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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 1 of 15 Page ID #:1 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney General, Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General, Civil Division 

AMANDA N. LISKAMM 

Acting Director, Consumer Protection Branch 

GABRIEL H. SCANNAPIECO 

Assistant Director, Consumer Protection Branch 

CHRISTINA PARASCANDOLA 

christina.parascandola@usdoj.gov 

ZACHARY A. DIETERT 

zachary.a.dietert@usdoj.gov 

Trial Attorneys 

Consumer Protection Branch 

Civil Division, U.S. Department of Justice 

450 5th Street, NW, Suite 6400-South 

Washington, DC 20044-0386 

Telephone: (202) 514-3097 (Parascandola) 

(202)-616-9027 (Dietert) 

Facsimile: (202) 514-8742 

Attorneys for Plaintiff 

UNITED STATES OF AMERICA 

UNITED STATES DISTRICT COURT 

CENTRAL DISTRICT OF CALIFORNIA 

United States of America, 

No. 

 Plaintiff, 

COMPLAINT FOR PERMANENT 

vs. INJUNCTION, CIVIL PENALTIES, 

AND OTHER RELIEF 

Dr. Tina Wong, 

Defendant. 
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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 2 of 15 Page ID #:2 

Plaintiff, the United States of America, acting upon notification and 

authorization to the Attorney General by the Federal Trade Commission (“FTC”), 

pursuant to Section 16(a)(1) of the FTC Act, 15 U.S.C. § 56(a)(1), for its 

Complaint alleges: 

1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A), 12, 

13(b), and 16(a)(1) of the Federal Trade Commission Act (“FTC Act”), 15 

U.S.C. §§ 45(a)(1), 45(m)(1)(A), 52, 53(b), and 56(a)(1), and Section 1401 of the 

COVID-19 Consumer Protection Act of the 2021 Consolidated Appropriations Act 

(“CCPA”), Pub. L. No. 116-260, § 1401, 134 Stat. 1182, 3275-76 (2020), which 

authorize Plaintiff to seek, and the Court to order, permanent injunctive relief, civil 

penalties, and other relief for Defendant’s acts or practices in violation of Sections 

5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52, and Section 1401 of the 

CCPA. 

JURISDICTION AND VENUE 

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

§§ 1331, 1337(a), 1345, and 1355. 

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

(c)(1), and 15 U.S.C. § 53(b). 

DEFENDANT 

4. Defendant Dr. Tina Wong, M.D. (“Defendant”) is a pediatrician and a 

distributor for doTERRA International, LLC (“doTERRA”), a Utah-based multilevel marketing company that sells essential oils, supplements, and other products. 

Defendant holds the rank of Blue Diamond with doTERRA and is also a member 

of the doTERRA US Founders Club 2.0. Defendant shares her doTERRA 

distributorship with her husband, Dr. Mark Wong. Defendant 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. 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 3 of 15 Page ID #:3 

COMMERCE 

5. At all times relevant to this Complaint, Defendant has 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. 

DEFENDANT’S BUSINESS ACTIVITIES 

6. Defendant promotes doTERRA products and business opportunities 

through numerous means, including through her website, social media accounts, 

and online webinars. Defendant has represented that certain doTERRA essential oil 

and supplement products (“doTERRA Products”) are effective in preventing and 

treating Coronavirus Disease 2019 (“COVID-19”). 

7. Defendant was one of several presenters at a January 12, 2022 Zoom 

webinar titled “The Path Forward: Protocols for the Current Climate” that included 

approximately 500 participants. The webinar was organized and promoted by 

doTERRA distributors who currently or previously worked as health-care 

practitioners, and the registration link for the webinar was distributed on publicly 

accessible social media accounts. During this webinar, Defendant introduced 

herself as a board-certified pediatrician and made the following statements: 

a) “Now we’re going to go into our first topic, which is COVID 

prevention basics and it really encompasses nutrition. That is 

the foundation of your health. And LLV [Lifelong Vitality Pack] 

from doTERRA is amazing. It provides 12 servings of fruits 

and vegetables a day. It’s totally antioxidant. It is 

comprehensive and bioavailable, meaning that your body 

absorbs it well. And so those three bottles are foundational. 

And then on top of that, we recommend the PB Assist for gut 

health and then the TerraZyme also for gut health because gut is 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 4 of 15 Page ID #:4 

so important. Much of your immune system is located in your 

gut. 

And on top of that, On Guard, of course, in fact, everybody 

please find your favorite immune oil that you have around and 

use it. Use it frequently. Use it all three ways. So my favorites 

are On Guard and oregano, actually, and I will put a drop of 

each into a little shot glass of water if I have any sore throat and 

I will gargle and I will swallow and that takes care of so much 

of the beginning of a sore throat. 

And what’s great about this Healthy Habits Kit is On Guard is 

in there. Oregano isn’t, you can add it. But in addition to that, 

you have frankincense, which is highly anti-inflammatory and 

so good for your immune system. And the other thing that I 

love is the On Guard Chewables because that has extra vitamin 

C and D on top of what you would get through the LLV and it 

has zinc and beta glucan as well.” 

[Defendant made these statements as a slide titled “COVID 

PREVENTION BASICS” was displayed. The slide included a 

depiction of the doTERRA Healthy Habits Kit and listed the 

$195 price. The Kit includes doTERRA Balance, tangerine, 

lavender, frankincense, and On Guard oils; Deep Blue Rub; 

DigestZen TerraZyme; PB Assist+; Microplex VMz; xEO 

Mega; and Alpha CRS+.] 

b) “And so this is the pediatric prevention/support for COVID. 

And, again, it starts at nutrition. And I like this slide because 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 5 of 15 Page ID #:5 

this is the order in which you want to give these supplements 

because they progressively taste better. And if you know kids, 

right, it’s all about the taste, okay? So first, the IOmega can 

taste a little fishy, so, so good for the immune system, though, 

and good for the brain. I mix it with orange juice. My kids don’t 

get juice usually, so when they get something with juice, they’re 

like excited and it tastes good. So I mix it with orange juice, a 

teaspoon. And then do that twice a day. The A to Z Chewables 

are great. Two a day is the recommended dose. 

And then the On Guard Chewable Tablets, it’s recommended 

dose three a day. But if your child has COVID, definitely six a 

day is the way that I would go. And then PB Assist is amazing. 

It tastes like candy, right? But it has no sugar in it. And that is a 

great one to take a lot of because you really want good immune 

health, even up to four a day is what I would recommend. 

Now, Immune Honey is awesome for kids, but we don’t want to 

use any honey for a child that is less than one because of the 

risk for botulism. So for that child, if you want to help with the 

cough, then you would make a molasses. So for greater than 

one year of age, I do give essential oils to my kids, just a little 

bit, though. And the safest ones, I would have to say, are 

frankincense and lemon. And also for sinus cups, frankincense 

and lemon are great because sometimes the Breathe oil is just a 

little too strong, that menthol component is a little too strong 

for them. So frankincense and lemon are great for respiratory 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 6 of 15 Page ID #:6 

oils. You can mix it with coconut oil, rub it on the chest, rub it 

on the spine, on the feet, diffuse it as well. It’s very effective. 

And something that I love to do for kids instead of giving 

pharmaceuticals or over-the-counters for congestion is I love to 

give them baths, even like several a day, even three a day, and 

just warm baths helps to decrease the congestion, and then 

when they come out of the bath, their pores are opened up, the 

perfect time to do a diluted essential oil, like frankincense or 

lemon on their skin and the body absorbs it very well.” 

[Defendant made these statements as a slide titled 

“PEDIATRIC PREVENTION/SUPPORT BASICS” was 

displayed. The slide included depictions of and prices for 

various doTERRA Products, including A-Z Chewables, IQ 

Mega, On Guard Chewables, PB Assist Jr, frankincense oil, and 

lemon oil.] 

c) “Okay, yes, and then the SOC [Symphony of the Cells] for kids 

is awesome and it’s such a wonderful way to bond with them, 

too. And just the really simple basic one will do, frankincense, 

tea tree, Aromatouch and peppermint. Remember always to 

dilute, though, because the peppermint can be a little bit strong. 

And we didn’t mention allowing your child to have a little bit of 

a fever to burn out the virus. You can do that unless they have a 

risk for febrile seizures, and in that case, you don’t want to risk 

that. But peppermint is a great oil for reducing fever. And 

actually, the Japanese peppermint that you can get free this 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 7 of 15 Page ID #:7 

month has a higher menthol content. So that will work even 

faster.” 

[Defendant made these statements as a slide titled “SUPPORT 

PROTOCOLS FOR COVID (+) PEDIATRIC, SUPPORT 

THERAPIES” was displayed. This slide included the text, 

“INFLAMMATORY PROTOCOL POST BATH: 

FRANKINCENSE, TEA TREE, AROMATOUCH, 

PEPPERMINT, COCONUT OIL.”] 

d) “Oils for a severe sore throat? I like to do a little shot glass of 

water with a drop of On Guard and gargle and swallow that 

about three or four times a day. That usually takes care of my 

sore throat. And if you’re brave, you can actually add a drop of 

oregano and that works really well, too. And there’s lots of 

studies that show that oregano is effective against a 

coronavirus, which is the family that COVID is in. 

The other thing is you can suck on the On Guard lozenges all 

day long. That really helps, too. Okay. And as Dr. Lisa 

mentioned, this is really like a sinus type virus. So doing a lot 

of the diffusing, the sinus mugs really are helpful. Putting 

actually DigestZen over your sinuses is very helpful as well. 

... So those are just some little tips. Of course, it’s 

symptomatic; you’re treating your symptoms, but that’s what 

the drugs do, too. So use your oils instead and then use them 

frequently. You also get the immune benefits of it. You’ll have 

side benefits.” 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 8 of 15 Page ID #:8 

8. Defendant has presented at a weekly Zoom webinar series that 

promotes doTERRA Products, titled “The Doctors Are In.” The webinar has been 

promoted on publicly accessible social media sites as an opportunity to: “Learn 

about essential oils from medical & dental professionals. Ask your essential oil 

questions & inquire about the ailments you have.” During the January 27, 2022 

“The Doctors Are In” webinar, Defendant introduced herself as a board-certified 

pediatrician and made the following statements: 

a) “The second cool thing about essential oils is that they are 

effective. So if you can imagine, those of you who see me on 

the screen, like this hand is a cell, okay? Every cell has a 

protective oily membrane that keeps out bacteria, keeps out 

diseases. And what happens is there’s another disease that 

actually works inside the cell and that’s the virus, like the 

COVID virus. It attaches to our cell and it works inside of our 

cell, okay? 

Most antibiotics, which is what we give for bacterial diseases, 

the antibiotics work outside the cell. They can’t go into the cell, 

okay? But essential oils can penetrate through the cell 

membrane and work within the cell to kill viruses or to change 

their modulation, the way that they’re expressed. So essential 

oils are very effective because they can get into a cell. On 

Guard, in particular, is a great oil for this time because it really 

helps with antivirus. It’s a great flu buster.” 

b) “This is a very complicated slide. I just want to say very 

quickly that garlic, black pepper oil and tea tree oil actually 

prevent the binding of the virus to your cells. It’s a competitive 

inhibition at the cell receptor site of the spike protein. So 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 9 of 15 Page ID #:9 

basically what I’m saying is that when you use those three oils, 

garlic, peppermint – I mean, black pepper or tea tree, it acts like 

a guard dog at the surface of your cell. It prevents the virus 

from binding. And then the other two essential oils I wanted to 

talk about in the study are lemon and geranium. Remember, 

where did I say the essential oils work in our cells? Where?... 

Inside of the cell, right. And one of the ways that lemon and 

geranium essential oil work inside the cell is that they don’t let 

the virus replicate itself. Pretty cool, right? You’ve all heard 

about like mRNA with the shot and everything. Well, lemon 

and geranium essential oil inhibit the mRNA transcription of 

the virus.” 

[Defendant made these statements as a slide with a diagram that 

included a depiction of a virus clearly labeled “SARS-CoV-2” 

was displayed. This slide included the text: “Several plant 

products have shown potential in interfering with the activity of 

ACE2.... For example, the essential oils from... garlic..., 

Melaleuca...[,] pepper... can potentially latch onto ACE2 and 

competitively inhibit viral binding and entry... essential oils 

from geranium and lemon prove to be effective against ACE2 

by downregulating its mRNA and protein expressions in 

epithelial cells.”] 

c) “And then a lot of people lose their sense of smell and taste 

with the COVID and so here is a protocol to help regain that. 

You smell clove essential oil three times a day, 20 seconds each 

time; lemon and then rose and then eucalyptus in that order and 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 10 of 15 Page ID #:10 

20 seconds each. Do that three times a day, and in 6 to 12 

weeks, you should be able to regain your taste – sense of taste 

and smell.” 

[Defendant made these statements as a slide titled “Olfactory 

Training FOR LOSS OF SMELL” was displayed. This slide 

included depictions of several different doTERRA essential oil 

products and included the text: “Pick 4 oils of contrasting 

aroma... Smell each one for 20 seconds 3 times a day... Do this 

for 6-12 weeks... Olfactory cells regenerate every 30 days so 

give your body time... Loss of taste, brush with cilantro oil 

twice a day.”] 

d) “So if you want to take a picture of this, you can. It’s a protocol 

that we made using the doTERRA products for COVID. 

Okay?” 

[Defendant made these statements as a slide titled “Tips for 

COVID Prevention” was displayed. This slide included the text: 

“1. Take LLV full dose (4 per bottle, divided into AM and 

PM)... 

2. Diffuse On Guard at night and rub on feet... 

3. Apply 2-3 times/day On Guard or FLOOT over neck and 

wrists 

4. Apply Correct X inside nose.... 

6. Keep gut healthy – probiotics enzymes (Terrazyme), 

doterra [sic] Greens with the superfoods (moringa, noni, acai, 

kale, alfalfa, wheat grass, and more!), and doterra fiber... 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 11 of 15 Page ID #:11 

7. Get your vaccine – initial and booster. Full immunity 

reached 2 weeks from second dose. 

o Take your LLV, on guard oil, lemon & other citrus 

essential oils (increases glutathione) throughout the preand post-vaccine period. 

o Oils to use for vaccine detox – cilantro oil in tea 2-3 

times a day. Rub zendocrine essential oil on feet and over 

liver. Take LLV and take zendocrine complex and/or 

zendocrine softgels 3 times daily for 2 weeks after shot.”] 

e) “And then here’s another picture if you want to take that so in 

the case that you do get it. Thankfully, omicron seems to be a 

little lighter of a strain, but you want to have your oils with you, 

you want to do early treatment because I do know quite a few 

deaths and I could have... them just – I haven’t treated COVID 

patients myself in the hospital. I mean, I’ve done it as an 

outpatient, but there have – I mean, it’s a serious thing. 

So if you’re not feeling well, you do need to get treatment. And 

then I would recommend highly that if you are positive or feel 

like you are, just do a ton of supplements, a ton of oils, and all 

the things that we’ve done here, twice a day. Showers, 

hydrotherapy. You want to be smelling the oils, drinking them, 

putting them on your skin, eating super healthy.” 

[Defendant made these statements as a slide titled “Tips for 

COVID Recovery” was displayed. This slide included the text: 

“Double LLV (8 per bottle, divided into AM and PM). Consider 

taking Turmeric also.... Diffuse On Guard at night and rub on 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 12 of 15 Page ID #:12 

feet... Every 15 minutes – Apply On guard or FLOOT or 

Nuclear Bomb over neck and wrists... Hot steamy showers 

twice a day. Breath or Eucalyptus oil in shower. Inhale 

deeply...”] 

9. At present, there is no published report of any well-controlled human 

clinical study to substantiate that any of the doTERRA Products referenced above 

treat, prevent, reduce the risk or severity of, or cure COVID-19, or counteract 

inflammation or other purported negative effects of COVID-19 vaccines. 

10. Based on the facts and violations of law alleged in this Complaint, 

Plaintiff has reason to believe that Defendant is violating or is about to violate the 

FTC Act and the CCPA. 

VIOLATIONS OF THE FTC ACT 

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

deceptive acts or practices in or affecting commerce.” 

12. Misrepresentations or deceptive omissions of material fact constitute 

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

13. 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, doTERRA Products are “drugs” as defined in Section 15(c) of the FTC Act, 

15 U.S.C. § 55(c). 

14. Enacted on December 27, 2020, the CCPA makes it unlawful, for the 

duration of the public health emergency declared on January 31, 2020 pursuant to 

Section 319 of the Public Health Service Act, for any person, partnership, or 

corporation to “engage in 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)) that is associated with 

. . . the treatment, cure, prevention, mitigation, or diagnosis of COVID 19.” CCPA 

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 13 of 15 Page ID #:13 

§ 1401(b)(1). As of the date of the filing of this Complaint, the public health 

emergency remains in effect. 

15. The CCPA provides that “[a] violation of subsection (b) shall be 

treated as a violation of a rule defining an unfair or deceptive act or practice 

prescribed under Section 18(a)(1)(B) of the [FTC] Act (15 U.S.C. § 57a(a)(1)(B)).” 

CCPA § 1401(c)(1). 

16. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as 

modified by Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 

1990, 28 U.S.C. § 2461, as amended, and as implemented by 16 C.F.R. § 1.98(d), 

authorizes this Court to award monetary civil penalties for each violation of 

Section 5(a) of the FTC Act pursuant to the CCPA, 16 C.F.R. § 1.98(d). 

COUNT ONE 

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

promotion, offering for sale, or sale of doTERRA Products, including through the 

means described in Paragraphs 6-8 of this Complaint, Defendant has represented, 

directly or indirectly, expressly or by implication, that doTERRA Products: 

a) treat, prevent, reduce the risk or severity of, or cure COVID-19 

in both adults and children; and 

b) counteract inflammation or other purported negative effects of 

COVID-19 vaccinations. 

18. On or after December 27, 2020, Defendant made the representations 

set forth in Paragraph 17, which are associated with the prevention, mitigation, 

treatment, or cure of COVID-19. 

19. The representations set forth in Paragraph 17 are false or misleading 

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

20. Therefore, the making of the representations set forth in Paragraph 17 

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

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Case 2:23-cv-00063 Document 1 Filed 01/05/23 Page 14 of 15 Page ID #:14 

advertisements in violation of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. 

§§ 45(a) and 52. 

21. Defendant committed the violations set forth in Paragraph 20 with the 

knowledge required by Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. 

§ 45(m)(1)(A). 

CONSUMER INJURY 

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

substantial injury as a result of Defendant’s violations of the FTC Act. Absent 

injunctive relief by this Court, Defendant is likely to continue to injure consumers 

and harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the FTC 

Act and the CCPA by Defendant; 

B. Award Plaintiff monetary civil penalties from Defendant for every 

violation of Section 5(a) of the FTC Act pursuant to the CCPA; and 

C. Award any additional relief as the Court determines to be just and 

proper. 

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Case 2:23-cv-00063 Document 1 

Dated: January 5, 2023 

FOR THE FEDERAL TRADE 

COMMISSION: 

ANISHA DASGUPTA 

General Counsel 

SERENA VISWANATHAN 

Associate Director 

Division of Advertising Practices 

CHRISTINE LEE DELORME 

TIFFANY M. WOO 

Attorneys 

Division of Advertising Practices 

Filed 01/05/23 Page 15 of 15 Page ID #:15 

Respectfully submitted, 

FOR THE UNITED STATES OF 

AMERICA: 

BRIAN M. BOYNTON 

Principal Deputy Assistant Attorney 

General, Civil Division 

ARUN G. RAO 

Deputy Assistant Attorney General, 

Civil Division 

AMANDA N. LISKAMM 

Acting Director, Consumer Protection 

Branch 

GABRIEL H. SCANNAPIECO 

Assistant Director, Consumer Protection 

Branch 

/s/ Christina Parascandola 

CHRISTINA PARASCANDOLA 

ZACHARY A. DIETERT 

Trial Attorneys 

Consumer Protection Branch 

Civil Division 

U.S. Department of Justice 

450 5th Street, NW, Suite 6400-South 

Washington, DC 20044-0386 

Tel.: (202) 514-3097 (Parascandola) 

 (202)-616-9027 (Dietert) 

Fax: (202) 514-8742 

christina.parascandola@usdoj.gov 

zachary.a.dietert@usdoj.gov 

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