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ALDEN F. ABBOTT 

General Counsel 

ELIZABETH JONES SANGER (WI I 080449) 

esanger@ftc.gov; (202) 326-2757 

4 JAMES A. PRUNTY (OR 84128) 

jprunty@ftc.gov; (202) 326-2438 

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EDWIN RODRIGUEZ (DC 446457) 

erodriguez@ftc.gov; (202) 326-3147 

SHIRA D. MODELL (DC 358757) 

smodell@ftc.gov; (202) 326-3116 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

1 o Fax: (202) 326-3259 

11 STACY PROCTER (Local Counsel) (CA 221078) 

12 sprocter@ftc.gov 

Federal Trade Commission 

13 10990 Wilshire Blvd., Suite 400 

14 Los Angeles, CA 90024 

Tel: (310) 824-4300 

15 Fax: (310) 824-4380 

16 ATTORNEYS FOR PLAINTIFF 

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UNITED STA TES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

FILED UNDER SEAL ) 

FEDERAL TRADE COMMISSION ) :� Plaintiff, 

'?-Dlfrf&--2104 -JC,8(.

� COMPLAINT FOR 

PERMANENT 

23 

V. 

24 ) INJUNCTION AND 

25 JASON CARDIFF, individually ) OTHER EQUITABLE and as an owner, officer, ) RELIEF 26 

27 

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director, or member of ) 

REDWOOD SCIENTIFIC ) 

TECHNOLOGIES, INC !:l 

eteRK. 

) wooeo 

U.S. OISmtCT COUR'I' 

I 

OCT - 3 2018 

I 

CENTRAL D1Sm1CT OF CALIFORNIA

BY DEPUTY
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California corporation;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, Inc., a 

Nevada corporation;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, Inc., a 

Delaware corporation;

IDENTIFY, LLC, a Wyoming 

limited liability company;

ADVANCED MEN’S 

INSTITUTE PROLONGZ 

LLC, d/b/a AMI, a California 

limited liability company; and

RUN AWAY PRODUCTS, 

LLC, a New York limited 

liability company; and

both general and limited 

partner of

CAROLS PLACE LIMITED 

PARTNERSHIP, an Arizona 

limited liability partnership;

EUNJUNG CARDIFF, a/k/a 

Eunjung Lee, a/k/a Eunjung 

No, individually and as an 

owner, officer, director, or 

member of

REDWOOD SCIENTIFIC 

TECHNOLOGIES, INC., a 

California corporation;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, Inc., a 

Nevada corporation;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, Inc., a 

Delaware corporation;

IDENTIFY, LLC, a Wyoming 

limited liability company;

ADVANCED MEN’S 

INSTITUTE PROLONGZ 

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LLC, d/b/a AMI, a California 

limited liability company; and

RUN AWAY PRODUCTS, 

LLC, a New York limited 

liability company; and

both general and limited 

partner of

CAROLS PLACE LIMITED 

PARTNERSHIP, an Arizona

limited liability partnership;

DANIELLE CADIZ, a/k/a Danielle 

Walker, individually;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, INC., a 

California corporation, also 

d/b/a Rengalife;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, INC., a 

Nevada corporation;

REDWOOD SCIENTIFIC 

TECHNOLOGIES, INC., a 

Delaware corporation;

IDENTIFY, LLC, a Wyoming 

limited liability company;

ADVANCED MEN’S INSTITUTE 

PROLONGZ LLC, d/b/a 

AMI, a California limited 

liability company;

RUN AWAY PRODUCTS, LLC, a 

New York limited liability 

company; and

CAROLS PLACE LIMITED 

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PARTNERSHIP, an Arizona 

limited liability partnership,

Defendants.

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

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

Commission Act (“FTC Act”), 15 U.S.C. § 53(b), Section 5 of the Restore Online 

Shoppers’ Confidence Act (“ROSCA”), 15 U.S.C. § 8404, Section 918(c) of the 

Electronic Fund Transfer Act (“EFTA”), 15 U.S.C. § 1693o(c), and Section 6 of 

the Telemarketing and Consumer Fraud and Abuse Prevention Act (the 

“Telemarketing Act”), 15 U.S.C. § 6105, to obtain temporary, preliminary, and 

permanent injunctive relief, rescission or reformation of contracts, restitution, the 

refund of monies paid, disgorgement of ill-gotten monies, and other equitable relief 

for Defendants’ acts or practices in violation of Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a) and 52, Section 4 of ROSCA, 15 U.S.C. § 8403, Section 

907(a) of EFTA, 15 U.S.C. § 1693e(a), Section 1005.10(b) of EFTA’s

implementing Regulation E, 12 C.F.R. § 1005.10, and Section 310.4(b)(1)(v) of 

the FTC’s Telemarketing Sales Rule (“TSR”), 16 C.F.R. § 310.4(b)(1)(v), in 

connection with their false and unsubstantiated claims for dissolvable film strips 

advertised for smoking cessation, weight loss, and male sexual performance; a 

related autoship continuity program resulting in unauthorized shipments and 

charges; abusive telemarketing through robocalls; and unsubstantiated earnings 

claims for a multi-level marketing scheme.
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JURISDICTION AND VENUE

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

1331, 1337(a), and 1345; 15 U.S.C. §§ 45(a) and 53(b); 15 U.S.C. § 8404(a); and

15 U.S.C. § 1693o(c).

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

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

PLAINTIFF

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

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

Act, 15 U.S.C. § 45(a), which prohibits unfair or deceptive acts or practices in or 

affecting commerce, and Section 12, 15 U.S.C. § 52, which prohibits false 

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

commerce. The FTC also enforces ROSCA, 15 U.S.C. §§ 8401-8405, which 

prohibits the sale of goods or services on the Internet through negative option 

marketing without meeting certain requirements to protect consumers, including 

providing clear and conspicuous disclosure of all material terms of the transaction 

prior to obtaining the consumer’s billing information, and obtaining the 

consumer’s express informed consent before charging the consumer; EFTA, 15 

U.S.C. §§ 1693-1693r, and its implementing Regulation E, 12 C.F.R. Part 1005,

which regulate the rights, liabilities, and responsibilities of participants in 

electronic fund transfer systems; and the TSR, 16 C.F.R. Part 310, which prohibits

deceptive and abusive telemarketing acts or practices. 

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

its own attorneys, to enjoin violations of the FTC Act, ROSCA, EFTA, Regulation 

E, and the TSR, and to secure such equitable relief as may be appropriate in each 

case, including rescission or reformation of contracts, restitution, the refund of 
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monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. §§ 53(b) and 

56(a)(2)(A); 15 U.S.C. § 8404(a); and 15 U.S.C. § 1693o(c).

SUMMARY OF THE CASE

6. Individual Defendants Jason Cardiff, Eunjung Cardiff, and Danielle 

Cadiz have for years operated a fraudulent multi-pronged scheme that has bilked 

consumers out of millions of dollars through baseless advertising claims for

products that purport to alleviate serious health conditions, while also enrolling

consumers in unwanted autoship programs that have resulted in millions of dollars 

in unauthorized charges.

7. Defendants’ evolving business operation injures consumers in 

multiple ways. First, Defendants’ marketing of their dissolvable film strips relies

on false or unsubstantiated claims for TBX-FREE (stop smoking aid), Eupepsia 

Thin (appetite suppressant), and Prolongz (men’s sexual performance), including 

claims that those products were proven to work. Defendants also make false 

claims that their film strips are made in the United States and are sold with moneyback guarantees. Then, Defendants enroll consumers – without prior notice and 

authorization and, in some cases, notwithstanding consumers’ or Defendants’ clear 

statements to the contrary – in autoship continuity plans that bill consumers

monthly for unwanted products. Defendants also make it difficult for consumers to 

cancel those plans and get their money back. More recently, Defendants have 

turned to abusive telemarketing practices by delivering prerecorded marketing 

messages to millions of consumers. Finally, Defendants recently launched a multilevel marketing scheme for which they make false or unsubstantiated earnings 

claims.

8. Individual Defendants have operated the scheme through a web of 

interrelated companies, using Corporate Defendants as their alter egos. Corporate 

Defendants form a common enterprise, and include three corporations with the 
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same name – Redwood Scientific Technologies, Inc., a California Corporation; 

Redwood Scientific Technologies, Inc. a Nevada Corporation; Redwood Scientific 

Technologies, Inc., a Delaware Corporation – and at least 4 other entities, Identify, 

LLC; Advanced Men’s Institute Prolongz LLC; Run Away Products, LLC; and 

Carols Place Limited Partnership.

CORPORATE DEFENDANTS

9. Corporate Defendant Redwood Scientific Technologies, Inc. 

(“Redwood California”), also doing business as Rengalife, is a California 

corporation with its principal place of business at 820 North Mountain Ave., Suite 

100, Upland, CA 91786. It has undergone name changes. Redwood California 

was initially Advanced Men’s Institute Prolongz LLC, which subsequently became 

Redwood Scientific Technologies LLC, and then finally the corporation Redwood 

California. Redwood California transacts or has transacted business in this district 

and throughout the United States. At times material to this Complaint, acting alone 

or in concert with others, Redwood California has advertised, marketed, 

distributed, or sold dissolvable film strips, including TBX-FREE, Eupepsia Thin,

and Prolongz, to consumers throughout the United States.

10. Corporate Defendant Redwood Scientific Technologies, Inc. 

(“Redwood Nevada”) was, until December 2017, a Nevada corporation whose 

registered agent was located at 202 N. Carson Street, Carson City, NV 89701. 

Redwood Nevada was the parent of Redwood California, and it transacted business 

in this district and throughout the United States.

11. Corporate Defendant Redwood Scientific Technologies, Inc. 

(“Redwood Delaware”) is a Delaware corporation with its principal place of 

business at 820 North Mountain Ave., Suite 100, Upland, CA 91786. Redwood 

Delaware was established in December 2017 as part of a merger between 

Greenway Design Group, Inc. and Redwood Nevada, thus becoming the parent of 
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Redwood California. Through its subsidiaries, including Redwood California, 

Redwood Delaware has advertised, marketed, distributed, or sold dissolvable film 

strips, including TBX-FREE, Eupepsia Thin, and Prolongz, to consumers 

throughout the United States. 

12. Corporate Defendant Identify, LLC (“Identify”) is a Wyoming limited 

liability company. Identify has reserved multiple trade names in Wyoming, 

including TBX-FREE, Redwood Scientific Technologies, Advanced Men’s 

Institute, and Runaway Products. At times material to this Complaint, acting alone 

or in concert with others, Identify has advertised, marketed, distributed, or sold 

dissolvable film strips, including TBX-FREE, Eupepsia Thin, and Prolongz, to 

consumers throughout the United States. Currently, Identify is the primary seller 

of TBX-FREE, Eupepsia Thin, and Prolongz, and receives revenue from the sales 

of those products. Identify’s bank accounts receive funds for activities conducted 

by other Corporate Defendants.

13. Corporate Defendant Advanced Men’s Institute Prolongz LLC

(“AMI”) was a California limited liability company formed in 2014 by Individual 

Defendant Eunjung Cardiff. The managing member of AMI is Corporate 

Defendant Run Away Products, LLC. At times material to this Complaint, acting 

alone or in concert with others, AMI has advertised, marketed, distributed, or sold 

Prolongz to consumers throughout the United States.

14. Corporate Defendant Run Away Products, LLC (“Run Away”) is a 

New York limited liability company formed on March 10, 2009 by Individual 

Defendant Eunjung Cardiff. Run Away has at various times placed advertising for 

Prolongz, and been responsible for meeting payroll for Corporate Defendant 

Redwood California’s employees.

15. Corporate Defendant Carols Place Limited Partnership is an Arizona 

asset management limited partnership formed on January 23, 2017. Carols Place
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Limited Partnership holds 69% of the Common Shares of Redwood Delaware for 

the benefit of Individual Defendants Jason and Eunjung Cardiff. The two partners

of Carols Place Limited Partnership are Carols Place Trust and Extension First, 

LLC, a Wyoming company formed on January 13, 2017 and owned by Individual 

Defendants Jason and Eunjung Cardiff. Carols Place Trust is a bridge trust formed 

on January 17, 2017 under Nevada law. Carols Place Trust owns the Cardiffs’ 

home. The only two settlors and trustees of Carols Place Trust are Individual 

Defendants Jason Cardiff and Eunjung Cardiff. Carols Place Limited Partnership 

has received funds from Corporate Defendant Identify.

INDIVIDUAL DEFENDANTS

INDIVIDUAL DEFENDANT JASON CARDIFF

16. Individual Defendant Jason Cardiff is the Founder, President, Chief 

Executive Officer, and a member of the Board of Directors of Corporate Defendant 

Redwood California, and the President, Chief Executive Officer, Secretary, 

Treasurer, and a Director of Corporate Defendant Redwood Delaware. Mr. Cardiff 

owns more than 150 million shares of Corporate Defendant Redwood Delaware 

common stock and controls all 2.5 million shares of Redwood Delaware’s Series A 

Super Voting Preferred Shares, accounting for 96.6 percent of Redwood 

Delaware’s voting securities. He was the President of Corporate Defendant 

Redwood Nevada before its December 2017 dissolution. Mr. Cardiff is also the 

managing member and has held himself out as an owner of Corporate Defendant 

Identify; he has held himself out as the owner of Corporate Defendant AMI; Mr. 

Cardiff is also a member of Corporate Defendant Run Away. Mr. Cardiff is a 

signatory on bank accounts of Corporate Defendants, as well as a trustee for Carols 

Place Trust.

17. Individual Defendant Jason Cardiff participated in the creation and 

dissemination of advertising for TBX-FREE, Eupepsia Thin, and Prolongz. Mr. 
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Cardiff has appeared in videos promoting TBX-FREE and Eupepsia Thin, in which 

he touts the products’ efficacy. Mr. Cardiff also appeared in multiple videos 

promoting Defendant Redwood California’s new multi-level marketing program 

(Rengalife), in which he claimed that Rengalife members are likely to earn 

substantial income. Mr. Cardiff negotiated with a telemarketing company to 

deliver millions of prerecorded messages, commonly known as robocalls, to 

consumers promoting Defendants’ products, and his voice is used by Defendants in 

those calls. In addition, Mr. Cardiff appears to have been routinely copied on 

internal and external company emails, making him generally aware of company 

operations.

18. Individual Defendant Jason Cardiff at all times material to this 

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

controlled, had the authority to control, or participated in the acts and practices of 

Corporate Defendants, including the acts and practices set forth in this Complaint. 

Mr. Cardiff resides in this district and, in connection with the matters alleged 

herein, transacts or has transacted business in this district and throughout the 

United States.

INDIVIDUAL DEFENDANT EUNJUNG CARDIFF

19. Individual Defendant Eunjung Cardiff, a/k/a Eunjung Lee, a/k/a 

Eunjung No, is the Secretary, Director of Marketing, and a member of the Board of 

Directors of Corporate Defendant Redwood California, as well as its registered 

agent. She is the Chief Operating Officer, Chief Marketing Officer, and a Director 

of Corporate Defendant Redwood Delaware, and she owns 550,800 shares of that 

company’s Common Stock. She was the Secretary of Corporate Defendant 

Redwood Nevada before its December 2017 dissolution. Ms. Cardiff organized

Corporate Defendant AMI; is the managing member of Corporate Defendant Run
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Away; and has signed financial documents identifying herself as an owner of 

Corporate Defendant Identify.

20. Individual Defendant Eunjung Cardiff is identified as part of the 

Management Team on the website of Corporate Defendant Redwood California, 

and her profile says that: 

At Redwood Scientific Technologies, Inc., [Ms. Cardiff] serves as the 

Marketing Director, in which she oversees management’s activities. 

Eunjung also supervises the company’s research and development 

activities – the bread and butter of Redwood. As all management 

personnel reports [sic] to Eunjung, she has the best insights into the 

company’s marketing strategy. Eunjung’s focus on ensuring that the 

company “meets” its financial targets, especially “acquisition cost per 

new customer,” guarantee[s] [t]he the company’s success and 

profitability. She also works [closely] with Jason to constitute, layout, 

and execute the company’s success strategy. 

21. Individual Defendant Eunjung Cardiff, who is married to Individual 

Defendant Jason Cardiff, participated in the dissemination of advertising for TBXFREE, Eupepsia Thin, and Prolongz. She was the principal person responsible for 

buying media for the three products. She participated in responding to requests for 

advertising claim substantiation during the television advertising clearance process 

for TBX-FREE. Ms. Cardiff also monitored the call centers receiving calls from 

consumers to purchase TBX-FREE, Eupepsia Thin, and Prolongz. Ms. Cardiff

also assisted Individual Defendant Jason Cardiff in filming some of the Facebook 

Live videos promoting Rengalife. Ms. Cardiff’s voice also is used by Defendants 

in robocalls to consumers, and she paid for robocall expenses. She has applied for 

multiple merchant accounts on behalf of several Corporate Defendants and she is a 

signatory on several of their checking accounts, as well as a trustee for Carols 
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Place Trust.

22. Individual Defendant Eunjung Cardiff, at all times material to this 

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

controlled, had the authority to control, or participated in the acts and practices of 

Corporate Defendants, including the acts and practices set forth in this Complaint. 

Ms. Cardiff resides in this district and, in connection with the matters alleged 

herein, transacts or has transacted business in this district and throughout the 

United States.

INDIVIDUAL DEFENDANT DANIELLE CADIZ

23. Individual Defendant Danielle Cadiz, a/k/a Danielle Walker, has 

served as Corporate Defendant Redwood California’s Director of Operations since 

December 2016 and as its Business Manager since January 2015. Ms. Cadiz’s 

Linkedin.com profile describes her responsibilities at Corporate Defendant 

Redwood California as “leading day to day business operations, office 

management, [Accounts Payable/Accounts Receivable], cash flow, Human 

Resources and strategic planning.” Ms. Cadiz executes virtually all of the 

activities of Corporate Defendants and has actual and implied authority to make 

decisions on behalf of Corporate Defendants.

24. In the course of her official responsibilities, Individual Defendant 

Danielle Cadiz receives information about consumer complaints. She also has 

communicated with the foreign manufacturers of the Defendants’ film strip 

products and appeared in a video promoting the film strip technology, entitled 

“The End of the Pill,” where she was identified as Corporate Defendant Redwood 

California’s “Operations Manager.” Ms. Cadiz, along with Individual Defendant 

Jason Cardiff, negotiated with a telemarketing company to deliver millions of 

robocalls to consumers promoting several of Defendants’ products. Ms. Cadiz 
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signed the contract for services with the telemarketing company and monitored the 

company’s performance under the contract.

25. Individual Defendant Danielle Cadiz, at all times material to this 

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

controlled, had the authority to control, or participated in the acts and practices of 

Corporate Defendants, including the acts and practices set forth in this Complaint. 

Ms. Cadiz resides in this district and, in connection with the matters alleged herein, 

transacts or has transacted business in this district and throughout the United 

States.

COMMON ENTERPRISE

26. Corporate Defendants have operated as a common enterprise while

engaging in the illegal acts and practices alleged in the Complaint. Individual 

Defendants Jason Cardiff, Eunjung Cardiff, and Danielle Cadiz have conducted the 

alleged deceptive practices described herein through the interrelated network of

Corporate Defendants, which share a business purpose, business functions, and 

employees; are commonly controlled by Individual Defendants; and have 

commingled funds. Defendants have been able to delay detection of chargeback 

activity from credit card companies and merchant card banks by using multiple 

company names, bank accounts, and merchant accounts virtually interchangeably 

since 2014. Because Corporate Defendants have operated as a common enterprise, 

each of them is jointly and severally liable for the acts and practices alleged below.
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ALTER EGO

27. There is such a unity of interest between Corporate Defendants and 

Individual Defendants Jason Cardiff and Eunjung Cardiff that they are alter egos. 

Corporate Defendants are all dominated and controlled by Individual Defendants 

Jason Cardiff and Eunjung Cardiff and were used to further the deceptive scheme 

described herein. Individual Defendants Jason and Eunjung Cardiff use personal 

credit cards to pay for expenses of Corporate Defendants and hold their stock in 

Redwood Nevada and Redwood Delaware in the name of Corporate Defendant 

Carols Place Limited Partnership. Corporate Defendant Carols Place Limited 

Partnership is comprised of Carols Place Trust and Extension First, LLC, which 

are both owned by the Cardiffs; Carols Place Trust also owns the Cardiffs’ home.

28. Failure to disregard the Corporate Defendants’ corporate forms would 

sanction a fraud and injustice by shielding and safeguarding them from liability for 

their roles in a deceptive scheme that has caused millions of dollars in consumer 

injury, and would unjustly enrich them by permitting them to keep moneys 

obtained from consumers through fraud.

COMMERCE

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

substantial course of trade in or affecting commerce, as “commerce” is defined in 

Section 4 of the FTC Act, 15 U.S.C. § 44.

DEFENDANTS’ BUSINESS ACTIVITIES

30. Defendants have manufactured, labeled, advertised, marketed, 

promoted, offered for sale, sold, and distributed to consumers dissolvable film strip 

products, including strips sold under the brand names TBX-FREE, Eupepsia Thin, 

and Prolongz. 
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31. TBX-FREE, Eupepsia Thin, and Prolongz are manufactured in China 

or India.

32. Defendants market TBX-FREE, Eupepsia Thin, and Prolongz as overthe-counter homeopathic drugs that consumers place on their tongues and then 

press against the roofs of their mouths.

33. According to its package label, the active ingredient in TBX-FREE is 

“Laburnum anagyroides 1X” and its purpose is the “Homeopathic treatment of 

chronic nicotinism.”

34. According to its package label, the active ingredient in Eupepsia Thin 

is “Paullinia Cupana H.B.K. 1X” and its purpose is as a “Homeopathic appetite 

suppressant.” 

35. According to its package label, the active ingredients in Prolongz are 

“Damiana Extract 1X (10 mg) ... and Ginseng Extract 1X (10 mg)” and its 

purpose is as a “Homeopathic Sexual Enhancement Strip.”

36. Defendants have sold Prolongz since at least 2014, TBX-FREE since 

at least 2015, and Eupepsia Thin since at least 2017. Defendants have sold

Prolongz, TBX-FREE, and Eupepsia Thin on multiple websites. Defendants have 

charged $49.95 for a box of TBX-FREE containing 120 film strips, and $49.95 for 

a box of Eupepsia Thin containing 60 film strips. Defendants have offered a box 

of Prolongz containing 60 film strips for a 15-day free-trial upon the payment of 

$4.98 in shipping and handling, and have charged $89.95 upon the expiration of 

the trial period.

TBX-FREE ADVERTISING

37. Defendants have advertised TBX-FREE through a national television 

infomercial campaign and on the Internet, including websites and Facebook Live 

videos. The core messages of this advertising have been that TBX-FREE enables 

users to quit smoking, that it is clinically proven to do so, and that it is superior to 
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other smoking cessation aids. These materials contain the following statements

and depictions, among others:

A. Excerpts from tbxfree.com website (captured 03/16/2017):

Revolutionary New Stop Smoking Product

More effective than the Patch and Gum

#1 Choice by Smokers

***

 88% Success Rate 

***

In clinical studies cited in The New England Journal of 

Medicine, the active ingredient in TBX-FREETM has an 88% 

cure care [sic] compared to the patch and gum combined.

***

***

PROVEN IN RESEARCH STUDIES TO HELP 

SMOKERS QUIT THEIR ADDICTION!

***

The Breakthrough

Stop Smoking Aid

That Calms Cigarette Cravings!

Proven in research studies to

help smokers quit their addiction!

B. TBX-FREE Facebook Live post (posted 02/24/2017): 

CLINICALLY PROVEN IN: 

l'i..-L).. 11oc ,Ew E GLAND 

~ JOURNAL o MEDICI E 

~

1 Harvard Health Publications V HARVARO t.1et11CA1. SCkOOI. 

Tf'111 Ir.I 11Jt•I, Jor ,u &10lurr II/~ 
17

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PRESENTER [DEFENDANT JASON CARDIFF]: . . . So I’m 

going to show you what we’ve done . We’ve developed the 

most successful stop-smoking product on the market, period, 

plain and simple. I challenge anybody that tells me they have a 

more successful stop-smoking product. It doesn’t exist.

***

 If you’ve tried to stop smoking, if you want to stop 

smoking, if you want to quit, if you want to make that change, 

this is the product for you. And what you get and how it works 

and the magic is it has no nicotine in it, first off. But it does 

have an active ingredient in it.

***

 And how this works is what’s really important. . . . 

[T]his little strip here, you put it on your tongue, and it releases 

a chemical to the brain, which is naturally found in nature, and 

it makes you feel like you’ve had a cigarette.

 Now, that’s the most important part. We’ve replaced the 

feeling of smoking with a non-nicotine-based product. And in 

five short days -- five days -- you get all the nicotine out of 

your system. You now have the nicotine out of your system 

and you have the chance to become and live a smoke-free life. 

And that is how the product works. That is why it has an 88 

percent success rate, and we can look here, we have an -- we 

have a proven track record of over an 88 percent success rate

from some of the greatest medical institutions and universities 

in the United States and the U.K. And that’s why it works so 

well -- no nicotine in your system.
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***

 What does one month supply, an entire month, of TBXFree -- it comes with two of these packets, two of them, okay? 

A whole month supply, it’s 120 strips, which if you follow the 

direction should be more than you ever need. 

I don’t really understand. You know you’ve tried to stop. 

You’ve tried to stop five, six, seven, ten times. This product 

will do it for you. You can quit smoking with TBX-Free. 

Here’s the best part, right? We offer a lifetime, money-back 

guarantee. . . . Lifetime, money-back guarantee for any reason, 

okay? If the product doesn’t work for you or you become a 

smoker again, not only will we either give you your money 

back or we’ll send you another box, whatever you want. We 

want the highest quality customer experience possible. You 

know the patches and gums won’t give you any guarantee 

because they know they don’t work. . . . So lifetime, moneyback guarantee. You have nothing to lose, everything to gain, 

the number, right here. . . . You get a one-month supply for 

[$]49.95, and you don’t pay shipping. Just think about it. Just 

what have you got to lose? It’s what you spend on cigarettes in 

a week. Can you imagine? You’re -- all of a sudden you’re 

smoke-free? 

C. Excerpts from TBX-FREE infomercial (captured 03/27/ 2018):

SPOKESMAN: This amazing strip delivers the same 

calming effect but with no tar, no tobacco, no nicotine, no 

ashes, no odor, huh, and my favorite, Taylor, no secondhand 

smoke.
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***

SPOKESWOMAN: To be able to break the chain of 

addiction with smokers, we have developed a product that gives 

you the freedom to not be addicted to any type of nicotine 

product. TBX-FREE is unique among stop-smoking products 

because of the delivery technology and it contains no nicotine. 

This nicotine-free system allows you to successfully stop 

smoking and at the same time you do not become addicted to 

TBX-FREE – like you might with the nicotine gum or patch.

NARRATOR: Have you ever wanted to quit smoking 

but didn’t think you could? Now, you can. Imagine living a 

smoke-free, nicotine-free life. Because of TBX-FREE, 

thousands of people are breaking the addiction of cigarettes. 

People around the world have discovered this amazing 

breakthrough and, now, through this TV offer -- Redwood 

Scientific Technologies is giving you an opportunity of a 

lifetime. TBX-FREE is a fast-acting, dissolvable strip that is 

setting cigarette smokers -- free for life. With TBX-FREE, you 

control the habit, the habit doesn’t control you.

***

SPOKESWOMAN: TBX-FREE is a fast strip delivery 

technology. You just place it on your tongue and it dissolves 

instantly and your nicotine craving disappears. And the 

moment it hits your system, you have the same satisfaction as if 

you had just finished a cigarette. 

***
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***

UNIDENTIFIED FEMALE: I smoked about a pack a 

day for ten years. I tried the patch first and I would still smoke. 

You know, I was wearing the patch, I would still smoke 

cigarettes. When I was chewing the gum, I would still smoke 

cigarettes. And then I tried the e-cig -- e-cigarettes and even 

those, still nicotine, you know, I kind of said, you know, I need 

to try something that’s, you know, not nicotine. And I was 

really surprised how TBX works.

UNIDENTIFIED FEMALE: TBX-FREE is the only 

thing that works. I’ve tried the gum, the patch, nothing works. 

And, plus, no side effects. What could be better? 

D. TBX-FREE Facebook Live post (posted 01/09/2017):

PRESENTER [DEFENDANT JASON CARDIFF]: We 

have an 88% effective rate in long-term cure in long-term 

CALL 

NOW! TBX 

' • I ,,,{..,_ ,., .. - I . • I / - ------- I 
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smokers. A long-term smoker is someone who’s been smoking 

more than 5 years, more than a pack or around a pack a day on 

average. 

Our clinical data on TBX-FREE have done [sic] by some 

of the greatest medical and scientific institutions anywhere that 

we know of, including, not limited to the New England Journal 

of Medicine, which ranks our product ten times more effective 

than nicotine-replacement therapy to stop smoking. That’s 

who’s giving us this data.

E. TBX-FREE Facebook Live post (posted 02/07/2017):

PRESENTER [DEFENDANT JASON CARDIFF]: I 

want to share with you what is TBX-Free, how does it work, 

what is the secret to learn how to stop smoking cigarettes fast. I 

mean really fast, within a week, within ten days.

We have long-term smokers that have learned this secret, 

that have been smoking for 30-plus years, two packs a day or 

more, and they no longer smoke cigarettes. If you’ve tried the 

patch and the gum, maybe you’ve tried hypnosis, maybe you’ve 

tried Chantix, and you’re a long-term smoker, I need your 

attention, just a little bit of your attention.

***

Now, you should never need more than one month. After 

five days of use, all the nicotine will be cleansed out of your 

system... And people say, well, does it work? Well, we have an 

88 percent success rate. We have a lifetime money-back 

guarantee.

***
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But first you have to stop smoking. You have to stop 

smoking, and you’re addicted to something we believe 

internally as a group and a company, cigarettes are the most --

one of the most harmful killers of America -- of Americans. 

And -- and, you know, we’re an American-based company. We 

have an American-based product. We’re here, located in 

Southern California. We have an all-U.S.-based team here at 

our laboratories, and we’re here for you.

38. Jason Cardiff is the “Presenter” appearing in the TBX-FREE 

Facebook Live posts quoted above.

EUPEPSIA THIN ADVERTISING

39. Defendants have advertised Eupepsia Thin through a national 

television infomercial campaign and on the Internet, including websites and 

Facebook Live videos. The core message of this advertising has been that 

Eupepsia Thin causes or enables substantial weight loss without users having to 

diet, increase their exercise, or make other lifestyle changes. These materials 

contain the following statements and depictions, among others:

A. Excerpts from bethinrx.com website (captured 02/05/2018):
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LIVE THE

EUPEPSIA

LIFESTYLE!

→ NO DIETS

→ NO GIVING UP FOOD

→ NATURAL AND EFFECTIVE

***

FDA Registered.

Natural, homeopathic and wholesome.

Proven active ingredient is an effective appetite suppressant.

***

***

• Eupepsia Thin TM contains a clinically proven super ingredient 

called Paullinia cupana H.B.K.

• Eupepsia ThinTM’s incredible active ingredient sends the brain 

the sensation of fullness.

• Once Eupepsia ThinTM mouth strip dissolve [sic] on your 

tongue, the active ingredient hits your blood stream sending the 

feeling of fullness which lasts for hours which in turn controls 

caloric intake.

***

Studies show the new product, Eupepsia Thin, gives people a 

chance to live a more active lifestyle and keep weight off.

***

IA 

w 
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Safe & Effective Weight-Loss

Current calorie reduction and meal plans have less than 5% 

success rate while the new product, Eupepsia ThinTM, has 

a substantially higher success rate. Until now there was 

no better way to shed the weight other than going 

through a huge lifestyle change.

***

Lose up to 15 pounds

your first month with Eupepsia Thin oral strips without diets 

or changing your food or lifestyle choices.

***

What is the price of Eupepsia ThinTM?

If you would like to lose 8-20 lbs – our one month supply at 

69.95 will work for you.

If you would like to lose 20-50 lbs – our three month supply at 

169.95 will work for you.

If you would like to lose 50-70 lbs – our six month supply at 

239.95 will work for you.

If you would like to lose 70-100 lbs – our one year supply at 

456.95 will work for you.

***

Is Eupepsia ThinTM 100% natural?

Unlike most diets and supplements on the market, 

Eupepsia ThinTM is all natural and FDA registered, 

without fillers or dangerous ingredients, eliminating side 

effects or withdrawals.

B. Excerpts from Eupepsia Thin infomercial (captured 

07/24/2017):

ON SCREEN: ARE YOU READY TO LOSE

 BEFORE and AFTER PHOTOS

 10 lbs

 20 lbs
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 100 lbs

 WITHOUT GIVING UP YOUR FAVORITE FOODS!

NARRATOR: Are you ready to lose 10, 20, even 100 pounds 

without giving up your favorite foods or adding any exercise? 

***

NARRATOR: The ingredients in Eupepsia will begin to 

activate in your system in less than 20 seconds. In minutes, 

you’ll feel your appetite suppress, giving you control over how 

much you eat. 

***

NARRATOR: This is exactly what you’ve been waiting for to

help you shed those unwanted pounds.

 ON SCREEN: Before photo

 Danny Lost 45 lbs!

 From 230 lbs to 185 lbs!

DANNY: Forty-five pounds. I went from 230 back to 185.

ON SCREEN: Before photo

Tricia Lost 20 lbs!

From 135 lbs to 115 lbs!

TRICIA: My current weight today is 115 pounds and I feel 

absolutely amazing. I am able to, you know, just eat whatever I 

want and still drink wine as well. 

***

ON SCREEN: YOU HAVE NOTHING TO LOSE.

But The Weight!

NARRATOR: With Eupepsia, you have nothing to lose but the 

weight. 
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SPOKESWOMAN 2: . . . This one-of-a-kind product will help 

you lose weight without stepping one foot in the gym or giving 

up any of your favorite foods. 

ON SCREEN: NO COUNTING CALORIES OR TRACKING 

FOOD! 

SPOKESWOMAN 2: No counting calories or tracking food 

and no expensive gym memberships to pay. 

***

SPOKESMAN 1: We are so confident that Eupepsia will work 

for you, it comes with a lifetime guarantee.

***

ON SCREEN: Before photo 240 lbs

 Karen Lost 90 lbs!

 Now 150 lbs!

KAREN: I’m half the size I used to be. I can get in half of 

these jeans. That’s quite an accomplishment.

***
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 ON SCREEN: Before photo

 Todd Lost 132 lbs!

 From 360 lbs to 228 lbs!

 TODD: I tell you what, ever since I got the Eupepsia 

product, I have been amazed. I lost -- actually, I weighed 360 

pounds. I lost 132 pounds on it. Very easy to do. And, now, 

I’m at 228 pounds. 

 And I tell you what, I’ve never felt better. I feel so good. 

My body is extremely different now. I don’t fight to breathe. 

My kidney level is back to normal. I have no diabetes 

whatsoever. I used to take five insulin shots a day. I no longer 

have to take nothing for diabetes. My kidneys are at a good 

function and I just -- I tell you what, Eupepsia has been 

awesome.

C. Eupepsia Thin package labeling:

• Oral Strip

EASY WEIGHT LOSS

_____________________

Safe & Effective

Still eat your favorite foods

No change in exercise required

• Made in USA

• Clinically proven to help suppress appetite between 

meals.

40. At least some of the people who provided testimonials in the Eupepsia 

Thin infomercial were actors who had been paid to appear in the infomercial and 
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who had not used Eupepsia Thin to lose the weight they discussed in their 

testimonials. 

PROLONGZ ADVERTISING 

41. Defendants have advertised Prolongz through a national television 

infomercial campaign and on the Internet. The core message of this advertising 

has been that Prolongz boosts men’s sexual performance, including by lengthening 

the duration of sex and preventing premature ejaculation. These materials contain 

the following statements and depictions, among others:

A. Excerpts from 2014 Prolongz infomercial: 

ON SCREEN: 

NARRATOR: Through this special offer, Advanced Men’s 

Institute is giving men the opportunity of a lifetime. 

.j• \i I 

~--

~ 'Iii , .la''~!E!..?.~ 

~ :5www.AIVl1 · - - · .com 
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ON SCREEN: [blinking lights and font]

 

 

 

 

 

 

NARRATOR: Do you want longer lasting sex? Do you want 

more time being intimate with your partner?

NARRATOR: Do you want to satisfy your partner like never 

before? Now it’s possible.

ON SCREEN:

NARRATOR: Thanks to a new first of a kind sexual performance 

product called Prolongz.
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B. Excerpts from 2015 prolongz.com website (captured May 16, 

2018): 

 30 DAY MONEY BACK GUARANTEE!

Prolongz is guaranteed to increase your ejaculatory control levels and 

overall sexual performance. ... 

***

LEVEL THE PLAYING FIELD 

WITH PROLONGZ 

1' 

~ 20 

,. 

1540 MirrJtC ;iver.a1?e 

; lS+-------1----af-+--

~ 

~ 10 

a!1tflma1y cffactlva: 

ALL NATURAL - ACTIVE INGREDIENTS 

STRIP DELIVERY TECH HD LOGY 

PROLONGZ USES ORAL STRIP OE LIVERY TECHNOLOGY 

TO COMBINE A HIGH DOSAGE BLAST OF GINSENG 

EXTRACT & DAMIANA EXTRACT - WH ICH CHANGES 

PROTEINS IN THE BRAIN THAT INCREASE CONTROL OVER 

MALE EJACULATION. 

HO.. 

HO" .0 1:H O,D 

HO , 0 

0 0 

1101/0" 

:~Ott -rOH OH 

an£:.tt,<t1cs which don't treat the problem; 1i-ev only treat the symptom. Prolorg:;: :; a FDA 

tcJ••tctC'CI Over-Thc-Ccurrl" lkmcoop•tl,ic Drug. th., ,tr,p, d,,,01~., ;,-. 20 S..ccncl,. ccmbinins 

NO l'ltESCltlPrtON NEEDED 

LONGH lASTING SEX 

lNCaEAJfD EJACUU rtON CONTROL. TIME 

0 TII rv Erlri,cl 1X 10 m11) 

Cid here to yjew 1he comptele Drug Facts Par,cl 

Prolongz'"" iS a mA regist~red OTC hOmeop.ithic drug. which helps in the 

prevention of Premature E;aculat1on {PE). lt 1s a first of it s kind produa which 

uses oral 1subll ngualJ d1ssotvable stnp delNcry technology for the treatment of 

PE. 

The proprietary blend of ingredients in Prolongz. reacts wit he chemica ls in the brain that 

control he major parts of sexua l excitement. Current products on the market are topical 

anesthetics which don' treat the problem; hey only trea he symptom. Prolongz is a FDA 

registered Over-The-Counter Homeopathic Drug, the strips dissolve in 20 Seconds; combining 

a high % dosage blast of Damiana & Ginseng , 

Click. here to view the complete Drug Facts PaneL 

Pro longzTu is a FDA registered OTC homeopathic drug, which helps in the 

prevention of Premature Ejaculation (PE), It is a first of its kind product which 

uses Oral (sublingual) dissolvable Strip delivery technology for the treatment of 

PE. 
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C. Excerpts from 2016 prolongz.com website (captured May 16, 

2018): 

PROLONGZ~ 

SUBLINGUAL DELIVERY 

INCREASED EJACULATION CONTROL , . 

MEDICALLY RECOMMENDED 

FAST-ACTING Ii EASV-fO-USE 

L•NGER LASTING SEX! 

CALL TO TRY: 

844-241-/IBJ 

AUSTRALIA'S BEST KEPT SECRETI ~ 

NOW AVAILABLE INTHE UNITED STATES! ~ 

TELL US WHERE TO SEN• 

'IOURmllRESS YOIIICITY 

V ZIPCOIIE 

E~ll .\DORESS 

SEND MY SUPPLY 

f'rolo~.z.r~ rs a FDA IeqI:1er1?d OIC J10-ne,opalt11c mug. 

Whii;h hltllμS ill lhl} pll}Vl!l'llion uf Pf1~111..1l11fl':I l:[.ll:utltill•ll 

(f'E:J. ll IS a ltrst ol rlS l;m(l product WfHCh II'Sl?S Ora l 

(stlll,,lnguBI) d1sSJJl'r.Wle Strp Iier.'l!f)' t&f'ln(rogy for tile 

h6iWilenl of PE. 

All NATURAL INGREDIENTS -- -

Conldins a 1<ery potent ndtural combln.ition ol l'roven to effectively inawe th~ length in Sex for 

over 97% oflhausands of Men who hillle llled 

Prolor,gf'. 

Longer lasting ,ex Is ddlievoble. Pru I ongl'" wlli 

make \'OU firml'I and last !onge;. 

Proven to effectively increase the length in Sex for 

over 97% oflhous.ands of Men who have tried 

ProlongzTM. 

Longer lasting sex is a chi evahl e. Pro! ongzTM will 

make you firmer and last longer. 
32

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DEFENDANTS’ DECEPTIVE SALES AND BILLING PRACTICES IN 

CONNECTION WITH TBX-FREE, EUPEPSIA THIN, AND PROLONGZ

42. Defendants’ advertising, including websites, infomercials, and social 

media, lists both website links and toll-free numbers that consumers can use to 

place orders for TBX-FREE, Eupepsia Thin, and Prolongz (“the Products”). 

Consumers then purchase the Products through inbound sales calls and website 

orders.

Defendants’ Failure to Disclose Autoship Programs

at the Time of the Initial Sale

43. When consumers order the Products and provide their payment 

information, Defendants have routinely enrolled them in a continuing autoship

program, which is commonly known as a continuity plan, without disclosing, or 

disclosing adequately, to those consumers either the enrollment, or the terms and 

conditions of the autoship program. Defendants’ autoship program then makes 

additional shipments to consumers at regular intervals and Defendants charge the 

credit or debit cards that consumers provided for their initial purchase for the 

subsequent shipments. Thus, if a consumer placed an order for a supply of any of 

the Products, the Defendants have often repeatedly, and on a continuing basis,

charged the consumer for additional product without further authorization. In 

numerous instances, Defendants have not disclosed, or have not disclosed

adequately, these material terms to consumers before consumers provide their 

credit or debit card information, and therefore have not obtained consumers’ 

express informed consent to the autoship program and the additional charges. 

44. In the case of website orders for TBX-FREE, Defendants’ websites

have not disclosed, or have not disclosed adequately, the negative option feature of 

their autoship program, whereby they interpret consumers’ silence or failure to 

contact them as consumers’ tacit acceptance of enrollment and of the receipt of 
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additional shipments and charges. In numerous instances, when consumers have 

proceeded to the shopping cart, provided their billing information, and completed 

the purchase, there has been no adequate disclosure about Defendants’ autoship

program or that any additional charges would be placed on a consumer’s credit or 

debit card. 

45. For telephone orders for the Products, in numerous instances, 

Defendants’ call center representatives similarly have not disclosed that 

Defendants will enroll consumers automatically into a continuing autoship

program that will result in additional shipments and charges to consumers’ credit 

or debit cards. In many cases, consumers have specifically asked not to be 

enrolled in an autoship program but Defendants did so anyway. In many cases, 

Defendants’ call center employees assured consumers they will not be enrolled in 

an autoship program but Defendants did so anyway.

46. At the time of the initial sale, Defendants do not disclose, or do not 

adequately disclose, their terms and conditions for cancellation and refunds for 

autoshipments before obtaining consumers’ billing information. Instead, 

consumers are later advised by Defendants’ customer service representatives that 

they must request cancellation, obtain a return merchandise authorization (“RMA”) 

number, and mail products back to Defendants at their own expense.

47. In cases in which consumers pay for their initial purchase using debit 

cards, Defendants have debited consumers’ bank accounts for the additional 

periodic shipments. Defendants did not obtain written authorization signed or 

similarly authenticated from consumers authorizing the recurring electronic fund 

transfers from their accounts, and did not subsequently provide consumers with a 

copy of such a written authorization.
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Consumers’ Post-Sale Experiences – Unauthorized Charges

48. Defendants ship their Products to consumers on a periodic basis and 

charge their credit or debit cards without consumers’ consent for any charge other 

than the initial purchase.

49. Consumers must contact Defendants to reject additional shipments 

and charges and to cancel their undisclosed and unauthorized enrollment in the 

autoship program.

50. Defendants’ mechanisms for stopping recurring shipments and 

charges are often not effective. Consumers are often not able to reach Defendants 

when they call to stop recurring shipments and charges. On many occasions when 

consumers do cancel their enrollment in the autoship program, Defendants 

continue sending additional shipments and placing additional charges on 

consumers’ credit and debit cards.

51. Defendants do not honor their money-back guarantees. Consumers 

who seek a refund are often told that the charges are not refundable. 

DEFENDANTS’ ILLEGAL TELEMARKETING CAMPAIGN

52. In February 2018, Defendants caused prerecorded messages, 

commonly known as robocalls, to be delivered to consumers. Defendants planned 

robocall campaigns for multiple products.

53. Defendants’ initial contract with the telemarketing company provided 

for “ringless voicemails” to be delivered to 1,500,000 consumers.

54. Defendants disseminated robocalls to targeted groups of consumers, 

such as men over the age of 40 in the state of California, and delivered prerecorded 

messages, some of which featured the voice of Individual Defendant Jason Cardiff. 

55. Defendants also conducted a robocall campaign for TBX-FREE using 

messages featuring the voice of Individual Defendant Eunjung Cardiff.
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56. Hundreds of consumers have complained about receiving unsolicited 

prerecorded messages for Defendants’ products.

DECEPTIVE RENGALIFE EARNINGS CLAIMS

57. In March 2018, Defendants launched Rengalife, a multi-level

marketing program. 

58. Rengalife members advance up the line from Executive to Director, 

and then to Vice President and Senior Vice President, based on the number of 

recruits in their downline networks, all of whom are making monthly purchases of 

at least $199.80 of Redwood Scientific dissolvable film strips via autoship. 

Members earn “commissions” on the monthly purchases of Redwood products 

made by recruits who are one, two, and three levels below them in their network, 

including a 30 percent “commission” on purchases by those team members one 

level down whom they recruited directly.

59. Defendants promoted Rengalife through a variety of media, including, 

but not limited to, online videos featuring Defendant Jason Cardiff. Defendants’ 

advertising made strong earnings claims for the Rengalife program, including the 

following statements, among others:

A. Rengalife.com/network-marketing:

“Finally your dreams can become real!

It all begins by signing up as a Rengalife member.

By becoming part of the Rengalife family, you will be on the 

path to creating your ideal life. Whether you are looking for a 

few extra dollars or pursuing an opportunity to replace a full 

time income, Rengalife has the way.”

B. “Get Started Today” Facebook Live video (posted 4/4/2018):

PRESENTER [JASON CARDIFF]: So you pick a package, 

and if I told you that you could make $2,000 a month, $5,000 a 
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month, $100,000 a month, we have somebody on pace to make 

. . . $100,000 a year. We’ve only been live a week and a half. 

If I told you you had to make a little tiny investment in product 

for yourself to get to the executive level, if I showed you how 

to spend $199.80 and you could make [$]5,000 a month, $6,000 

a month, is that a good investment? And you would say, yes, it 

is, it’s a very good investment.

60. Defendants represented that Directors are guaranteed a “Minimum 

monthly Paid commission [of] $600,” Vice Presidents $2,600 per month, and 

Senior Vice Presidents $12,600 per month. 

61. Individual Defendant Jason Cardiff put these guarantees in terms of 

annual earnings:

Rengalife “New Levels” Vimeo video (captured May 25, 2018):

PRESENTER [JASON CARDIFF]: . . . That takes you from 

executive to director. That also locks in your annual salary at a 

minimum -- a very minimum of $7,200 a year once you go 

from that level of executive to director.

***

And at a vice president level, not only do you start to enjoy 

some of the super first class bucket list travel, but you also lock 

in your annual income at a minimum of over $30,000.

***

The next level is a senior vice president level. . . . This means

. . . you’ve locked in your income at $144,000 a year. You’re 

also receiving the three weeks of first class travel.
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62. Rengalife also promises one-time bonuses as members advance 

through the ranks. New Directors receive a $500 bonus, new Vice Presidents 

$1,200, and new Senior Vice Presidents $10,000. 

63. A Rengalife member must have ten people in his or her network to 

become a Director, 110 to become a Vice President, and 1,100 to become a Senior 

Vice President.

64. Defendants did not have actual earnings data for Rengalife members 

at the time they made their earnings claims, nor did they have any basis for 

earnings claims based on the sale of Redwood film strips, because those products 

have never been sold without deceptive and unfair practices.

65. The Rengalife program is structured such that, if members follow 

Defendants’ instructions for advancing through the program by recruiting new 

members, the vast majority of participants will lose money, not earn substantial 

income.

VIOLATIONS OF THE FTC ACT

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

deceptive acts or practices in or affecting commerce.” 

67. Misrepresentations or deceptive omissions of material fact constitute 

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

68. Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the 

dissemination of any false advertisement in or affecting commerce for the purpose 

of inducing, or which is likely to induce, the purchase of food, drugs, devices, 

services, or cosmetics. For the purposes of Section 12 of the FTC Act, 15 U.S.C. § 

52, TBX-FREE, Eupepsia Thin, and Prolongz are “drugs” as defined in Section 

15(b) of the FTC Act, 15 U.S.C. § 55(b). 
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UNSUBSTANTIATED EFFICACY CLAIMS AND FALSE CLAIMS 

THAT TBX-FREE, EUPEPSIA THIN, AND PROLONGZ ARE 

CLINICALLY PROVEN TO BE EFFECTIVE

COUNT I

FALSE OR UNSUBSTANTIATED EFFICACY CLAIMS FOR TBX-FREE

69. Through the means described in Paragraph 37, Defendants have 

represented, directly or indirectly, expressly or by implication, that:

A. TBX-FREE is an effective smoking cessation product;

B. TBX-FREE is more effective than either nicotine patches or 

nicotine gum in enabling cigarette smokers to stop smoking;

C. TBX-FREE enables many cigarette smokers to quit in seven to 

ten days;

D. TBX-FREE has an 88 percent success rate, including among 

people who have smoked cigarettes for more than five years;

and

E. Smokers should not need to purchase more than one month of 

TBX-FREE.

70. The representations set forth in Paragraph 69 are false or misleading 

or were not substantiated at the time the representations were made. 

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

69 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT II

FALSE PROOF CLAIMS FOR TBX-FREE

72. Through the means described in Paragraph 37, Defendants have 

represented, directly or indirectly, expressly or by implication, that:

A. Clinical studies have been conducted on TBX-FREE, and have 

shown that TBX-FREE is an effective smoking cessation 

product;

B. TBX-FREE has been proven in clinical studies to be more 

effective than nicotine patches or nicotine gum in enabling 

smokers to stop smoking;

C. Clinical studies of TBX-FREE conducted on 10,600 people 

have shown that TBX-FREE has an “88% success rate”;

D. The New England Journal of Medicine (“NEJM”), Harvard 

Health Publications, and Johns Hopkins University have 

published clinical studies proving that TBX-FREE is an 

effective smoking cessation product; and

E. NEJM’s clinical studies showed that TBX-FREE is ten times 

more effective for smoking cessation than nicotine replacement 

therapy.

73. The representations set forth in Paragraph 72 are false. 

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

72 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT III

FALSE OR UNSUBSTANTIATED EFFICACY CLAIMS 

FOR EUPEPSIA THIN

75. Through the means described in Paragraph 39, Defendants have 

represented, directly or indirectly, expressly or by implication, that:

A. Eupepsia Thin is an effective appetite suppressant and weight 

loss aid;

B. Eupepsia Thin starts working in less than 20 seconds, and 

suppresses a user’s appetite within minutes;

C. Eupepsia Thin enables users to lose 10, 20, or even 100 pounds 

without dieting, giving up their favorite foods, or increasing 

their exercise;

D. Eupepsia Thin users can lose 15 pounds their first month 

without dieting or changing their food or lifestyle;

E. Eupepsia Thin users can lose as much as 20 pounds in one 

month and as much as 50 pounds in three months;

F. Eupepsia Thin is more effective at causing weight loss than 

conventional calorie reduction and meal plans; and

G. Eupepsia Thin enables consumers to avoid gaining back weight 

they lose, without any lifestyle changes.

76. The representations set forth in Paragraph 75 are false or misleading 

or were not substantiated at the time the representations were made.

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

75 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT IV

FALSE PROOF CLAIMS FOR EUPEPSIA THIN

78. Through the means described in Paragraph 39, Defendants have 

represented, directly or indirectly, expressly or by implication, that clinical studies 

have been conducted on Eupepsia Thin and those studies show that it is an 

effective appetite suppressant and weight loss aid.

79. The representations set forth in Paragraph 78 are false. 

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

78 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

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

COUNT V

FALSE OR UNSUBSTANTIATED EFFICACY 

CLAIMS FOR PROLONGZ

81. Through the means described in Paragraph 41, Defendants have 

represented, directly or indirectly, expressly or by implication, that:

A. Prolongz substantially increases ejaculation control and the 

duration of sex; and

B. Prolongz treats or prevents premature ejaculation. 

82. The representations set forth in Paragraph 81 are false or misleading 

or were not substantiated at the time the representations were made.

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

81 of this Complaint constitutes a deceptive act or practice and the making of false

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT VI

FALSE PROOF CLAIMS FOR PROLONGZ

84. Through the means described in Paragraph 41, Defendants have 

represented, directly or indirectly, expressly or by implication, that Prolongz is 

clinically proven to increase ejaculation control and the duration of sex for more 

than 97% of users.

85. The representations set forth in Paragraph 84 are false. 

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

84 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

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

ADDITIONAL VIOLATIONS OF THE FTC ACT

COUNT VII

FALSE CLAIMS THAT EUPEPSIA THIN 

IS MADE IN THE UNITED STATES 

87. Through the means described in Paragraph 39, Defendants have 

represented, directly or indirectly, expressly or by implication, that Eupepsia Thin 

is made in the United States.

88. The representation set forth in Paragraph 87 is false. 

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

87 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT VIII

FALSE CLAIMS THAT TBX-FREE, EUPEPSIA THIN, AND PROLONGZ

ARE SOLD WITH MONEY-BACK GUARANTEES

90. Through the means described in Paragraphs 37, 39, and 41,

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

that consumers who are not satisfied with the Products will get their money back. 

91. The representations set forth in Paragraph 90 are false. Many 

consumers who request their money back from Defendants are denied refunds. 

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

90 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

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

COUNT IX

DECEPTIVE TESTIMONIALS

93. Through the means described in Paragraph 39, Defendants have 

represented, directly or indirectly, expressly or by implication, that the product 

users depicted in the Eupepsia Thin infomercial were actual persons who had 

successfully used Eupepsia Thin to lose substantial amounts of weight. 

94. In truth and in fact, at least some of the testimonialists who appeared 

in the infomercial were actors who had been recruited and paid for brief on-screen 

appearances, and had not used Eupepsia Thin to lose the weight they discussed in 

the advertising.

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

93 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

the FTC Act, 15 U.S.C. §§ 45(a) and 52.
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COUNT X

FAILURE TO DISCLOSE ADEQUATELY AUTOMATIC ENROLLMENTS 

IN CONTINUITY PLANS

96. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of the Products, Defendants have represented, 

directly or indirectly, expressly or by implication, that consumers who provide 

their billing information are placing a product order.

97. In numerous instances in which Defendants made the representation 

set forth in Paragraph 96, Defendants failed to disclose, or disclose adequately, that 

consumers who provided their billing information for a product order would be 

enrolled automatically in a continuity plan for future autoshipments of the Products 

that would be charged to their credit or debit cards. This additional information 

would be material to consumers in their decision to purchase Defendants’ products.

98. Defendants’ failure to disclose, or disclose adequately, the material 

information described in Paragraph 97, in light of the representation set forth in 

Paragraph 96, constitutes a deceptive act or practice in or affecting commerce in 

violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

COUNT XI

MISREPRESENTATIONS – CONTINUING AUTOSHIP PROGRAM

99. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of the Products, Defendants have represented, 

directly or indirectly, expressly or by implication, that consumers will not be 

enrolled in an autoship program and that their credit or debit card will be charged 

only for a one-time purchase of the Products.

100. The representations set forth in Paragraph 99 are false. In numerous 

instances where Defendants have told consumers they will not be enrolled in an 

autoship program, Defendants have enrolled consumers in an autoship program, 
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charging consumers’ credit or debit cards for additional shipments they did not 

agree to purchase.

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

99 of this Complaint constitutes a deceptive act or practice and the making of false 

advertisements, in or affecting commerce, in violation of Sections 5(a) and 12 of 

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

COUNT XII

UNFAIRLY CHARGING CONSUMERS WITHOUT AUTHORIZATION

102. In numerous instances, in connection with the advertising, marketing, 

promotion, offering for sale, or sale of the Products, Defendants have caused 

charges to be submitted for payment to the credit and debit cards of consumers 

without the express informed consent of those consumers.

103. Defendants’ acts or practices as set forth in Paragraph 102 cause or 

are likely to cause substantial injury to consumers that those consumers cannot 

reasonably avoid themselves and that is not outweighed by countervailing benefits 

to consumers or competition. 

104. Therefore, Defendants’ acts or practices as set forth in Paragraph 102

constitute unfair acts or practices in violation of Section 5 of the FTC Act, 15 

U.S.C. § 45(a) and 45(n).

VIOLATIONS OF THE RESTORE ONLINE SHOPPERS’ CONFIDENCE 

ACT (ROSCA)

105. In 2010, Congress passed ROSCA, 15 U.S.C. §§ 8401-05, which 

became effective on December 29, 2010. Congress passed ROSCA because 

“[c]onsumer confidence is essential to the growth of online commerce. To 

continue its development as a marketplace, the Internet must provide consumers 

with clear, accurate information and give sellers an opportunity to fairly compete 

with one another for consumers’ business.” 15 U.S.C. § 8401.
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106. Section 4 of ROSCA, 15 U.S.C. § 8403, generally prohibits charging 

consumers for goods or services sold in transactions effected on the Internet 

through a negative option feature, as that term is defined in the TSR, 16 C.F.R. § 

310.2(w), unless the seller: (a) clearly and conspicuously discloses all material 

terms of the transaction before obtaining the consumer’s billing information; (b) 

obtains the consumer’s express informed consent before making the charge; and 

(c) provides a simple mechanism to stop recurring charges. See 15 U.S.C. § 8403.

107. The TSR defines a negative option feature as: “in an offer or 

agreement to sell or provide any goods or services, a provision under which the 

consumer’s silence or failure to take an affirmative action to reject goods or 

services or to cancel the agreement is interpreted by the seller as acceptance of the 

offer.” 16 C.F.R. § 310.2(w).

108. As described above in Paragraphs 42 through 47, Defendants 

advertise and sell their Products to consumers through a negative option feature as 

defined by the TSR. See 16 C.F.R. § 310.2(w).

109. Under Section 5 of ROSCA, 15 U.S.C. § 8404, a violation of ROSCA 

is a violation of a rule promulgated under Section 18 of the FTC Act, 15 U.S.C. 

§ 57a, and therefore constitutes an unfair or deceptive act or practice in or affecting 

commerce in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

COUNT XIII

VIOLATIONS OF ROSCA

110. In numerous instances, in connection with the selling of TBX-FREE

on the Internet through a negative option feature, Defendants have failed to:

A. Clearly and conspicuously disclose all material terms of the 

negative option feature of the Product purchase before 

obtaining the consumer’s billing information;
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B. Obtain the consumer’s express informed consent to the negative 

option feature before charging the consumer’s credit card or 

debit card; and/or

C. Provide simple mechanisms for a consumer to stop recurring 

charges to the consumer’s credit card or debit card.

111. Defendants’ practices as set forth in Paragraph 110 are a violation of 

Section 4 of ROSCA, 15 U.S.C. § 8403, and are therefore a violation of a rule 

promulgated under Section 18 of the FTC Act, 15 U.S.C. § 57a, 15 U.S.C. 

§ 8404(a), and therefore constitute an unfair or deceptive act or practice in or 

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

VIOLATIONS OF THE ELECTRONIC FUND TRANSFER ACT AND 

REGULATION E

112. Section 907(a) of the EFTA, 15 U.S.C. § 1693(a), provides that a 

“preauthorized electronic fund transfer from a consumer’s account may be 

authorized by the consumer only in writing, and a copy of such authorization shall 

be provided to the consumer when made.” Section 903(10) of EFTA, 15 U.S.C. § 

1693a(10), provides that the term “preauthorized electronic fund transfer” means 

“an electronic fund transfer authorized in advance to recur at substantially regular 

intervals.” 

113. Section 1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b), provides 

that “[p]reauthorized electronic fund transfers from a consumer’s account may be 

authorized only by a writing signed or similarly authenticated by the consumer. 

The person that obtains the authorization shall provide a copy to the consumer.”

114. Section 1005.10(b) of the Consumer Financial Protection Bureau’s 

Official Staff Commentary to Regulation E (“Official Staff Commentary to 

Regulation E”), 12 C.F.R. § 1005.10(b), Supp. I, provides that “[t]he authorization 

process should evidence the consumer’s identity and assent to the authorization.” 
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Id. ¶ 10(b), cmt. 5. The Official Staff Commentary to Regulation E further 

provides that “[a]n authorization is valid if it is readily identifiable as such and the 

terms of the preauthorized transfer are clear and readily understandable.” Id. 

¶ 10(b), cmt. 6.

115. Pursuant to Section 918(c) of EFTA, 15 U.S.C. § 1693o(c), every 

violation of EFTA and Regulation E constitutes a violation of the FTC Act.

COUNT XIV

EFTA AND REGULATION E VIOLATIONS – UNAUTHORIZED 

DEBITING FROM CONSUMERS’ ACCOUNTS

116. In numerous instances, Defendants debit consumers’ bank accounts 

on a recurring basis without obtaining a written authorization signed or similarly 

authenticated from consumers for preauthorized electronic fund transfers from 

their accounts, thereby violating Section 907(a) of EFTA, 15 U.S.C. § 1693e(a), 

and Section 1005.10(b) of Regulation E, 12 C.F.R. § 1005.10(b).

117. In numerous instances, Defendants debit consumers’ bank accounts 

on a recurring basis without providing to the consumer a copy of a written 

authorization signed or similarly authenticated by the consumer for preauthorized 

electronic fund transfers from the consumer’s account, thereby violating Section 

907(a) of EFTA, 15 U.S.C. § 1693e(a), and Section 1005.10(b) of Regulation E, 12 

C.F.R. § 1005.10(b).

118. By engaging in violations of EFTA and Regulation E as set forth in 

Paragraphs 116 and 117, the Defendants have engaged in violations of the FTC 

Act. 15 U.S.C. § 1693o(c).

VIOLATIONS OF THE TELEMARKETING SALES RULE

119. Congress directed the FTC to prescribe rules prohibiting abusive and 

deceptive telemarketing acts or practices pursuant to the Telemarketing Act, 15 

U.S.C. §§ 6101-6108. The FTC adopted the original TSR in 1995, extensively 
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amended it in 2003, and amended certain provisions thereafter. 16 C.F.R. Part 

310.

120. Under the TSR, a “telemarketer” is any person who, in connection 

with telemarketing, initiates or receives telephone calls to or from a consumer or 

donor. 16 C.F.R. § 310.2(ff). 

121. Under the TSR, an “outbound telephone call” means a telephone call 

initiated by a telemarketer to induce the purchase of goods or services or to solicit 

a charitable contribution. 16 C.F.R. § 310.2(x).

122. As amended, effective September 1, 2009, the TSR prohibits initiating 

an outbound telephone call that delivers a prerecorded message to induce the 

purchase of any good or service. 16 C.F.R. §310.4(b)(1)(v). Calls delivering 

prerecorded messages are commonly called “robocalls.”

123. Pursuant to Section 3(c) of the Telemarketing Act, 15 U.S.C. 

§ 6102(c), and Section 18(d)(3) of the FTC Act, 15 U.S.C. § 57a(d)(3), a violation 

of the TSR constitutes an unfair or deceptive act or practice in or affecting 

commerce, in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

COUNT XV

UNLAWFUL PRERECORDED MESSAGES

124. Through the means described in Paragraphs 52 through 56, as 

applicable, in numerous instances in connection with telemarketing, Defendants 

have engaged in initiating or causing the initiation of outbound telephone calls that 

delivered prerecorded messages to induce the sale of goods or services, in violation 

of 16 C.F.R. § 310.4(b)(1)(v).
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RENGALIFE

COUNT XVI

MISREPRESENTATIONS REGARDING EARNINGS

125. Through the means described in Paragraphs 57 through 65, 

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

that people who become Rengalife members are likely to earn substantial income. 

126. The representation set forth in Paragraph 125 is false, misleading, or

was not substantiated at the time the representation was made. 

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

125 of this Complaint constitutes a deceptive act or practice in or affecting 

commerce in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

CONSUMER INJURY

128. Consumers have suffered and will continue to suffer substantial injury 

as a result of Defendants’ violations of the FTC Act, ROSCA, EFTA, Regulation 

E, and the TSR. In addition, Defendants have been unjustly enriched as a result of

their unlawful acts or practices. Absent injunctive relief by this Court, Defendants 

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

public interest.

THIS COURT’S POWER TO GRANT RELIEF

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

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

and redress violations of any provision of law enforced by the FTC. The Court, in 

the exercise of its equitable jurisdiction, may award ancillary relief, including 

rescission or reformation of contracts, restitution, the refund of monies paid, and 

the disgorgement of ill-gotten monies, to prevent and remedy any violation of any 

provision of law enforced by the FTC.
0 0 

PRAYER FOR RELIEF 

2 Wherefore, Plaintiff FTC, pursuant to Section I 3(b) of the FTC Act, 15 

3 U.S.C. § 53(b), Section 5 of ROSCA, 15 U.S.C. § 8404, Section 918(c) ofEFTA,

4 15 U.S.C. § 1693o(c), Section 6 of the Telemarketing Act, 15 U.S.C. § 6105, and 

s the Court's own equitable powers, requests that the Court: 

6 A. Award Plaintiff such preliminary injunctive and ancillary relief as

7 may be necessary to avert the likelihood of consumer injury during the pendency 

8 of this action and to preserve the possibility of effective final relief, including but 

9 not limited to, temporary and preliminary injunctions, an order freezing assets, 

1 o immediate access to all corporate premises, and appointment of a receiver. 

1 I 8. Enter a permanent injunction to prevent future violations of the FTC

12 Act, ROSCA, EFT A, Regulation E, and the TSR, by Defendants; 

13 C. Award such relief as the Court finds necessary to redress injury to

14 consumers resulting from Defendants' violations of the FTC Act, ROSCA, EFTA, 

Is Regulation E, and the TSR, including but not limited to, rescission or reformation 

J 6 of contracts, restitution, the refund of monies paid, and the disgorgement of ill17 gotten monies; and 

18 D. Award Plaintiff the costs of bringing this action, as well as such other

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

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Dated: 0 c:..h� 31 U>J i

Respectfully submitted, 

ALDEN F. ABBOTT 

General Counsel 

ELIZABETH SANGER 

esanger@ftc.gov 

JAMES A. PRUNTY 

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jprunty@ftc.gov

EDWIN RODRIGUEZ 

erodriguez@ftc.gov

SHIRA D. MODELL 

smodell@ftc.gov

Federal Trade Commission

600 Pennsylvania Ave., NW

Washington, DC 20580

STACY PROCTER (Local Counsel) 

sprocter@ftc.gov

Federal Trade Commission

10990 Wilshire Blvd., Suite 400

Los Angeles, CA 90024

Attorneys for Plaintiff

FEDERAL TRADE COMMISSION