FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

PUBLIC

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF THE ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

DOCKET NO. 9397 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer of HEALTH 

RESEARCH LABORATORIES, LLC and 

WHOLE BODY SUPPLEMENTS, LLC 

RESPONDENTS’ MOTION TO QUASH SUBPOENA TO FORMER LEGAL 

COUNSEL 

Respondents Health Research Laboratories, LLC, Whole Body Supplements, LLC, 

and Kramer Duhon file this Motion to Quash Subpoena to Former Legal Counsel. 

Brief Motion 

On January 10, 2021, Respondents received an email from Complaint Counsel 

Jonathan Cohen to Thomas J. Fleming of the law firm of Olshan Frome Wolosky LLP 

(“Olshan”). Attached to the email were a letter to Thomas J. Fleming and a subpoena to 

Olshan. See Ex. A (Email, letter, and subpoena). From approximately January 2015 

until November 2019, Olshan served as legal counsel for the Respondents with regard to 

disputes with the Federal Trade Commission (“FTC”), including issues related to a Civil 

1 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

PUBLIC

Investigative Demand (“CID”) issued by the FTC and the settlement of a lawsuit initiated 

by the FTC. See Ex. B (Declaration of Kramer Duhon). 

On January 17, 2021, Respondents’ counsel had a meet-and-confer conference 

with Complaint Counsel Jonathan Cohen and Elizabeth Averill regarding the subpoena. 

Because the subpoena seeks privileged attorney client communications and privileged 

work product, Respondents’ counsel requested that Complaint Counsel withdraw the 

subpoena or, at a minimum, remove the request for privileged documents. Complaint 

Counsel refused to withdraw or modify the subpoena, making it necessary to file this 

Motion to Quash. 

Prayer and Conclusion 

This Motion to Quash is unnecessary. The FTC should not be issuing subpoenas 

for opposing counsel’s files. Because of a concern that the privileges could be waived in 

the absence of a motion to quash, Respondents were forced to file this motion. 

Respondents request that the Court quash the subpoena and instruct Complaint Counsel 

to not issue additional subpoenas for privileged documents without first obtaining court 

approval. 

2 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

 

PUBLIC

Dated: February 17, 2021 Respectfully submitted, 

REESE MARKETOS LLP 

By: /s/ Joel W. Reese 

Joel W. Reese 

Texas Bar No. 00788258 

joel.reese@rm-firm.com 

Joshua M. Russ 

Texas Bar No. 24074990 

josh.russ@rm-firm.com 

750 N. Saint Paul St., Suite 600 

Dallas, TX 75201-3201 

Telephone: (214) 382-9810 

Facsimile: (214) 501-0731 

ATTORNEYS FOR RESPONDENTS 

CERTIFICATE OF COMPLIANCE 

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

undersigned counsel represents that, on February 17, 2021, I conferred with Complaint 

Counsel Jonathan Cohen and Elizabeth Averill regarding this motion. Complaint 

Counsel refused to withdraw the subpoena or remove the request for privileged 

documents, making it necessary to file the motion. 

/s/ Joel W. Reese 

Joel W. Reese 

3 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

CERTIFICATE OF SERVICE 

I hereby certify that on February 17, 2021, I filed the foregoing document 

electronically using the FTC’s E-Filing system, which will send notification to: 

April J. Tabor The Honorable D. Michael Chappell 

Acting Secretary Administrative Law Judge 

Federal Trade Commission Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-113 600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 Washington, DC 20580 

ElectronicFilings@ftc.gov 

Elizabeth Averill 

eaverill@ftc.gov 

Jonathan Cohen 

jcohen2@ftc.gov 

COMPLAINT COUNSEL 

/s/ Joel W. Reese 

Joel W. Reese 

4 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit A 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

• 

---

From: Cohen, Jonathan jcohen2@ftc.gov

Subject: In re Health Research Laboratories, No. 9397

Date: February 10, 2021 at 1:43 PM

To: TFleming@olshanlaw.com 

Cc: Averill, Elizabeth eaverill@ftc.gov, Garrett, Celia cgarrett1@ftc.gov, Welby, Grant gwelby@ftc.gov, joel.reese@rm-firm.com, 

josh.russ@rm-firm.com

 Per our call, please see the attached subpoena. 

 Thanks, 

Jonathan Cohen 

Enforcement Division | Bureau of Consumer Protection | Federal Trade Commission 

600 Pennsylvania Avenue, N.W., CC-9528 Washington, D.C. 20580 

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

OlshanSubpoen

aExecuted.pdf

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

l 1nil<'d ~HIies or .<\mi:rica 

H-:lJl:RAL TRADE CO\.Hv11SSIO~ 

600 PL.:)1;1':SYLVANIA AV!:. NW. CC-95~8 

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(202) 326-2993; fa\ crill(,i'ftr.j!o\· 

.Jonathan Cohen 

(102) 326-2!-!-I: jcohcnh1 ft1.:.g0\ 

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VIA EMAIL 

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RE: In re He11lrh Ret,e,1rcl1 L11bomtories, No. 9397 (F.T.C,) 

Subpoena Duet..•,., Tc:c11n1 

Torn, 

Pt.·r our call, encln~cd pk:i-c find :1 subp(ll·t1:1 Ju,,., 1,-,·1111/ ro ( l]sh:111 J • n Jllll' \\'qlnsk) I.LI' 

("Olsh:m") i,sw.:J in the aho\'L' captiDnl'd adjudica1in· prnn•cuing. \ ,·,· I() C:.F.R. ;; .l3-t(1i). \X"c 

:1pprL·ci:itc y11ur w1llin~>11t.•ss to accept ,en ice h1 email. Thl' ;11 r:ichl'J ~cheJulc dcscnbcs thl· 

subr(Jl'na's sc< 'Pl'. \\·l' Im\ c: al,,) l'rn;l( >sL·d c< >ttrtl',1 u }pit·s c,t rhl' ( '.()mpbint and Pnnecrin, t )rdl't. 

\\'e \Y(lulJ i-\hJh c,msiJL·r :tppn,pria!l' acc,m1m,ida1·iun~ t,1 fac1\it:itc ( lbhan\ cnmpliance 

induding, among "rher things. potl°fl ti:ilh 11 i,hJr:J\\ ing thl' :-uhp1 n:11a 11·ithnur rrquJicl' anJ 

continuing to Sl'l'k rhl' ducutrn:nt~ ar issm· from rh1: Resp• )lldt·nts dirl·nh. T<1 datl', Rl'~p1>t1dl'nt~ 

h:1,·l' :i,sc1·tt.·J att<irnl'\' clil·tH rri,·i!l'gt· 1Yith n·spn:t lD aLhice l >lslrnn and others pi-,,Yide<.l anJ furrher 

informed us rhar thn· lack compk·rc :icct.",S r" tht.·tr file. 

l· L'd frl'l' t() c11nract us 11·irh :m\ qm.:srir,ns. 

<:< :: \'ia l-:kc1nini1.: \Liil 

jnd Rl'l'Sl', l '.:-+ (l"d.l-ke!,d[/'1'111 firnt.C(lm) 

Joshu:1 Ru!,s, 1·:"·l· (111,h.Rus,(a•nn firnu.·,1111) 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

SUBPOENA DUCES TECUM 

Provided by the Secretary of the Federal Trade Commission, and 

Issued Pursuant to Commission Rule 3.34(b), 16 C.F.R. § 3.34(b)(2010) 

PUBLIC

1 TO 

Olshan Frame Woloksy LLP 

c/o Thomas J. Fleming, Esq. 

1325 Avenue of the Americas, New York, NY 10019 

2. FROM 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

This subpoena requires you to produce and permit inspection and copying of designated books, documents (as defined in 

Ruie 3.34(b)), or iangible things, at the date and trme specified m Item 5, and at the request of Counsel listed fn Item 9, in 

lhe proceeding described In Item 6. 

3. PLACE OF PRODUCTION 

Federal Trade Commission 

600 Pennsylvania Ave, NW. Mailstop CC-9528 

Washington, DC 20580 

6 SUBJECT OF PROCEEDING 

In the Matter of Health Research laboratories, No. 9397 

7. MATERIAL TO BE PRODUCED 

4. MATERIAL WILL BE PRODUCED TO 

Grant Welby - (202) 326-2136; gwelby@ftc.gov 

5. DATE AND TIME OF PRODUCTION 

February 19, 2021 at 9:00 AM 

See documents and materials identified on the attached Schedule and Exhibits, including the Protective Order 

Governing Discovery Material. 

8 ADMINISTRATIVE LAW JUDGE 9. COUNSEL AND PARTY ISSUING SUBPOENA 

The Honorable D. Michael Chappell 

Complaint Counsel 

Elizabeth J. Averill• (202) 326-2993 

Jonathan Cohen• (202) 326-2551 

Federal Trade Commission 

Washington, D.C. 20580 ___..... 

DATE SIGNED SIGNATURE OF GOCJNSEL J5SUING SUBPOENA 

Feb 9, 2021 

" GENERAL INSTRUCTIONS 

APPEARANCE 

The delivery of this- subpoena to you by any method 

prescribed by the Commission's Rules of Practice is 

legal service and may subject you to a penalty 

1mpose.d by law for failure to comply. 

MOTION TO LIMIT OR QUASH 

The Commlss1on's Rules of Practice require that any 

motion to llrn1t or quash th,s subpoena must comply with 

Commission Rule 3,34(c), 16 C.F R. § 3.34(c), and In 

particular must be filed within the earlier of 10 days after 

service or the time for compliance. The original and ten 

copies of the petition must be flied before the 

Administrative Law Judge and with the Secretary of the 

Commission. accompanied by an affidavit of service of 

the document upon counsel listed ,n Item 9. and upon all 

other parties prescribed by the Rules of Practice. 

FTC Form 70-E (rev. 1197) 

TRAVEL EXPENSES 

The Commission's Rules of Practice require that fees and 

mileage be paid by the party that requested your appearance. 

You should present your claim to counsel listed in Item 9 for 

payment. If you are permanently or temporarily living 

somewhere other than the address on this subpoena and it 

would require excessive travel for you to appear. you must get 

prior approval from counsel listed In Item 9, 

A copy of the Commission's Rules of Practice 1s available 

online at hruu/..bilh'LfTCRulesofPractlce. Paper copies are 

available upon request. 

This subpoena does not require approval by 0MB under 

the Paperwork Reduction Act of 1980. 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

________________________________________________ 

________________________________________________ 

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. 

SCHEDULE FOR PRODUCTION OF DOCUMENTS PURSUANT TO SUBPOENA 

Pursuant to Complaint Counsel’s attached Subpoena Duces Tecum issued pursuant to 16 

C.F.R. § 3.34(b), You must produce the specified materials to Federal Trade Commission 

Complaint Counsel, 600 Pennsylvania Ave, NW, CC-9528, Washington, DC 20580 (c/o Grant 

Welby, Records Custodian). 

SPECIFICATIONS 

(1) Documents Related To, constituting, or analyzing Substantiation Materials for the

Subject Claims. 

(2) Documents Related To Subject Advertisements. 

(3) Any other Documents Related To Respondents’ contentions, made to Complaint

Counsel, that Olshan authorized the Subject Advertisements and/or Subject Claims, approved 

them, or otherwise suggested that Respondents had adequate substantiation to support Subject

Claims. 

(4) Disclaimers or limitations of any sort Related To advice, counsel or

recommendations Olshan provided Respondents about the Subject Advertisements and/or

Subject Claims. 

(5) Complaints of any sort Respondents made concerning advice, counsel or

recommendations that Olshan provided Respondents about the Subject Advertisements and/or

Subject Claims. 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

DEFINITIONS 

PUBLIC

A. “And,” as well as “or,” shall be construed both conjunctively and disjunctively, 

as necessary, to bring within the scope of any Request all information that otherwise might be

construed as outside its scope. 

B. “Any” includes “all,” and “all” includes the word “any.” 

C. “Advertisement” or “Advertisements” or “Advertising” means any written or

verbal statement, illustration, or depiction that promotes the sale of a good or service, or is

designed to increase consumer interest in a brand, good, or service and was disseminated to 

consumers. The terms include, but are not limited to: labeling, packaging, package inserts, 

radio, television, promotional materials, print (including but not limited to brochures, 

newspapers, magazines, pamphlets, leaflets, circulars, mailers, book inserts, letters, catalogues, 

posters, charts, billboards, and point of purchase displays), audio programs transmitted over a

telephone system, telemarketing scripts, on-hold scripts, upsell scripts, training materials

provided to telemarketing firms, program-length commercials or other infomercials, website

content, social media, and other digital content, including electronic newsletters. 

D. “Respondents” mean Health Research Laboratories, LLC; Whole Body

Supplements, LLC; and Kramer Duhon, either individually or collectively. 

E. “Document” or “Documents” mean the complete original and any non-identical

copy (whether different from the original because of notations on the copy or otherwise), 

regardless of origin or location, of any written, typed, printed, transcribed, filmed, punched, or

graphic matter of every type and description, however and by whomever prepared, produced, 

disseminated or made, including, but not limited to, any advertisement, book, pamphlet, 

periodical, contract, correspondence, file, invoice, memorandum, note, report, record, 

handwritten note, working paper, routing slip, chart, graph, paper, index, map, tabulation, 

manual, guide, outline, script, abstract, history, calendar, diary, agenda, minute, code book or

label. “Document” shall also include all Electronically Stored Information. 

F. “Each” includes “every,” and “every” includes “each.” 

G. “Efficacy” means the tendency, propensity or likelihood that the Subject Claims 

are true. 

H. “Electronically Stored Information” or “ESI” mean the complete original and 

any non-identical copy (whether different from the original because of notations, different

metadata, or otherwise), regardless of origin or location, of any writings, drawings, graphs, 

charts, photographs, sound recordings, images, and other data or data compilations stored in any

electronic medium from which information can be obtained either directly or, if necessary, after

You translate it into a reasonably usable form. This includes, but is not limited to, email, text, 

instant messaging, videoconferencing, social media, and other electronic correspondence

(whether active, archived, or in a deleted items folder), metadata, word processing files, 

spreadsheets, databases, and recordings, whether stored on: cards; magnetic or electronic tapes;

disks; computer hard drives, network shares or servers, or other drives; cloud-based platforms;

cell phones, PDAs, computer tablets, or other mobile devices; or other storage media. 

I. “Olshan” means Olshan Frome Wolosky LLP, and any of its partners, associates, 

attorneys, affiliates, successors, subsidiaries, parents, assignees, owners, officers, managers, or

controlpersons. 

2 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

PUBLIC

J. “Identified Products” means Black Garlic Botanicals, BG18 (also known as BG18), The Ultimate Heart Formula, and Neupathic. 

K. “Referring To” or “Relating To” means discussing, describing, reflecting, 

containing, analyzing, studying, reporting, commenting on, evidencing, constituting, setting

forth, considering, recommending, concerning, or pertaining to, in whole or in part. 

L. “Subject Advertisements” mean Advertisements Relating To the Identified 

Products. 

M. “Subject Claims” means: (i) the claims identified in paragraphs 7, 9, 11,13, 14, 

16, 18 and 20 of the Complaint issued in this matter; (ii) prevention or reduction in 

cardiovascular disease risk including, without limitation, by lowering blood pressure, improving

blood flow, reducing cholesterol, or decreasing arterial plaque; (iii) treatment of cardiovascular

disease including, without limitation, by lowering blood pressure, improving blood flow, 

reducing cholesterol, or decreasing arterial plaque; (iv) prevention or reduction in atherosclerosis

including, without limitation, by reducing cholesterol or decreasing arterial plaque; (v) treatment

of atherosclerosis including, without limitation, by lowering blood pressure, improving blood 

flow, reducing cholesterol, or decreasing arterial plaque; (vi) prevention or reduction in 

hypertension including, without limitation, by lowering blood pressure or decreasing arterial

plaque; (vii) treatment of hypertension including, without limitation, by lowering blood pressure

or decreasing arterial plaque; (viii) cure or reduction of diabetic neuropathy including, without

limitation, by improving blood circulation or alleviating nerve pain and discomfort; (ix)

treatment of diabetic neuropathy including, without limitation, by improving circulation or

alleviating nerve pain and discomfort; and (x) any other asserted health benefit purportedly 

associated with any Identified Product. 

N. “Substantiation Materials” means any Scientific Information Relating To the

Efficacy of any Identified Product, including but not limited to tests, reports, studies, clinical

trials, experiments, demonstrations, scientific literature, and written opinions. 

O. “You” or “Your” means Olshan. 

INSTRUCTIONS 

A. Covered Documents. You must furnish every responsive Document in Your

possession, custody, or control, including Documents in the possession, custody or control of

Your attorneys, accountants, agents, affiliates, directors, officers, consultants, employees, 

contractors, bailees, other representatives, or any other person or entity from whom You can 

obtain such Documents by demand, request, or otherwise. 

B. No Duplicative Production. If You previously produced responsive Documents

to the FTC, You need not produce those Documents again. 

C. Document Production. You must produce Documents in the order in which they 

appear in Your files or as electronically stored and without being manipulated or otherwise

rearranged; if Documents are removed from their original folders, binders, covers, containers, or 

electronic source to be produced, then You must specify the folder, binder, cover, container, or 

electronic media or file paths from which such Documents came. In addition, number by page

(or file, for those Documents produced in native electronic format) all Documents in Your

submission, with a unique Bates identifier. 

3 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

PUBLIC

D. Privilege Claims. If You withhold any responsive Document based on a claim of

privilege or any similar claim, You must assert the claim no later than the return date for these

Requests for Production. In addition, submit, together with the claim, a schedule of the items

withheld, stating individually as to each item: (1) the type, specific subject matter, date, and 

number of pages; (2) the names, addresses, positions, and organizations of all authors and 

recipients; and (3) the specific grounds for making the privilege or similar claim. If only a

portion of any responsive material is privileged, You must produce all non-privileged portions. 

E. Electronic Submission of Documents: Please contact the FTC (Grant Welby, 

Document Custodian, (202) 326-2136, gwelby@ftc.gov) before producing documents to the FTC

electronically. We will work with you to arrange a mutually-convenient means of production. 

F. Sensitive Personally Identifiable Information: Unless specifically requested 

herein, do not produce any Sensitive Personally Identifiable Information (“Sensitive PII”) or

Sensitive Health Information (“SHI”) before conferring with Complaint Counsel. You must 

transmit Sensitive PII or SHI to Complaint Counsel. For purposes of these Requests, Sensitive 

PII includes: an individual’s Social Security number alone; or an individual’s name or address

or phone number in combination with one or more of the following: date of birth, Social 

Security number, driver’s license number or other state identification number, or a foreign 

country equivalent, passport number, financial account number, credit card number, or debit card 

number. SHI includes medical records and other individually identifiable health information 

Relating To the past, present, or future physical or mental health or conditions of an individual, 

the provision of health care to an individual, or the past, present, or future payment for the

provision of health care to an individual. 

4 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

______________________________________ 

______________________________________ 

______________________________________ 

PUBLIC

DECLARATION OF RECORDS CUSTODIAN 

PURSUANT TO FED R. EVID. 803(6) AND 902 (11) 

I, __________________, being of legal age, do hereby declare and depose as follows: 

1. I am a custodian of records for Olshan Frome Wolosky LLP (“Olshan”). In that 

capacity, I am responsible for the compilation and maintenance of records pertaining to business 

Olshan conducts. Due to my responsibilities, I have personal knowledge of the manner in which 

the subpoenaed party creates and maintains records of the business that it conducts. 

2. On February __, 2021, in response to a subpoena dated February 9, 2021 issued 

by the Federal Trade Commission, Olshan transmitted to the Federal Trade Commission true and

accurate copies of records maintained by the subpoenaed party consisting of _____ pages, and __ 

files. 

3. The documents produced are true and accurate copies of records maintained by 

the subpoenaed party in the regular course of business. 

4. The records produced in response to the Federal Trade Commission’s subpoena 

were made at or near the time of the occurrence of the matters and transactions set forth therein 

by, or from information transmitted by, a person with knowledge of those transactions. 

5. Olshan made the records produced to the Federal Trade Commission in response 

to the subpoena as part of regular practice in its regularly conducted business. 

6. Olshan kept the records produced to the Federal Trade Commission in response to 

the subpoena in the course of its regularly conducted business. 

I declare under penalty of perjury that the foregoing is true and correct under 28 U.S.C. § 

1746(2). 

Executed on ______________, 2021, in _____________, New York. 

Signature 

Printed name 

Title of records custodian 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

________________________________________________ 

________________________________________________ 

PUBLIC

X180007 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman 

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, 

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

business is 16250 Knoll Trail Drive, Dallas, TX 75248. 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

PUBLIC

4. Respondents have 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. 

5. 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 

6. HRL began selling Black Garlic Botanicals in November 2016. Each capsule 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. 

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

following representations and depictions: 

2 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

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! 

In This Heart Health Breaking News Issue: 

Gardiovascular disease - #1 cause of death in the world! 

Diabetes & venous insufficiency are additional risks . 

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

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

One Man's Personal Journey Created an Empire of Good Health ,, 10 

................ 12 

PUBLIC

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: 

x BLACK GARLIC WORKS WITH YOUR BODY 

x Cholesterol: Black Garlic helps maintain healthy cholesterol 

levels. 

x Clotting: Black Garlic supports healthy platelet aggregation, 

which can help to keep blood circulating and works against 

clotting. 

3 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

PUBLIC

x Supports and helps maintain healthy blood pressure levels to 

combat risks. 

x 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. 

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

healthy blood pressure, cholesterol and triglyceride levels. 

x BLACK GARLIC 

A BREAKTHROUGH FOR 

9 Cholesterol 

9 Blood Sugar 

9 Blood Pressure 

9 The Heart 

9 The Brain 

x “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.

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

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

BG18 

8. WBS began selling BG18 in August 2017. The product 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. 

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

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

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

Your Heart. 

4 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

Could Black Garlic be the Japanese Secret 

to Significant tr Rtducing Heart ,\ltack Risk? For .111 

11at11ral, safe, etfrctivc heart health, nothing l'\'Cll 

compares to Hlad .. Garik! 

That's why, for meny people across the U.S., Black Garlic has been the 

answer to reducing their risk of America's #1 killer ... 

Each year, 635,000 people in the U.S. have their first he.art attack! 

And cardio- vascular disease is the leading r.iuse of global death, rausing 

17.3 miUion deaths a year - a number that's expected to grow to more than 

23.6 million by 2030. 

PUBLIC

x [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. 

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

high blood pressure and lowers high levels of bad cholesterol and 

triglycerides. 

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

because IT WORKS!” ~ Lorraine T. 

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

Exhibit B (BG18 mailer). 

x 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. 

x 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 

10. HRL has been selling The Ultimate Heart Formula (“UHF”) since November 2008. 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). 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. 

5 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

"When it comes to a 

sudden heart attack ... 

What You 

Don't Know 

Richard Cohen, M.D. 

Scientific Advisor CAN Hurt You!'' 

Do you ~ what YOUR arteries look like right now? 

Cl Lill] '--'~~ 

[(b@)□ 

OffiillJ 

Keeping your risk low and your HEART healthy is aJI about keeping your arteries CLEAR! See inside for help from a 

revolutionary, new, hea,rt-helping liquid drop formula ... 

SEE INSIDE to discover a natural nutrient that is up to j_5~_Eff_ECJ1Jl.E 

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

PUBLIC

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

multipage mailers and company websites. An example of a mailer is attached as Exhibit C, 

which contains the following statements and depictions on its first and second pages: 

Exhibit C (The Ultimate Heart Formula mailer). 

6 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

"Lt's no secret ... Heart Attack is the 

#1 killer of men an.d. women." 

"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." 

Avoiding a heart 

attack is all about 

keeping your arteries 

clear, yom 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 cau ea stroke. 

Now there's a new, improved twist 

on our most effective natural, 

heart-helping treatment. 

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

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

including: 

x 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. 

x 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. 

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

x 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! 

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

artery protection ... without side effects! 

7 

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

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 ... 

OPEN NOW to Ease These Issues: 

v Burning 

v nchlng 

V Tlngllng 

v Numbness 

v Constant cold 

AndSO 

MUCHMORE! 

v Swelllng and heaviness 

v Cramps and restlessness ... 

PUBLIC

x 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 

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

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). HRL 

sold a one-month’s supply of Neupathic for $39.95, plus shipping and handling. The 

recommended dosage is two capsules per day. 

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

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

example of a mailer is attached as Exhibit D, which contains the following depictions and 

statements on the first page: 

Exhibit D (Neupathic mailer). 

The mailer continues inside with additional claims: 

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

symptoms below. 

8 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

It can also help address the direct cause 

of nerve pain and neuropathy, damaged 

nerves, excess fluid - and poor circulatio 

Allowing you to: 

... Increase your mobility 

... Relieve nerve pain 

... Reduce swelling and tighcn s 

... Gain back your freedom to mo 

and enjoy your favorite activities again 

9 Shooting pain 

9 Burning 

9 Pins and needles 

9 Electric shock-like pain 

9 Extra sensitivity 

9 Numbness 

9 Throbbing 

9 Tingling 

9 Stinging 

9 Stabbing 

9 Radiating 

Neupathic was specifically formulated with 6 distinct nutrients to help 

address ALL these issues and more. 

x 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. 

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

Exhibit D (Neupathic mailer, p. 11). 

x 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. 

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

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

x “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 

9 

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

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.

Count I 

Respondents’ Unsubstantiated Claims Related to Black Garlic Botanicals 

(HRL and Duhon) 

14. 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; 

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. 

15. The representations set forth in Paragraph 14 were not substantiated at the time the 

representations were made. 

Count II 

Respondents’ Unsubstantiated Claims Related to BG18

(WBS and Duhon) 

16. 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. 

10 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

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. 

17. The representations set forth in Paragraph 16 were not substantiated at the time the 

representations were made. 

Count III 

Respondents’ Unsubstantiated Claims Related to UHF

(HRL and Duhon) 

18. 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. 

19. The representations set forth in Paragraph 18 were not substantiated at the time the 

representations were made. 

Count IV 

Respondents’ Unsubstantiated Claims Related to Neupathic 

(HRL and Duhon) 

20. 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: 

11 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

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

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

21. The representations set forth in Paragraph 20 were not substantiated at the time the 

representations were made. 

Violations of Sections 5 and 12 

22. 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. 

12 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

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 

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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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

NOTICE OF CONTEMPLATED RELIEF 

PUBLIC

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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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

~7JPUBLIC

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 13th day 

of November 2020. 

By the Commission. 

April J. Tabor 

Acting Secretary 

SEAL: 

15 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit A 
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!. . . . . . . . . . . . . . . . . . . . . . . . . . . 12 

PRODUCT 

NOW 

AVAILABLE

HRL004984

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
2 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Cardiovascular Disease: #1 cause of De

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. 

Te 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 afiction seems to spare only the 

Japanese! 

Despite smoking and blood pressure levels 

comparable to that in Western countries, what 

are the Japanese doing diferently? 

Black Garlic. 

Tis discovery in 2001 has turned out to be 

a really powerful elixir for the heart and the 

whole cardiovascular system.

LIFESTYLE CHOICES THAT INCREA SE 

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 tha

HRL004985

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

• • • • 

PUBLIC

Chest pain 

(tightness, 

pressure, 

squeezing) 

Respiratory--­ Cough 

Shortness 

of breath 

• 

Brain 

___--Dizziness 

--- Skin 

Pale skin 

--Pain 

in the neck, 

shoulders or 

upper back 

t;--'----',--- Heart 

Arrhythmias 

- --:~--Gastric 

Nausea 

Vomiting 
HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 3

of 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. 

Tis 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!

EA 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. Tere are 2 

types: 

LDL (Bad) Cholesterol 

• Contributes to plaque (a 

thick, hard deposit that can 

clog arteries & make them 

less fexible). 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. 

on that can help – find out what it is!! HRL004986

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 incre

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 insufciency. 

Chronic venous insufciency occurs when the leg veins do 

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

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

If lef untreated, chronic venous insufciency can cause pain, 

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

Venous insufciency 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

f If If t ~ \ I 

ll\11 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE5

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.

ncreased 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

- -

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

 

 

PUBLIC

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. 

The Miraculous Solution in Japan: 

Black Garlic 

Te 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 afer Hirosaki University 

professor, Jiniti Sasaki, showed that Black Garlic had a 

benefcial efect on harmful cells in the body — the same 

research was conducted using white garlic and did not yield the 

same results. 

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 

ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com HRL004989 6 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

HEALTH RESEARCH LABS – BREAKING NEWS CARDIOVASCULAR ISSUE 7

Blood Pressure — Yet, Low Cholesterol!

art 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 efcacy 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 fow, 

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 efective 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 

ofen trigger the body’s natural function of pumping insulin. Tis 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

------

r 

, 
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.

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

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

down. I was in my early ffies and couldn’t fgure 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 fnd 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 sufering. 

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 ofer 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 efects 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!

“Te 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-Grifn 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 back.

HRL004992

-

WALL STREET 

JOURNAL 
10 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

Black Garlic Can Improv

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. Tis 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! Tank 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 

prove 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 in

fammation, boosts immune 

function, and is toxic to invading bodies.

Te 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.Tis 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 efect. 

Black Garlic positively impacts cellular immunity, 

causing a rejuvenated appearance. 

DETOX

Black Garlic acts as a blood purifer 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. Tis product is 

amazing and I 

can’t live without it.” ~ John I.*

Just 2 capsules 

a Day!

HRL004994

- -- . 

.. 

-- - - -, 
12 ORDER BLACK GARLIC BOTANICALS TODAY CALL 1-888-461-0599 www.HRLsupplements.com

“Research has proven garlic has powerful health benefts, 

but you must take it in high concentrations to have a 

noticeable efect. 

Tat’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 satisfed with 

your purchase — or you don’t pay. 

Health Research Labs products are made 

with premium quality standards and the 

latest scientifc research to ensure you’re 

happy with the results. 

Here’s what we promise:

•	Premier natural products developed by the best international 

scientifc team of experts, doctors, 

and health professionals that meet 

rigid quality specifcations.

•	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 frsthand. 

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. Tis is 

a quality product!” 

~ Rolf M.*

“Black Garlic 

gives me more 

energy, more boost, 

and less stress. 

Tis product is 

excellent!!” 

~ Bobby Mitchell*

“My acid 

refux is a 

thing of the 

past!” 

~ Eldon K.*

HRL004995

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | 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! 

Trough 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 fnancial risk on your part. 

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

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

this trial period of 2 months, you felt that the benefts 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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!

MEGA-INTENSIVE

3 Bottles,

plus 3 Bottles FREE!

Save a WHOPPING $210!

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

-------..J.t■ 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 $198.90) 

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 $127.90) 

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 $86.90) 

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 supply.

❒ 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 $239.90.

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 Labs.

$479.90 $189.95

$239.70 $119.95

$119.85 $79.95

SAVE $289.45!

SAVE $119.75!

SAVE $39.95!

2 MONTH FREE TRIAL

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3 FREE

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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

□ 

[5] ~ ~ ~ 

1111111111~1l~l~l~II I I I I 11111 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Healt

H ReseaRcH labs

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

Sql!74:>Jl!9S81,1 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit B
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

1

7,hroughout liistory ... 

:Has shown an amazing 

power to improve heart 

~nd cardiovascular 

health, maintain . 

normal cholesterol 

levels, boost your 

~mune system. 

And MUct.j ~ORE! 

S • I "..I ee ,n 1ue now ... 

To learn about a extraordinary city in 

Japan where many people live to a 

I 

l 

:~,,,_ _ft Wiw0 

L 

healthy 1 00+ with none of these ~-· 

common health problems we 

suffer from here in America ... ·--i• 

Called by Doctors 

and Scientists: 

'The Perre,:t 

Human 

Heanh 

Food .. " 

I 

·1 

sudported ., -. --!~ii by' ~oncrete 

Clinical Studies: 

wA11 STREET ~~le : 

Richard Cohen, M.D. JOURNAL -~ I Al 

FTC0001

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

Cutting-Ed e Natural Medicine I 

"If you're looking for a stronger heart and complete health overhaul ... 

Black Garlic is one 

of the few "Full Bodv 

Healers'' on eanh 

I trust 1008/o." 

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

Your Heart ... Your Brain ... Hyperglycemia ... Weight Control and more. 

Dear Friend, 

What I'm about to tell you is really 

pretty amazing ... 

You see, there's a place in Japan, 

called the Aomori prefecture, which is 

the garlic capital of Japan ... 

This ONE district produces nearly 

80% of the total garlic crop in Japan. 

But what it's really famous for 

around the world is its fermented, 

healing Black Garlic! A proven superfood that has helped its citizens for 

thousands of years to live longer and 

healthier than you or I can expect to. 

In fact, this Japanese city could be 

considered a miraculous 

"Blue Zone:' much like 

nearby Okinawa. This 

is defined by National 

Geographic Magazine as 

a place where people eat 

a unique diet that gives 

them extraordinary 

health benefits. 

Black Garlic as a healing and 

longevity agent first gained a modern 

following and global popularity after 

Hirosaki University professor, Jiniti 

Sasaki, showed that Black Garlic 

reduced cell size of certain serious 

diseases. 

He knew he was on to something 

important when he conducted the 

same research using white garlic, but 

did not yield the same healthier results. 

And while his clinical research 

confirmed that black garlic absolutely 

has unique healing properties ... 

This was NOT news to the 

Japanese people who 

have been using it for 

thousands of years 

to live longer and 

healthier! 

So while you may 

occasionally see garlic used 

as a ingredient in a natural 

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'f 

j 

supplement to promote good 

health, it is not anywhere near as 

potent and effective as fermented 

Black Garlic extract! 

Because you see, when 

normal white garlic is 

fermented it undergoes an 

amazing transformation 

that COMPLETELY alters its 

chemical makeup ... and turns 

it into a supreme superfood! 

Black garlic is fermented for a 

precise period of time at a high 

temperature, and under high 

humidity. This process turns 

garlic cloves dark, gives them 

a sweet taste, and alters their 

consistency. And it also makes 

them more potent and beneficial. 

The proven health bent!fits 

it offers you are astounding! 

For example: 

■ Black Garlic has been shown to 

have positive effects for more 

than 150 different health issues 

due to its numerous powerful 

natural phyto-chemicals. 

Continued on page 5. 

ONLY Black Garlic 

gives you a whopping 

23 essentia~ health 

improving nutrients. 

6 Essential Minerals: 

• Sodium 

• Potassium 

• Magnesium 

• Calcium 

• Iron 

• Zinc 

18 Important Amino Acids: 

• Isoleucine 

• Luecine 

• Lysine 

• Methionine 

• Histidine 

• Phenylalanine 

• Tryptophan 

• Valine 

• Arginine 

• Alanine 

• Asparagine 

• Glutamine 

• Glycine 

• Praline 

• Serine 

• Tyrosine 

• Cystine 

• Threonine 

BG181sloaded 

with these 

nutrients vour 

bodr needs! 

....____,_.-

Call now 1-888:200-1834 for BG 18 and see how it can help YOU. 3 

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JI 4 ,L 

So how exactly does it help people in 

Japan live longer, healthier lives? 

Let's look at 6 ways it can help 

you do the same ... 

1) It Helps Prevents Plaque Buildup ... 

In fact, it 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. 

2) Reduces Blood Pressure and 

Cholesterol.. Black Garlic helps reduce high 

blood pressure and lowers high levels 

of bad cholesterol and triglycerides. 

3) Helps Naturally Regulate Weight. .. 

Black Garlic helps enhance a healthy weight 

enhances digestion, removes waste, and 

improves energy. It also lessens the effects 

of an unhealthy diet on your blood and liver. 

Black Garlic helps you get the best easiest 

most natural slimming results without the 

frustrations that come with diets. 

4) Immunity Booster ... Black Garlic 

helps reduce inflammation and boost immune 

function. The allicin in black garlic, a sulfur-rich 

compound, is a powerful weapon against 

bacteria, viruses, tung~ and parasites. And it 

contains twice the antioxidant punch of fresh 

garlic. because of the fermentation process. 

Black Garlic may be as effective as a immuneboosting shot and is an ideal preventative 

remedy. 

(( Black Garlic has also been used 

by millions of Americans to 

improve heart health! / 

5) Powerful Anti-Aging ... Black Garlic is 

a great energizer and helps prolong a healthy 

life! It also helps repair age-damaged skin with 

double the amount of antioxidants than regular 

garlic. Like rust attacking metal, free radicals 

eat away at your cells and destroy them, causing 

aging. Black Garlic rejuvenates your body 

by positively impacting cellular health 

and strength. 

6) Amazing 'Detox Agent ... Black Garlic 

acts as a blood purifier and cleanses your body. 

It has antibacterial anti-fungal properties and 

kills bacteria linked to stomach ulcers. Black 

Garlic supports cell regeneration and alkalinizes 

your body to protect against disease. It also 

features abundantly rich oxygen to protect 

against abnormal cell growth, 

viruses, and bacteria. 

And you can 

get all this with 

just TWO BG18 

Black Garlic 

capsules a day! 

--- ----~ ..... 

., -

These statements have not been evaluated by the Food and Drug Administration (FDA). This product is not intended to diagnose, treat, cure or prevent any disease. 

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.. 

Meet Dr. Richard Cohen, MD 

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 a!~e-related illness. 

He completed his under!graduate degree at Duke University with honors. 

And received his medica1I degree from Hahnemann Medical University 

in Philadelphia. Dr. Cohe!n 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 tmatments like BG 18 to help 

his patients eliminate a variety of health problems. 

Continued from page 3. 

■ It can reduce inflammation, 

boost immune function and 

boost cardiovascular health in 

multiple ways. ' 

One of Black Garlic's 

main compounds is 

allicin, a sulfur-rich 

compound that 

is likely its most 

powerful weapon 

against bacteria, 

viruses, fungi, and ~ 

parasites. ~ 

■ Black Garlic has also 

recently been discovered 

to contain TWICE the 

antioxidant punch of fresh 

garlic due to its extensive 

aging process. 

Black Garlic isn't just a 

cure-all for your body ... 

It has significant, unique 

health effects that NO other 

substance on earth has. 

Black Garlic is the best 

example of a food offered 

in abundance by Mother 

Nature, turned into a 

"Health Bonanza" by 

ancient man through a 

simple, yet astonishing 

process, and then 

proven by modern 

science to have a 

revitalizing effect on your 

body! 

Numerous studies show 

Black Garlic's amazing health 

potential in nearly every area 

of your body, from clogged 

arteries to preventing insect 

bites and ear infections. 

Continued next page ... 

Call now l-888·-200-1834 for BGI8 and see how it can help YO~ __ _!. ___ ,

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6 l 

Raw Garlic vs. 

Black Garlic 

There's INO Comparison When it Comes 

to Healthy Benefits For You ... 

As raw garlic ferments and turns black. .. An astonishing transformation takes place that can improve your health and vitality! 

This chart shows just one example of the how the fermentation process changes 

essential amino acids in garlic. These essential amino acids are protein-building 

blocks that are NOT produced by your body. They must be included in your diet. 

Essential Amino Acids Raw Garlic (per 1 OOg) Black Garlic (per 1 OOg) 

lsoleucine 217 mg 371 mg 

Leucine 308 mg 779 mg 

Lysine 273 mg 385 mg 

Methionine 76 mg 210 mg 

Histidine 113 mg 287 mg 

Phenylalanine 183 mg 461 mg 

Tryptophan 66 mg 102 mg 

Valine 291 mg 610 mg 

---- This is only ONE example of what happens to raw garlic during --- the fermentation process. This is truly amazing ... How black garlic 

creates new nutrients that are enhanced by the fermentation process! 

BG 18 is packed with the power of 1200 mg of potent, no-taste, 

no-odor, fermented Black Garlic in daily use capsules. 

There's even solid evidence, as 

seen in Japan's Aomori province, 

and more, that Black Garlic can help 

slow your aging process. 

Black Garlic contains a wide 

range of phytocompounds that act 

together to produce a wide variety 

of responses in your body. It's 

also rich in critical nutrition like 

manganese, calcium, phosphorus, 

selenium, and vitamins B6 and C, so 

it's beneficial for your bones as well 

as your thyroid. 

Garlic also helps your body cleanse 

itself of toxic heavy metals, such as 

lead, mercury, cadmium and arsenic. 

••I 

··='1 ..,1... ~ 

·.J! , ' .. # "'• t ' .. 

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Clinical studlies abound 

on the amazing effectiveness 

of Black Garlic ... 

One of Black Garlic's most potent 

secret weapon is a compound called 

Allicin. 

Researchers have found that it's a 

highly-effective natural "antibiotic" that 

takes care of anything in its path. Even 

better, in the face of Allicin, bacteria 

aren't able to resist it. Something rarely 

seen in medical circles. 

In studies, Black Garlic has shown 

consistent, positive results over 

fresh garlic, says Matthew Budoff, 

a professor at the David Geffen 

School of Medicine at University of 

California, Los Angeles. 

He is also the co-author of a study 

that found Black Garlic reduced the 

amount of soft, newly formed plaque 

in arteries, compared with placebo. 

And in a 2009 animal study, 

Japanese researchers found that 

black garlic was more effective than 

fresh garlic in reducing the size of 

tumors. The study was published in 

the journal Medicinal and Aromatic 

Plant Science and Technology. 

In ano·ther study, black garlic was 

found to have twice the antioxidant 

levels as fresh garlic-as the aging/ 

fermenting process appears to double 

the antioxidants. 

Black garlic is also packed with 

high concentrations of sulfurous 

compounds, especially one called 

s-allylcycteine. 

Science has shown a number of 

health benefits from SAC, including 

inhibition of cholesterol formation. 

Continued next page ... 

Look at What People are Saying About BG 18 ... 1 

"I'm a natural health 

consultant and my wife 

and I have a therapy 

practice where we 

recommend supplements. 

I'm grateful for having 

BLACK GOLD BG-18 in 

my life! The main features I like about this 

product are heart health, a boosted immune 

system and living with less problems." 

- Douglas 5. 

"I'm a senior. 83 years old, 

and just had a good to 

excellent health checkup!• 

- Maria G. 

"I feel stronger, feel my 

general well being is 

better, and also feel I have 

stronger immunity. I also 

have my husband taking 

this product and he also 

will not be without it now!" 

- Jeannine S. 

"My blood sugar levels 

have improved. My A 1 C 

dropped by 2 points. My 

blood pressure has also 

been lowered. I recommend 

this product because IT 

WORKS!" 

- Lorraine T. 

II 

.I 

These testimonials are from real users of BG18. Results may vary based on the user. 

Call now l-888-.200-18:34 for BGl8 and see how it can help YOU ' 1JI 

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I 

I 

8 

Could e1Jck Garlic be the Japanese Se . ret 

to Significa tly Reducing Heart Attack Risk? For all 

natural, safe effective heart health, n9thi11g even 

con1pares to Black Garlic! 

That's why, for many people across the U.S., Black Garlic has been the 

answer to reducing their risk of America's #1 killer ... 

Each year, 635,000 people in the U.S. have their first heart attack! 

And cardio- vascular disease is the leading cause of global death, causing 

17.3 million dea1ths a year - a number that's expected to grow to more than 

23.6 million by 2030. 

However, ca111 you guess which ONE country seems to easily avoid 

this serious epidemic ... Yes, you, guessed it. .. JAPAN! 

Despite smoking and blood pressure levels similar to those in 

Western countries, the Japanese are seemingly IMMUNE 

from the ravages of heart disease. 

So what are they doing differently? They are 

HUGE believers in, and users of, Black Garlic! And this 

discovery has turned out to be a true miracle elixir for 

your heart, and your entire cardiovascular system. 

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. 

Call now for BGI8 and 

claim the same health 

benefits for yourself! 

There,s also great news for those 

who suffer from type 2 diabetes ... 

This condition can wreak havoc 

on your health due to the effects of 

oxidative stress. Uncontrolled diabetes 

may lead to serious complications 

like kidney disease, heart disease, 

nerve damage and vision problems -

sometimes even blindness. 

However, the potent antioxidants 

in black garlic have shown to 

...._____, lessen oxidative stress caused by 

increasing blood sugar levels. Multiple 

studies have found that its high level 

of antioxidants exert an even stronger 

effect than regular garlic and could 

be even more helpful in preventing 

complications of diabetes. 

There's NO doubt ... Black Garlic 

is a perfect "Wonder Food" that 

EVERYONE should consider talcing 

everyday. 

Continued on page 10. 

I 

1 

I 

I 

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Black Garlic also helps you 

in an une~xpected way ... 

When it comes to your weight. 

It's no secret that belly fat and poor heart health go 

hand in hand. In fact, studies show that fat around your 

stomach poses a higher risk than any other fat, and contributes 

to high blood pressure, poor metabolism and high triglycerides. 

Some good news is that just 2 BG 18 capsule a day 

can help you lose wei!ght and reduce your risk in 

several different ways ... 

► Allicin, an active component of black garlic, has shown 

to enhance weight loss. 

► Black Garlic has a hi!~h level of iodine, an effective 

nutrient for treating hyperthyroid conditions, which 

nearly always leads to extra weight gain. 

► Black Garlic also can help process fat, enhance digestion, 

remove waste, and improve energy. 

► Plus, it lessens the effects of an unhealthy diet on your blood 

and liver. So you can lboost your immunity, reduce blood 

pressure, protect your blood vessels from damage, and stop 

inflammation all while helping you reach your ideal weight! 

Clinically proven to wmk ... 

► Korean researchers published findings from an animal weight 

loss study in the Journal of Nutrition. Garlic was shown to 

reduce body weight and showed a significant antiobesity effect. 

~ ► A 2012 study in Nutrition Research and 

;t .. .....__a Practice reported incredible beneficial ( . effects of aged garlic extract on 

cardiovascular risk in postmenopausal 

women. 

► And the American Journal of 

Hypertension showed that allicin 

positively impacts blood pressure, 

insulin, and triglyceride levels. 

' 

ii 

11 

J 

Call now 1-888-:200-1834 for BG 18 and see how it can help YOU. _97 J 

I 

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10 

Continued from page 8. 

So how is Black Garlic 

transformed in to 

something so special? 

Developed in Asia, black garlic 

has been gaining popularity among 

Westerners for several years now, but 

it has recently caught the eye of the 

health-minded due to studies revealing 

its impressive nutritional properties. 

Black garlic is produced by 

"fermenting" whole bulbs of fresh 

garlic in a humidity-controlled 

environment in temperatures of 

about 60 to 90 degrees F for 86 days. 

No additives, no preservatives, just 

pure garlic. 

Once out of the heat, the bulbs 

are left to oxidize. This lengthy 

process causes the garlic cloves to 

turn black and develop a soft texture. 

As the white cloves slowly 

transition into their final black 

appearance, compounds in the 

fresh garlic transform into a whole 

new range of compounds. 

In its potent, Blackened form, 

it is then dried and the powdered 

extract can be put in a <:apsule. Just 

In BG 18 you'll get only 

100% pure, premiumsourced black garlic extract. 

t/ Protect your heart! 

t/ Lower high cholesterol! 

v' Find your ideal weight! 

v' Protect against diabetes! 

v' Cleanse your body 

oftoxins! 

like you'll find in our BG 18 pure 

Black Garlic extract formula. 

Our BG18 Black Garlic 

formula gives you the full, 

raw, health-improving power 

of Black Garlic! 

BGI8 has only ONE purpose: To 

give you the same gift oflongevity, 

health and vitality it gives the Japanese 

people who take it regularly. 

Especially when it comes to ending 

your health problems, low energy and 

issues related to poor heart health, 

diabetes overweight issues, aging 

and more, without drugs. 

You might find other products that 

have ingredients for one or the other of 

these issues, but I guarantee you won't 

find ANYTHING with the 1,000+ year 

track record and unique healing power 

as the Black Garlic in BGI8. 

BG I 8 is the only 100% all natural 

solution you need to help add 

healthy years to your life, and right 

the ship when it comes to your heart 

health! All this in a single, daily dose 

that costs only pennies a day. 

Continued on page 12. 

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A potent, 

i cell-protecting 

antioxid;1nt is 

at the bean 01 

Black Garlic 

8 ecause of its unique composition, black garlic is recognized for its 

high antioxidant content, with one ... 

5-allyl-cysteine ... having huge scientific 

interest for its potency. 

A study published in 2012 in tihe 

Journal Oxidative Medicine and Cellular 

Longevity showed that this antioxidant is 

especially abundant in black garlic, unlike 

common white garlic, which contains only 

small amounts. As a result, black garlic 

can help fight oxidative stress, fret~ radical 

damage and cellular aging. In addition, the 

antioxidant power of S-allyl-cysteine has 

health benefits for the cardiovascular system. 

The cardio•protective 

effect of black garlic. .. 

Black garlic can also improve your lipid 

profile, an important factor in protecting 

against cardiovascular problems. lhis 

beneficial effect was the object of a study 

published in the journal Nutrition, where 

researchers evaluated the potential of black 

garlic among 55 people with high blood 

cholesterol levels. They found increases 

in 'good' HDL-cholesterol in patients 

supplemented with black garlic compared 

with those given a placebo. 

Black garlic also has significant 

anti·inflammatory effects ... 

Black garlic also contains two lt 

compounds -AGE-1 and AGE-2 - which 

a number of studies suggest offer anti- I 

inflammatory help. To evaluate these 

effects, Korean researchers studied levels of l 

molecules in the inflammatory response. 

Published in the journal, Phytotherapy 

Research, their findings confirmed the 

anti-inflammatory action of AGE-1 which, 

reduced levels of nitric oxide and prostaglandin. Secretion of proinflammatory 

cytokines was similarly suppressed by of 

AGE-1. 

These observations suggest that the 

AGE-1 compound present in black garlic can 

have a potent anti-inflammatory effect. 

BG18 can deliver all these health benefits to you! Call now. 

Call now 1-888-200-1834 for BG 18 and see how it can help YOU. --:-- ---· . .. --~· 

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Black Garlic: 

As reported by the 

Wall Street Journal ... 

(( Black garlic has shown potential health 

benefits in animal studies, including a 

report last year by Korean researchers 

that it helped control cholesterol in rats 

fed a high-fat diet. Another aged garlic 

product, called Kyolic from Japan, has 

shown benefits in humans. 

12 

The evidence is "quite compelling" 

that Black Garlic seems to help mitigate 

cardiac risk factors, such as high cholesterol and blood pressure, says David 

L. Katz, director of Yale University's 

Yale-Griffin Prev~ntion ~ I 

Research Center. )) ~ a e 

If you're laoking to add healthy 

years to your life, and want to 

avoid many of the h1ealth problems 

that plague so many seniors, 

call toll-free 1-888-200-1834 

now for BG 18. 

Continued from page 10. 

Reply now 100% 

risk free for all-natural, 

health-restoring, 

risk-reducing BGIB! 

I've arranged for you to try 

premium quality BG18 - riskfree - 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 

BG18 now. 

In my opinion, it is the 

most potent superfood, health-• 

improving formula on the 

market today! And the ONLY 

one I'm confident can improve 

your risky health issues and help 

you get back to normal. 

Don't wait... reply now to 

start on BG 18 and get special, 

first-time buyer only low 

pricing. Plus, if you reply now, 

you'll also get a special offer 

on our astounding Hydrafuel 

product! 

Don't put your good health 

at risk. BG18 is a popular, 

natural solution for men and 

women of all ages who struggle 

to maintain heart health, health}' 

blood sugar levels and more. 

And of course you're backed 

by our 100% Money Back 

Guarantee ... 

Yes, your reply is 100% risk 

free ... If you're not 100% satisfied , 

with your improved health 

after using BG 18, simply send 

it back for a full refund of your 

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Question: 

What is the single, greatest health benefit of Black Garlic? , 

Answer: 

In my experienced medical opinion, Black Garlic's most important 

benefit is its all natural help for heart issues and diabetes. 

From potential life extention to antioxidant help to disease protection, 

no doubt Black Garlic can do a lot to help you. But what I see in so 

many people is poor heart health and serious blood sugar issues. 

And I believe that is where it greatest benefit lies. 

And if you have BOTH, that is a dangerous 

combination ... 

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

• 47% of Americans are unaware that diabetes can 

lead to heart disease. 

c 58% don't know that it can affect their sex life. 

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

I • Having high amounts of sugar in the bloodstream 

develops into fat that clogs, narrows, and inflames 

the blood vessels, causing additional wear and tear. 

_;z l ». I 

I'm confident BG18 can help improve both of these 

dangerous health issues and get you on firmer footing. 

And no other natural heal,er can help protect you from 

both like Black Garlic can. Call now for BG18 and see 

for yourself. 

purchase price within 60 days. 

No questions asked. 

I look forward to hearing from you! 

Sincerely, 

f ;£1 tL lllD. 

Richard Cohen, M.D. 

Whole Body Supplements 

Medical Director 

P.S. Amazing BG18, packed with 

1200 mg of pure Black Garlic gives 

you the power of a variety of needed 

good-health nutrients ail in two 

capsules! 

Most notably, it can help your 

entire cardio system 

run smoothly. Reply 

now if you want to 

enjoy the longer life 

Call now 1-888-200-1834 for BG 18 and see how it can help YOU. 13 

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and ultimate heath benefits Japanese 

people enjoy every day! BG 18 is 

100% effective and safe to use daily! 

Remember, thousands of people have 

already used it to help extend the 

healthy years of their life! Call now 

risk free 1-888-200-1834. 

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

email newsletter! It's called Dr. Cohen's 

Healthy News Now ... and it discusses the 

latest news on many different health 

issues. Our customers love it! Just give 

us your email address when you place 

your orde.r for BG18. 

Get UP to 

1 Bonles 

of BG18 

FREE! 

That's right. .. 

See your Risk Free Reply 

Fonn now for details! 

Proven help is on the way 

for your heart and entire 

body! 

--- ___,,, 

Grab This mbo Offer and Save 

14 

When you repl)r for BG18 now, you also 

qualify for a special, discounted supply 

of our trusted Hydrafuel Formula. 

Support your cellular hydration with this premium formula 

that contains 14 vitamins and minerals to help keep your cells 

100% heathy 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 

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Improve heart health, boost energy, improve sexual health, 

beat stress, im'prove performance and reduce wrinkles ... These 

are just a few of the benefits found in HydraFuel. 

It can fill in your cells' nutrient gaps to give your health a 

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Try the amazing powers of HydraFuel for yourself. You'll SEE 

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Don't wait. .. Reply now and get this 

perfect companion product to BG 18. 

'-----"' 

• Vitamin C 

• Vitamin E 

• Vitamin 81 

• Riboflavin 

• Niacin 

• Vitamin 86 

• Folic acid 

• Vitamin 812 

• Biotin 

• Pantothenic acid 

• Calcium 

• Magnesium 

• Zinc 

• Chromium 

• SynerTea® 

• Amla 

• Spectra: which 

contains over 2 

dozen fruit and 

vegetable extracts 

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! 

BG18 Risk I 

. 

Free Repli, Form 

Up to $384.85 in to al savings and get free Shipping! 

~YES ! I'm ready to reap the same amazing health rewards the Japanese have enjoyed for 

centuries. I've seen the impressive research on Black Garlic from leading medical institutions around the 

world that prove taking black garlic can substantially improve my health! I understand I'm covered by 

your 60-day money back guarantee ... Either BG 18 works as promised, or l can get a full and fast refund . 

. Please send me the following supply: 

0 SUPER-INTENSIVE: I get a 5 month supply, plus a 7 month bonus $6e4:40 5219•

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D TOTAL PACKAGE: I get everything is the Mega-Intensive Package $604:40 $249.95 

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Select Your Preferred Met.hod of Payment: 

D Enclosed is my check, cash or money order for: $ _____ _ (Make check payable to Whole Body Supplements, 165 Pleasant Ave., South Portland, ME 04106) 

D Please bill my credit card: D~ D. , ~ .. Ll5~ 

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enclosed envelope: 

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www.WholeBodySupplementcom 

Try the BG18 Risk-Free For_,60.Days. 

If You Don't Feel 100% Better - YOlI'LL GET YOUR MONEY BACK! 

YOU will be the only judge. You've .read about the amazing 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

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transforming 

people's health, 

especially 

for their 

HEARTS. 

"Nothing improves 

lives like this does.'' , 

t v Increases energy 

ti Strengthens the immune system 

v Promotes anti-aging effects 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit C
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 ● 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

► 
“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 ● 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Oichard 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...

■ The risk of heart-related issues can be 

minimized and give you greater peace of mind.

■ 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 ● 3

(continued on page 5)

Eydroxin 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.

HRL005070

TJie 

Ultimate 

Heart 

FQmtuln

-­·

--·
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

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

Bven 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 fow 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 blocRed that blood fow 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 signifcant 

limitation to blood fow or cause symptoms.

Severe heart blockage is typically greater 

than 70%. This degree of narrowing results in 

signifcantly reduced blood fow 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 fow 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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I 
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Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 ● 5

■ You could help maintain normal cholesterol 

and blood pressure.

■ You could improve your circulation.

■ 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 efective 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!

HRL005072

The 

Ultimate 

Heart 

Formula .......... ..... ~~-==-
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

Call Toll-Free 888-462-9386 Help Keep Your Arteries Clear and Enjoy More Peace of Mind! ● 6 

and help prevent an unexpected heart attack.

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

eported and loss of blood flow to the heart, r

 in their patients’ “significant improvements”

symptoms.

Two studies reported in the medical journal, 

, that 51% and 43% of people were Pharmacotherapy

able to get off blood-pressure and cardiovascular 

medication with the help of CoQ10 treatment.

In another CoQ10 study, reported in the 

, 100% Clinical Investigator medical journal, 

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

 80% experienced beneficial blood- And

pressure levels.

e, in yet another study involving Furthermor

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

results showed that 75% of people experienced 

 also Ultimate Heart Formula The 

contains a powerful, clot-busting agent!

Qhe Ultimate Heart Formula gives you 

the power of a Japanese soy plant 

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

 (nd recent scientifc medicinal history!

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!

A and CoQ10, the Like EDT

results from the clinical studies carried 

 For out on Natto have been remarkable!

example, researchers from JCR Pharmaceuticals, 

Oklahoma State University, and Miyazaki Medical 

e College, gave people 200-grams of Natto befor

The result... breakfast. 

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...

n another study, performed by Miyazaki I

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...

epresents the most exciting develop- “Natto r

ment in the prevention and treatment of cardiovascular related problems. We have fnally found 

a potent natural agent that can help thin and 

dissolve clots efectively, without side-efects.”

 According to the : The bottom line is

, up to American Thrombosis Association

20-million cases of blood clot-related illnesses 

are reported each and every year. But now, 

, Ultimate Heart Formula thanks to Natto in the 

you have a proven safe way to help your body 

support healthy arteries.

(continued on page 8)

HRL005073

tfl,, 

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 ● 7

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 efects. 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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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

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

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)

Qhere 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.

HRL005075

-

- v;;- Ultima1" 

Heart 

Formula 

--- ._,-;:_..;..~ 
Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 ● 9

“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. Hufman

“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. (fter trying diferent 

things, I tried the Ultimate Heart Formula 

which worked great. Of course the doctors 

don’t want to hear about how good the natural 

stuf can be, but for me I»m sticRing with it. ThanR 

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

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 

T 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 

specifcally shown to help improve the efects 

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 

remarRable diferences 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!

HRL005077

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
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Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 ● 11

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 benefcial 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 fow.

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 fow 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 ofer benefts 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 

infammation 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!

HRL005078

_,,.._,.,;,,ol.. 

Th.e 

Wtimate 

Heart 

Formula ....._..........,....,,..... ':.~~.~-· 

~ •i.at~ 
12 ● Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386

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 

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“

”

If you can keep YOUR arteries clear, 

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HRL005079

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Help Keep Your Arteries Clear and Enjoy More Peace of Mind! Call Toll-Free 888-462-9386 ● 13

On the other hand, heart/cardio medications 

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I look forward to hearing from you!

Sincerely,

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Health Research Labs, Scientific Advisor

P.S. Our Ultimate Heart Formula can help 

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

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Now... and it discusses many different health 

issues. Our customers love it! Just give us your 

email address when you place your order.

Vou can enjoy a healthy 

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FREE SHIPPING!

Richard Cohen

HRL005080

Tlie 

Ultimate 

HMrt 

Form11la

-......-............ ';.-=.,."":!::::::"' ---1 

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

Pupport your cellular hydration with 

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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.

Grab This Combo Offer and SAVE:

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 —Dr. Cohen

Our Iron-Clad Guarantee: 

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HRL005081

--··-.. ••• ta The 

Ultimate 

Heart 

Formula

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15

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worry less and have more confidence in my heart health with this natural symptom-relieving, 

heart health formula! I understand it is doctor-formulated and guaranteed to give my entire cardio system 

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Health Research Labs, 

165 Pleasant Avenue, 

South Portland, ME 04106

1. By Mail: Use the enclosed 

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Our Iron-Clad Guarantee: Try Ultimate Heart Formula Risk-Free For 60 Days.

If You Don’t Feel 100% Better — YOU’LL GET YOUR MONEY BACK!

YOU will be the only judge. You’ve read about the cardio-improving and 

heart-strengthening power of Ultimate Heart Formula. For up to 60 days, you can 

use it completely risk free in your own home and see your results. If you are not 

100% satisfied, you can request a full refund. No questions asked. —Dr. Cohen

Ultimate Heart Formula Risk-Free Reply Form

7 FREE

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC Give Your Heart and Arteries a Fresh Start! And, give yourself more peace of mind as you reduce the risk of heart problems. Give Your Heart and Arteries a Fresh Start!

“That’s right... Peace-Of-Mind, 

knowing that every day you are 

doing something to help your 

heart stay healthy.

”

—Richard Cohen, M.D., Scientific Advisor

Thousands of people just like you have already discovered the powerful effect of our Ultimate Heart Formula.

See their amazing stories inside now...

UHF-D2-US

Health Research Labs

165 Pleasant Ave.

South Portland, ME 04106

PRSRT STD

U.S. Postage

PAID

Health

Research Labs

HRL005083

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit D
NATURAL NERVE PAIN RELIEF ● 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:

✔ Burning

✔ Itching

✔ Tingling

✔ Numbness

✔ Constant cold

✔ Swelling and heaviness

✔ 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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 ● 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

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----,•- , 

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~,,:. 
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 ● 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)

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4 ● 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.

✔ Shooting pain

✔ Burning

✔ Pins and needles

✔ Electric shock-like pain 

✔ Extra sensitivity

✔ Numbness

✔ Throbbing

✔ Tingling

✔ Stinging

✔ Stabbing

✔ Radiating

Neupathic was specifcally formulated 

with 6 distinct nutrients to help address 

ALL these issues and more.

HRL005039

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Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 ● 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 fve 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 afect 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

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6 ● 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 ● 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 fuid, 

that can make your legs heavy, tired and 

bulge with veins.

And unfortunately, this can eventually 

also do nerve damage as that extra fuid 

puts pressure on those nerves and causes 

damage.

Take a look... If your own legs and 

feet are swollen, infamed, 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
8 ● 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:

■ Lack of coordination

■ Pain and numbness

■ Tingling in hands or feet

■ Sensory loss 

■ 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495 ● 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 stifness. 

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 

frst 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 defnitely feel 

more comfortable.”

—Margaret J.

HRL005044

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
10 ● 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:

■ You find it 

difficult to walk 

because you can’t 

feel the ground 

under your feet.

■ You can’t stop 

the itching, burning, 

stabbing, pins and 

needles or tingling in 

your legs and feet.

■ Your hands, 

feet and legs are 

always cold.

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

because of pain and discomfort.

■ It’s hard to keep your balance on unsteady 

legs and feet.

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

enjoy your favorite activities.

■ You feel trapped and immobile because of 

your unhealthy legs and feet.

■ 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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | 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 ● 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 sufer 

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

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
12 ● Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

And you’ll be backed by our 

iron-clad GUARANTEE:

If you’re not 100% satisfied with the 

soothing, symptom-relieving results of 

Neupathic, you can return it anytime 

within 60 days for a full refund. 

No questions asked.

Neupathic’s twice-a-day, easy-to-swallow 

capsules are rapidly absorbed and speed 

throughout your system to bring you fast relief.

Neupathic can make getting back 

on your feet fast and easy...

In my opinion as a doctor, there is nothing

stronger to help you move easier, suffer less, 

sleep better and get more done than by using 

Neupathic.

Reply now for Neupathic and get the 

nerve-pain-easing power of these concentrated 

nutrients in each capsule.

I give you my personal guarantee that it does 

And then having weeks, months and 

even years of constant comfort!

Imagine enjoying a whole day without ever

thinking of the PAIN in your feet!

HRL005047

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
work. It can help you quickly feel more energetic 

than you have in years.

As a first-time user, we’ve made special 

arrangements for you to try Neupathic for 

60 days with no risk.

And remember, if you’re not utterly delighted 

with your results by day 60, just call or email us, 

then send back the unused portion to us — and 

we will never charge you another cent.

This is a 100% iron-clad guarantee, so 

you can’t possibly lose!

Plus, you’ll get FREE SHIPPING and a 

FREE Gift!

Don’t wait... Reply now to get your 

supply of Risk Free Neupathic! 

Yours for Healthy Legs and Feet,

 Richard Cohen, M.D. 

Scientific Advisor

P.S. Neupathic can help get you moving 

comfortably again! 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 shown to help reverse 

damaged nerves to help 

you feel great all day 

and all night! Call now 

888-761-5495.

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

Are you ready to 

walk, dance and 

move easily again!

What have your legs kept you from 

enjoying...

✔ Taking a long walk

✔ Running or jogging

✔ Playing tennis or golf

✔ Working in your yard

✔ Sleeping comfortably at night

✔ Taking vacations

✔ Dancing

✔ Going for a drive

✔ Fishing

✔ Serving others

✔ Sitting through 

a movie 

✔ Driving

✔ Playing with 

grandkids 

✔ Biking

DON’T MISS OUT 

ANY MORE!

CALL NOW toll free to soothe your 

diabetic nerve pain and more...

888-761-5495

Richard Cohen

Call now toll free or mail the 

Reply Form on the next page for 

soothing Neupathic! And remember, 

you get FREE SHIPPING!

HRL005048

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
14 ● Soothe Diabetic Nerve Pain and More! Call Now Toll Free 888-761-5495

When you request your supply of Neupathic, you also qualify for a special, discounted

supply of our Regimen Cell Rejuvenation Formula.

Hit Your Body’s “RESET” Button... And Help Regenerate 

All 50 Trillion of Your Body’s Cells to “Primary Purity!”

Top U.S. Medical Institutions Verify the Power of the 25 Nutrients 

in Our Regimen Cell Rejuvenation Formula. So You Can

Help Restore Every Part of Your Health:

✔ Move Freely

✔ Maintain Healthy

Cholesterol

✔ Promote Healthy

Hair Growth

✔ Boost Energy

✔ Diminish Wrinkles

See What Happens When ALL 50 TRILLION of 

Your Cells Experience a “Rebirth!”

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.

Grab This Combo Offer and SAVE:

✔ Maintain Optimal Weight

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Discounted

Pricing!

YOUR FREE GIFT!

Get a FREE Supply of Soothing Glucophene Pain-Relieving Cream!

Yours 

FREE!

GET YOUR FREE TUBE NOW WHEN YOU BUY AT LEAST 

2 BOTTLES OF NEUPATHIC!

With Neupathic working inside to help your nerve pain and other 

lower leg health problems, Glucophene cream works outside to 

help you instantly, upon application, reinvigorate your legs and feet.

Call now toll-free, or return the form on the next page to get your 

FREE supply with your 2 bottle, or more, supply of Neupathic.

This is an exclusive offer that is not available anywhere else.

✔ NO RISK ✔ NO COST ✔ COMPLETELY FREE TRIAL!

HRL005049

PUBLIC FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

■ 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!

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

supply absolutely FREE! I pay only $129.95 and get FREE SHIPPING!

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

supply absolutely FREE! I pay only $79.95 and get FREE SHIPPING!

■ INTENSIVE: I get a 1 month supply for only $39.95 + $5.95 S&H!

■ TOTAL PACKAGE: I get everything in the Mega-Intensive

Package plus buy 3 months of Regimen for only $119.95 and get

another 3 months FREE! All of this with FREE SHIPPING!

Neupathic Risk-Free Reply Form

■ 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 

guaranteed to give my legs and feet new life and energy. I understand I’m covered by your 60-day 

money back guarantee... Either Neupathic works for me, or I can get a full and fast refund. 

Our Iron-Clad Guarantee: Try Neupathic Risk-Free For 60 Days. 

If You Don’t Feel 100% Better — Day and Night — YOU’LL GET YOUR MONEY BACK!

YOU will be the only judge. You’ve read about the symptom-improving and 

invigorating power of Neupathic. For up to 60 days, you can use it completely 

risk free in your own home and see your results. If you are not 100% satisfied, 

you can request a full refund. No questions asked. —Dr. Cohen

SELECT YOUR PREFERRED METHOD OF PAYMENT:

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

amount of: $ ____________________________________________________

■ Please charge the full amount to my credit card:

■ ■ ■ ■

■■■■ ■■■■ ■■■■ ■■■■ ■■■■

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

2. By Phone: CALL TOLL-FREE

888-761-5495

3. Online:

www.HRLsupplements.com

3 Ways to Place Your Order:

Subtotal ________________

S&H ________________

*RUSH Processing + 4.95

TOTAL ________________

15

7 FREE

3 FREE

1 FREE

$199.95

SAVE $350.85! 

Only 55 cents/day

$129.95

SAVE $145.45! 

Only 66 cents/day

$79.95

$239.95

SAVE $310.85!

Quantities are limited! Please order by next Tuesday! 

CALL NOW TOLL FREE: 888-761-5495

■ Please remove my name from future mailings.

✔

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

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

3 FREE 3 FREE

+

HRL005050

---

---

---

--

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[] 

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□□□□ □□□□ □□□□ □□□□ □□□□ 

-

a 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC 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!”

If you feel trapped by your legs... If you are in pain, no matter whether you 

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

“You will read about a doctor-formulated nerve 

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 

● SPECIAL EDITION

“

See Inside Now...

□ HRL005051
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

A 

__________________________________________

In the Matter of 

Health Research Laboratories, LLC,

 a limited liability company, 

Whole Body Supplements, LLC,

 a limited liability company, and 

Kramer Duhon,

 individually and as an officer of 

)

)

)

)

)

)

)

)

)

)

) 

 Docket No. 9397 

 Health Research Laboratories, LLC, )

 and Whole Body Supplements, LLC, )

) 

Respondents. )

__________________________________________)

PROTECTIVE ORDER GOVERNING CONFIDENTIAL MATERIAL 

Commission Rule 3.31(d) states: “In order to protect the parties and third parties against 

improper use and disclosure of confidential information, the Administrative Law Judge shall 

issue a protective order as set forth in the appendix to this section.” Pursuant to Commission 

Rule 3.31(d), the protective order set forth in the appendix to that section is attached verbatim as 

Attachment A and is hereby issued. 

ORDERED: 

D. Michael Chappell 

Chief Administrative Law Judge 

Date: November 20, 2020 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

ATTACHMENT A 

For the purpose of protecting the interests of the parties and third parties in the abovecaptioned matter against improper use and disclosure of confidential information submitted or 

produced in connection with this matter: 

IT IS HEREBY ORDERED THAT this Protective Order Governing Confidential 

Material (“Protective Order”) shall govern the handling of all Discovery Material, as hereafter 

defined. 

1. As used in this Order, “confidential material” shall refer to any document or portion thereof 

that contains privileged, competitively sensitive information, or sensitive personal information. 

“Sensitive personal information” shall refer to, but shall not be limited to, an individual’s Social 

Security number, taxpayer identification number, financial account number, credit card or debit 

card number, driver’s license number, state-issued identification number, passport number, date 

of birth (other than year), and any sensitive health information identifiable by individual, such as 

an individual’s medical records. “Document” shall refer to any discoverable writing, recording, 

transcript of oral testimony, or electronically stored information in the possession of a party or a 

third party. “Commission” shall refer to the Federal Trade Commission (“FTC”), or any of its 

employees, agents, attorneys, and all other persons acting on its behalf, excluding persons 

retained as consultants or experts for purposes of this proceeding. 

2. Any document or portion thereof submitted by a respondent or a third party during a Federal 

Trade Commission investigation or during the course of this proceeding that is entitled to 

confidentiality under the Federal Trade Commission Act, or any regulation, interpretation, or 

precedent concerning documents in the possession of the Commission, as well as any 

information taken from any portion of such document, shall be treated as confidential material 

for purposes of this Order. The identity of a third party submitting such confidential material 

shall also be treated as confidential material for the purposes of this Order where the submitter 

has requested such confidential treatment. 

3. The parties and any third parties, in complying with informal discovery requests, disclosure 

requirements, or discovery demands in this proceeding may designate any responsive document 

or portion thereof as confidential material, including documents obtained by them from third 

parties pursuant to discovery or as otherwise obtained. 

4. The parties, in conducting discovery from third parties, shall provide to each third party a 

copy of this Order so as to inform each such third party of his, her, or its rights herein. 

5. A designation of confidentiality shall constitute a representation in good faith and after 

careful determination that the material is not reasonably believed to be already in the public 

domain and that counsel believes the material so designated constitutes confidential material as 

defined in Paragraph 1 of this Order. 

2 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

PUBLIC

6. Material may be designated as confidential by placing on or affixing to the document 

containing such material (in such manner as will not interfere with the legibility thereof), or if an 

entire folder or box of documents is confidential by placing or affixing to that folder or box, the 

designation “CONFIDENTIAL – FTC Docket No. 9397” or any other appropriate notice that 

identifies this proceeding, together with an indication of the portion or portions of the document 

considered to be confidential material. Confidential information contained in electronic 

documents may also be designated as confidential by placing the designation “CONFIDENTIAL

– FTC Docket No. 9397” or any other appropriate notice that identifies this proceeding, on the 

face of the CD or DVD or other medium on which the document is produced. Masked or 

otherwise redacted copies of documents may be produced where the portions deleted contain 

privileged matter, provided that the copy produced shall indicate at the appropriate point that 

portions have been deleted and the reasons therefor. 

7. Confidential material shall be disclosed only to: (a) the Administrative Law Judge presiding 

over this proceeding, personnel assisting the Administrative Law Judge, the Commission and its 

employees, and personnel retained by the Commission as experts or consultants for this 

proceeding; (b) judges and other court personnel of any court having jurisdiction over any 

appellate proceedings involving this matter; (c) outside counsel of record for any respondent, 

their associated attorneys and other employees of their law firm(s), provided they are not 

employees of a respondent; (d) anyone retained to assist outside counsel in the preparation or 

hearing of this proceeding including consultants, provided they are not affiliated in any way with 

a respondent and have signed an agreement to abide by the terms of the protective order; and (e) 

any witness or deponent who may have authored or received the information in question. 

8. Disclosure of confidential material to any person described in Paragraph 7 of this Order shall 

be only for the purposes of the preparation and hearing of this proceeding, or any appeal 

therefrom, and for no other purpose whatsoever, provided, however, that the Commission may, 

subject to taking appropriate steps to preserve the confidentiality of such material, use or disclose 

confidential material as provided by its Rules of Practice; sections 6(f) and 21 of the Federal 

Trade Commission Act; or any other legal obligation imposed upon the Commission. 

9. In the event that any confidential material is contained in any pleading, motion, exhibit or 

other paper filed or to be filed with the Secretary of the Commission, the Secretary shall be so 

informed by the Party filing such papers, and such papers shall be filed in camera. To the extent 

that such material was originally submitted by a third party, the party including the materials in 

its papers shall immediately notify the submitter of such inclusion. Confidential material 

contained in the papers shall continue to have in camera treatment until further order of the 

Administrative Law Judge, provided, however, that such papers may be furnished to persons or 

entities who may receive confidential material pursuant to Paragraphs 7 or 8. Upon or after 

filing any paper containing confidential material, the filing party shall file on the public record a 

duplicate copy of the paper that does not reveal confidential material. Further, if the protection 

for any such material expires, a party may file on the public record a duplicate copy which also 

contains the formerly protected material. 

3 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC

 

 

PUBLIC

10. If counsel plans to introduce into evidence at the hearing any document or transcript 

containing confidential material produced by another party or by a third party, they shall provide 

advance notice to the other party or third party for purposes of allowing that party to seek an 

order that the document or transcript be granted in camera treatment. If that party wishes in 

camera treatment for the document or transcript, the party shall file an appropriate motion with 

the Administrative Law Judge within 5 days after it receives such notice. Except where such an 

order is granted, all documents and transcripts shall be part of the public record. Where in 

camera treatment is granted, a duplicate copy of such document or transcript with the 

confidential material deleted therefrom may be placed on the public record. 

11. If any party receives a discovery request in any investigation or in any other proceeding or 

matter that may require the disclosure of confidential material submitted by another party or third 

party, the recipient of the discovery request shall promptly notify the submitter of receipt of such 

request. Unless a shorter time is mandated by an order of a court, such notification shall be in 

writing and be received by the submitter at least 10 business days before production, and shall 

include a copy of this Protective Order and a cover letter that will apprise the submitter of its 

rights hereunder. Nothing herein shall be construed as requiring the recipient of the discovery 

request or anyone else covered by this Order to challenge or appeal any order requiring 

production of confidential material, to subject itself to any penalties for non-compliance with any 

such order, or to seek any relief from the Administrative Law Judge or the Commission. The 

recipient shall not oppose the submitter’s efforts to challenge the disclosure of confidential 

material. In addition, nothing herein shall limit the applicability of Rule 4.11(e) of the 

Commission’s Rules of Practice, 16 CFR 4.11(e), to discovery requests in another proceeding

that are directed to the Commission. 

12. At the time that any consultant or other person retained to assist counsel in the preparation of 

this action concludes participation in the action, such person shall return to counsel all copies of 

documents or portions thereof designated confidential that are in the possession of such person, 

together with all notes, memoranda or other papers containing confidential information. At the 

conclusion of this proceeding, including the exhaustion of judicial review, the parties shall return 

documents obtained in this action to their submitters, provided, however, that the Commission’s 

obligation to return documents shall be governed by the provisions of Rule 4.12 of the Rules of 

Practice, 16 CFR 4.12. 

13. The provisions of this Protective Order, insofar as they restrict the communication and use 

of confidential discovery material, shall, without written permission of the submitter or further 

order of the Commission, continue to be binding after the conclusion of this proceeding. 

4 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

Exhibit B 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF THE ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

DOCKET NO. 9397 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer ofHEALTH 

RESEARCH LABO RA TORIES, LLC and 

WHOLE BODY SUPPLEMENTS, LLC 

DECLARATION OF KRAMER DUHON 

I, Kramer Duhon. hereby declare: 

1. My name is Kramer Duhon. I am the CEO of Health Research Laboratories, LLC 

and Whole Body Supplements. LLC. I make this declaration based on personal knowledge ofthe 

facts set forth herein. 

2. On or about January 7, 20 I 5, I received a Civil Investigative Demand ("CID") from 

the Federal Trade Commission ("FTC") and immediately hired the law firm of Olshan Frome 

Wolosky LLP to represent the Respondents in connection with CID and all other legal issues 

related to the FTC. From January 7, 2015 until approximately November 13, 2019, the 

lawyers at Olshan represented me and provided legal advice regarding all issues and 

disputes with FTC. The Respondents have had no relationship with Olshan or its attorneys 

other than an attorney-client relationship. I, and the other Respondents, consider all of the 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 2/17/2021 | OSCAR NO. 600685 | PUBLIC PUBLIC

documents, files, and communications within Olshan's possession, custody or control to be 

confidential. 

Pursuant to 28 U.S. C. § 1746, I declare under pen f perjury that the foregoing is true 

and correct based on my personal knowledge.