 14). 

15. From 2014 through mid-2019, sales of Teami Profit tea, Teami Alive tea, Teami 

Relax tea, and the Teami 30 Day Detox Pack exceeded $15.2 million. 

16. In April 2018, FTC staff wrote to Defendants regarding several Teami product 

endorsements on Instagram by influencers. FTC staff informed Defendants that any material 

connections to any endorsers, such as monetary payments, should be clearly and conspicuously 

disclosed in their endorsements; that to make a disclosure both “clear” and “conspicuous,” 

endorsers should use unambiguous language and consumers should be able to notice the 

disclosure easily without having to look for it; and that because consumers viewing posts in their 

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Instagram feeds typically see only the first few lines of a longer post unless they click “more,” 

endorsers should disclose any material connection above the “more” link. (Exhibit 15). 

17. On May 10, 2018, Defendants implemented a social media policy. Defendants 

assert that they either provided written copies of the policy to paid influencers or included the 

policy as part of the influencers’ contracts with Teami. The policy instructed influencers, 

“[E]nsure that all posts for which you receive free product or any type of compensation as an 

inducement to make the post ... [u]se hashtags or words that clearly let the public know of the 

connection between you and Teami” and “DON’T ... [m]ake the disclosure below the ‘more’ 

button – the disclosure needs to be seen in the first part of your post without clicking anything 

else.” 

18. In many instances, paid influencers were contractually required to obtain approval 

from Teami for their Instagram posts – including the specific text used – before publishing them. 

Yet, numerous Instagram posts published by paid influencers after May 2018 did not comply 

with Teami’s own social media policy. 

19. Defendants did not enforce their requirement that “disclosure[s] need[ed] to be 

seen in the first part of [a] post without clicking anything else.” Between June and late-October 

2018, hundreds of Instagram posts were published by well-known influencers whom Defendants 

paid more than $500 to endorse Teami products. In most cases, consumers viewing these posts 

in their Instagram feeds would not have seen any text disclosing the influencers’ connections to 

Teami unless the consumers took the extra step of clicking to see “more.” 

20. In numerous instances after May 2018, well-known influencers paid by 

Defendants to promote Teami teas and skincare products posted video endorsements on 

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Instagram that did not disclose any connections between the endorsers and Defendants within the 

video itself. In many instances, the text accompanying these videos did not include a disclosure 

in the first two or three lines of text visible to followers of the influencers viewing the posts in 

their feeds without the need to click “more.” Followers who viewed these videos in their 

Instagram feeds – either because the videos played automatically within the mobile app, or 

because the followers chose to play the videos – could have viewed the videos without clicking 

“more.” Examples of such endorsements include: a November 23, 2018 post by Cardi B, a 

rapper with 53.3 million Instagram followers (Exhibit 16.a, b, and c, with almost 20.4 million 

views); a September 24, 2018 post by Brittany Renner, a fitness model and author with 5.2 

million followers (Exhibit 17.a, b, and c, with 984,000 views); an August 16, 2018 post by Katya 

Elise Henry, a social media fitness trainer with 6.2 million Instagram followers (Exhibit 18.a. b, 

and c, with 241,000 views); an October 2, 2018 post by Adrienne Eliza Houghton, a singer, 

actress, and television personality with 4.5 million Instagram followers (Exhibit 19.a, b, and c, 

with 254,000 views); a July 24, 2018 post by Leyla Milani-Khoshbin, a model, actress, and 

television host with 1.1 million Instagram followers (Exhibit 20.a and b, with 428,000 views); a 

July 10, 2018 post by Alexa PenaVega, an actress and singer with 1.6 million Instagram 

followers (Exhibit 21.a, b, c, and d, with 24,000 likes); and a February 4, 2019 post by Jenicka 

Lopez, a reality television personality with 810,000 Instagram followers (Exhibit 22.a and b, 

with 138,000 views). The first page of each exhibit referenced in this paragraph displays the 

Instagram post as it appears when viewed using a desktop computer’s internet browser and not

viewed as part of a follower’s Instagram feed. By contrast, when viewed in a follower’s feed, 

the caption is truncated such that at most three lines of text are visible unless the follower clicks 

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on a link labeled “more.” When viewed in an Instagram feed on a mobile phone, the posts would 

have resembled Exhibits 16.b, 17.b, 18.b, 19.b, and 21.b. 

21. In numerous instances after May 2018, Instagram posts published by well-known 

influencers paid by Defendants to endorse Teami teas and skincare products included an 

endorsement within the photo itself (by clearly showing a Teami-branded product) or within the 

first two or three lines of the post’s caption, but made any disclosures regarding the connections 

between the endorsers and Defendants in text located below the third line of the caption. 

Followers of the influencers viewing the posts in their Instagram feeds would have seen the 

endorsements but would not have seen any disclosures unless they clicked on an option to see 

“more.” Examples of such endorsements include: an August 28, 2018 post by Jordin Sparks, a 

singer-songwriter with 1.7 million Instagram followers (Exhibit 23.a and b); a July 30 2018 post 

by Brittany Renner (Exhibit 24.a and b); a June 15, 2018 post by Princess Mae, an Instagram 

celebrity with 2.1 million Instagram followers (Exhibit 25.a and b); and an August 21, 2018 post 

by Darnell Nicole, a reality television personality with 645,000 Instagram followers (Exhibit 

26.a and b). The first page of each exhibit referenced in this paragraph displays the Instagram 

post as it appears when viewed using a desktop computer’s internet browser and not viewed as 

part of a follower’s Instagram feed. By contrast, when viewed in a follower’s feed, the caption is 

truncated such that at most three lines of text are visible unless the follower clicks on a link 

labeled “more.” When viewed in an Instagram feed on a mobile phone, the posts would have 

resembled the second page of each exhibit. 

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

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

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Commission because, among other things, Defendants engaged in their unlawful acts and 

practices repeatedly over a period of several years and continued their unlawful conduct for 

many months after they learned that the FTC was investigating them. 

VIOLATIONS OF THE FTC ACT 

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

or practices in or affecting commerce.” 

24. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

teas, including Teami Profit tea, Teami Alive tea, Teami Relax tea, Teami Skinny tea, and Teami 

Colon tea, are either “food” or “drugs” as defined in Sections 15(b) and (c) of the FTC Act, 15 

U.S.C. §§ 55(b), (c) and Teami skincare products, including Teami Green Tea Blend Detox 

Mask and Teami Soothe Tea Infused Facial Oil, are “cosmetics” as defined in Section 15(e) of 

the FTC Act, 15 U.S.C. § 55(e). 

COUNT I 

FALSE OR UNSUBSTANTIATED EFFICACY CLAIMS 

25. Through the means described in Paragraph 14, Defendants have represented, 

directly or indirectly, expressly or by implication, that: 

A. Teami Profit Tea treats cancer; 

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B. Teami Profit Tea significantly reduces serum cholesterol and unclogs 

arteries; 

C. Teami Alive Tea significantly decreases migraines; 

D. Teami Relax Tea prevents and treats colds and prevents flus; 

E. Users of the Teami 30 Day Detox lose an average of five to twenty pounds 

every time they do the thirty-day detox; 

F. Users of the Teami 30 Day Detox only have to drink the tea in order to 

experience substantial weight loss; 

G. The Teami 30 Day Detox causes substantial weight loss, including as 

much as forty pounds; 

H. The Teami 30 Day Detox causes rapid and substantial weight loss, 

including as much as four or more pounds per week; and 

I. The Teami 30 Day Detox Pack burns body fat. 

26. The representations set forth in Paragraph 25 are false or misleading, or were not 

substantiated at the time the representations were made. 

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

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

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

COUNT II 

DECEPTIVE FAILURE TO DISCLOSE MATERIAL CONNECTION 

28. In connection with the advertising, marketing, promotion, offering for sale, or sale 

of Teami tea and skincare products, including through the means described in Paragraphs 18 

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through 21, Defendants have represented, directly or indirectly, expressly or by implication, that 

social media posts by influencers about Teami products reflected the views of individuals who 

had used the Teami product. 

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

in Paragraph 28 of this Complaint, Defendants have failed to disclose adequately to consumers 

that the influencers were paid to endorse the Teami products. This fact would be material to 

consumers in evaluating the endorsements of Teami products in connection with a purchase or 

use decision. 

30. Defendants’ failure to disclose adequately the material information described in 

Paragraph 29, above, in light of the representation described in Paragraph 28, above, constitutes 

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

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

CONSUMER INJURY 

31. Consumers have suffered and will continue to suffer substantial injury as a result 

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

as a result of their unlawful acts or practices. Absent injunctive relief by this Court, Defendants 

are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. 

THIS COURT’S POWER TO GRANT RELIEF 

32. 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, 

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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 future violations of the FTC Act by 

Defendants; 

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

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

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

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

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

Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

Dated: March 5, 2020

MICHAEL OSTHEIMER 

CHRISTINE DELORME 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, D.C. 20580 

Tel.: 202-326-2699, -2095 

Fax: 202-326-3259 

Email: mostheimer@ftc.gov; cdelorme@ftc.gov 

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

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