X180007 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman 

Noah Joshua Phillips 

Rohit Chopra 

Rebecca Kelly Slaughter 

Christine S. Wilson 

________________________________________________ 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company,

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

________________________________________________ 

COMPLAINT 

The Federal Trade Commission, having reason to believe that Health Research 

Laboratories , a limited liability company, Whole Body Supplements , a 

limited liability company, and Kramer Duhon, individually and as an owner and officer of HRL 

and WBS 

Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges: 

1. Respondent HRL is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

2. Respondent WBS is a Nevada limited liability company with its principal office or place 

of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

3. Respondent Kramer Duhon is the Chief Operating Officer and managing member of HRL 

and the Chief Operating Officer and managing member of WBS. Individually or in concert with 

others, he controlled or had the authority to control the acts and practices of HRL and WBS, 

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

business is 16250 Knoll Trail Drive, Dallas, TX 75248. 
 

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4. Respondents have advertised, labeled, offered for sale, sold, and distributed, or caused to 

be distributed a number of dietary supplement products to consumers. HRL sold, among other 

products, Black Garlic Botanicals, The Ultimate Heart Formula, and Neupathic. WBS sold 

BG18, among other products. Black Garlic Botanicals, BG18, The Ultimate Heart Formula, and 

Neupathic are ood

Trade Commission Act. 

5. The acts and practices of Respondents alleged in this complaint have been in or affecting 

Black Garlic Botanicals 

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

600 mg of the active ingredient black garlic, and the recommended dosage is two capsules a day. 

HRL sells a one-month supply of Black Garlic Botanicals for $39.95, plus shipping and 

handling. 

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

materials for Black Garlic Botanicals in multi-page mailers sent to consumer residences and on 

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

following representations and depictions: 
 

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Exhibit A (Black Garlic Botanicals mailer) 

This front-page content is followed by additional descriptions of the dangers of 

cardiovascular disease. For example, the second and third pages display a banner across 

A banner at the bottom states

help 

The mailer continues with the following statements about the efficacy of black garlic in 

reducing arterial plaque, blood pressure, and cholesterol: 

 

BLACK GARLIC WORKS WITH YOUR BODY 

Cholesterol: Black Garlic helps maintain healthy cholesterol 

levels. 

Clotting: Black Garlic supports healthy platelet aggregation, 

which can help to keep blood circulating and works against 

clotting. 
 

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Supports and helps maintain healthy blood pressure levels to 

combat risks. 

Healthy Arteries 

Plaque build-up in arteries can lead to unhealthy heart conditions. Black 

Garlic helps keep blood vessels barrier-free to create smooth flow, which 

could address symptoms of fatigue. It may also inhibit calcium binding, 

which is responsible for arterial plaque formation. 

Want Healthy Blood Pressure & Cholesterol? Black Garlic helps maintain 

healthy blood pressure, cholesterol and triglyceride levels. 

BLACK GARLIC 

A BREAKTHROUGH FOR 

Cholesterol 

Blood Sugar 

Blood Pressure 

The Heart 

The Brain 

months my LDL levels have reduced from 300 to 150. This product 

 

Botanicals. Thi 

BG18 

8. WBS began selling BG18 in August 2017. The product has identical ingredients to Black 

Garlic Botanicals. Each capsule contains 600 mg of the active ingredient black garlic, and the 

recommended dosage is two capsules a day. WBS sells a one-month supply of BG18 for $44.95, 

plus shipping and handling. 

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

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

example of a mailer for BG18 is attached as Exhibit B. 

The front page of the attached BG18 mailer features an image of a caduceus and, a 

photograph of a doctor in a white coat, n amazing 

power to improve heart and cardiovascular health, maintain normal cholesterol levels, 

boost your immune system. And MUCH MORE The mailer continues with the 

following representations: 

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

Your Heart. 
 

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[Black Garlic] can help reverse plaque build-up in arteries not just slow 

it down. Black Garlic keeps blood vessels barrier-free to create a smooth 

blood flow and alleviates symptoms of fatigue. It also strongly inhibits 

calcium binding, which is responsible for plaque build-up. 

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

high blood pressure and lowers high levels of bad cholesterol and 

triglycerides. 

 I recommend this product 

~ Lorraine T. 

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

 Exhibit B (BG18 mailer). 

Yes, Black Garlic is a true miracle for cardiovascular health! Just 1 

capsule knocks down cholesterol and high blood pressure within days. It 

can also unblock, clean, and strengthen your arteries. 

The cardio-protective effect of black garlic. . . Black garlic can also 

improve your lipid profile, an important factor in protecting against 

cardiovascular problems. 

The Ultimate Heart Formula 

10. ce November 2008. UHF 

contains Vitamins C, E, and B12 as well as garlic extract (25 mg), Tetrasodium EDTA (40 mg), 

Ubiquinol (CoEnzyme Q-10) (5 mg), and Nattokinase (10 mg). HRL sold a oneof UHF for $39.95, plus shipping and handling. The recommended dosage is 20 drops or 1ml, 

twice per day. 
 

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

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

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

Exhibit C (The Ultimate Heart Formula mailer). 
 

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

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

including: 

Instead, right before you is a simple, safe, inexpensive, non-painful and 

preventative option that could help you say goodbye to your heart surgeon 

and avoid an angioplasty. 

Our Ultimate Heart Formula can help support a healthy heart, healthy 

cholesterol and healthy blood pressure. As blockages in your veins and 

arteries become clear, you can experience better blood circulation 

resulting in more energy, better sleep, sharper mental clarity and better 

health. 

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

The Ultimate Heart Formula is an all-natural combination of 19 powerful 

herbs and essential nutrients that counter the causes of poor cardio health. 

ingredients specifically shown to help improve the effects of a weakened 

heart, clogged arteries, high blood pressure and high cholesterol for older 

people! 

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

artery protection ... without side effects! 
 

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Yes, with the Ultimate Heart Formula, a lifetime of plaque build up could 

disappear before you know it! The artery-flushing power of this formula 

 

Neupathic 

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

Neupathic contains the following active ingredients: Vitamins E (30 IU), B1 (33.3 mg), B6 

(33.3 mg), B12 (16.7 mcg), and folate (266.7 mcg), and Evening Primrose Oil (666.7 mg). HRL 

sold a one- and handling. The 

recommended dosage is two capsules per day. 

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

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

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

statements on the first page: 

Exhibit D (Neupathic mailer). 

The mailer continues inside with additional claims: 

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

symptoms below. 
 

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Shooting pain 

Burning 

Pins and needles 

Electric shock-like pain 

Extra sensitivity 

Numbness 

Throbbing 

Tingling 

Stinging 

Stabbing 

Radiating 

 Neupathic was specifically formulated with 6 distinct nutrients to help 

 address ALL these issues and more. 

formulated from the ground 

up to improve your circulation and ease the numbness, tingling, itching, 

burning and swelling from excess fluid trapped in your legs. 

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

Exhibit D (Neupathic mailer, p. 11). 

Respond now if your nerve pain is driving you crazy! 

completely natural, real relief from your discomfort. All natural 

Neupathic is 100% effective and safe to use every day! Remember, it has 

[sic] shown to help reverse damaged nerves to help you feel great all day 

and all night. 

 

 I also hardly 

 Ruth J. 

-

first day you use it. Then it continues to control your pain every day. My 
 

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feet have began [sic] to feel normal. Neupathic has improved my life. My 

nerve pain is gone and I will continue to take Neupathic until my 

 Gloria R. Id. 

Count I 

Unsubstantiated Claims Related to Black Garlic Botanicals 

(HRL and Duhon) 

14. In connection with the advertising, promotion, offering for sale, or sale of Black Garlic 

Botanicals, HRL and Kramer Duhon have represented, directly or indirectly, expressly or by 

implication, that Black Garlic Botanicals: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque; 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

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

representations were made. 

Count II 

(WBS and Duhon) 

16. In connection with the advertising, promotion, offering for sale, or sale of BG18, WBS 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

BG18: 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 
 

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c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

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

representations were made. 

Count III 

(HRL and Duhon) 

18. In connection with the advertising, promotion, offering for sale, or sale of UHF, HRL 

and Kramer Duhon have represented, directly or indirectly, expressly or by implication, that 

UHF 

a. Prevents or reduces the risk of cardiovascular disease including by lowering blood 

pressure, improving blood flow, reducing cholesterol, or decreasing arterial 

plaque; 

b. Treats cardiovascular disease including by lowering blood pressure, improving 

blood flow, reducing cholesterol, or decreasing arterial plaque. 

c. Prevents or reduces the risk of atherosclerosis including by reducing cholesterol 

or decreasing arterial plaque; 

d. Treats atherosclerosis including by reducing cholesterol or decreasing arterial 

plaque; and 

e. Cures, treats, or mitigates hypertension including by decreasing arterial plaque or 

lowering blood pressure. 

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

representations were made. 

Count IV 

Unsubstantiated Claims Related to Neupathic 

(HRL and Duhon) 

20. In connection with the advertising, promotion, offering for sale, or sale of Neupathic, 

HRL and Kramer Duhon have represented, directly or indirectly, expressly or by implication, 

that Neupathic: 
 

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

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

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

representations were made. 

Violations of Sections 5 and 12

22. The acts and practices of Respondents as alleged in this complaint constitute unfair or 

deceptive acts or practices, and the making of false advertisements, in or affecting commerce in 

violation of Sections 5(a) and 12 of the Federal Trade Commission Act. 

NOTICE 

You are notified that on July 13, 2021, at 10:00 a.m., at the Federal Trade Commission 

offices, 600 Pennsylvania Avenue, NW, Room 532-H, Washington, DC 20580, an 

Administrative Law Judge of the Federal Trade Commission will hold a hearing on the charges 

set forth in this Complaint. At that time and place, you will have the right under the Federal 

Trade Commission Act to appear and show cause why an order should not be entered requiring 

you to cease and desist from the violations of law charged in this Complaint. 

You are notified that you are afforded the opportunity to file with the Federal Trade 

Commission an answer to this Complaint on or before the 14th day after service 

of the Complaint upon you. An answer in which the allegations of the Complaint are contested 

must contain a concise statement of the facts constituting each ground of defense; and specific 

admission, denial, or explanation of each fact alleged in the Complaint or, if you are without 

knowledge thereof, a statement to that effect. Allegations of the Complaint not thus answered 

will be deemed to have been admitted. 

If you elect not to contest the allegations of fact set forth in the Complaint, the answer 

should consist of a statement that you admit all of the material facts to be true. Such an answer 

will constitute a waiver of hearings as to the facts alleged in the Complaint and, together with the 

Complaint, will provide a record basis on which the Commission may issue a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. In 

such answer, you may, however, reserve the right to submit proposed findings of fact and 

conclusions of law under FTC Rule § 3.46. 

Failure to answer timely will be deemed to constitute a waiver of your right to appear and 

contest the allegations of the Complaint. It will also authorize the Commission, without further 

notice to you, to find the facts to be as alleged in the Complaint and to enter a final decision 

containing appropriate findings and conclusions and a final order disposing of the proceeding. 
 

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The Administrative Law Judge will hold an initial prehearing scheduling conference not 

later than 10 days after the answer is filed by the last answering Respondent. Unless otherwise 

directed by the Administrative Law Judge, the scheduling conference and further proceedings 

will take place at the Federal Trade Commission, 600 Pennsylvania Avenue, NW, Room 532-H, 

Washington, DC 20580. Rule 3

practicable before the prehearing scheduling conference, but in any event no later than 5 days 

after the answer is filed by the last answering Respondent. Rule 3.31(b) obligates counsel for 

each party, within 5 days of receiving a R

without awaiting a formal discovery request. 

Moreover, the Commission has reason to believe that, if the facts are found as alleged in 

the Complaint, it may be necessary and appropriate for the Commission to seek relief to redress 

injury to consumers. Such relief could be in the form of restitution for past, present, and future 

consumers and such other types of relief as are set forth in Section 19(b) of the Federal Trade 

Commission Act. The Commission will determine whether to apply to a court for such relief on 

the basis of the adjudicative proceedings in this matter and such other factors as are relevant to 

consider the necessity and appropriateness of such action. 
 

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NOTICE OF CONTEMPLATED RELIEF 

Should the Commission conclude from the record developed in any adjudicative proceedings 

in this matter that Respondents have violated or are violating Sections 5(a) and 12 of the FTC 

Act, 15 U.S.C. §§ 45(a) and 52, the Commission may order such relief against Respondents as is 

supported by the record and is necessary and appropriate, including but not limited to: 

a.

prevent, or reduce the risk of any disease. 

b. A prohibition on representations about the health benefits, safety, efficacy, or the 

competent and reliable scientific evidence. 

c. A prohibition on misrepresentations regarding tests, studies, or other research. 

d. A requirement that Respondents preserve records relating to competent and reliable 

clinical tests or studies. 

e. A requirement that Respondents send appropriate notification of the order to all affected 

customers. 

f. A requirement that Respondents cancel any automatically recurring orders for Black 

Garlic Botanicals, BG18, UHF, or Neupathic for any existing customer who was first 

charged before the issuance of the Complaint. 

g. A requirement that Respondents will not use, sell, rent, lease, or transfer any identifying 

information related to any customer who paid money to any Respondent for Black Garlic 

Botanicals, BG18, UHF, or Neupathic prior to the issuance of the Complaint. 

h. A requirement that, for a period of time, Respondents send acknowledgments of the order 

to the Commission. 

i. A requirement that, for a period of time, Respondents create and preserve certain records 

demonstrating compliance with the order. 

j. A requirement that, for a period of time, Respondents provide notice of all new business 

activity to the Commission. 

k. A requirement that Respondents file periodic compliance reports with the Commission. 

l.

determined by the Commission. 

 
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m. Any other relief appropriate to correct or remedy the effects of Resp

practices or of any or all of the conduct alleged in the complaint.

IN WITNESS WHEREOF, the Federal Trade Commission has caused this complaint to be 

signed by its Secretary and its official seal to be hereto affixed at Washington, DC, this 13th day 

of November 2020. 

By the Commission. 

April J. Tabor 

Acting Secretary 

SEAL: