UNITED STATES OF AMERICA 

Federal Trade Commission 

WASHINGTON, D.C. 20580 

April 24, 2020 

Via Electronic Mail 

Total Life Changes, LLC 

c/o Ron Rose, Director of Legal and Compliance 

6095 Corporate Dr. 

Fair Haven, Michigan 48023 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Rose, 

FTC staff has reviewed social media posts made by Total Life Changes, LLC (“Total 

Life Changes”) business opportunity participants or representatives that unlawfully advertise that 

certain products treat or prevent Coronavirus Disease 2019 (COVID-19) and misrepresent that 

consumers who become Total Life Changes business opportunity participants are likely to earn 

substantial income. This letter is to provide you with information about laws and regulations 

enforced by the Federal Trade Commission (“FTC”) that may bear upon your business activities, 

including the activities of your business opportunity participants and representatives. 

Some examples of Coronavirus prevention or treatment claims made by your business 

opportunity participants or representatives include: 

 “Have you had your vitamins today! Did your kids have their vitamins? Did you 

get your daily dose of Fruits and vegetables? HOW WILL YOU FIGHT OFF 

CORONA? USE NUTRABURST-CHAGA- .... #coronacure #coronaprevention 

... #immunesupport #immunebooster ... #immunesystembooster” 

 “Yesss Protect Your Immune System... #nutraburst #coronavirusfighter ... 

#immunesystembooster.” The text accompanied the image of a product with a 

surgical mask and a caption reading, “PROTECT YOURSELF. GIVE YOUR 

IMMUNE SYSTEM THE BOOST IT NEEDS.” 

 “BOOST UP YOUR IMMUNE SYSTEM!!! Don’t get caught out there and 

#Corona grab a hold of you.” Text accompanied an image of four bottles of Nutra 

Burst. 

 “Worried about vulnerability to the Coronavirus? Why not boost your immune 

system with a shot of #NutraBurstLiquidVitamins. Ol’ time people seh... “betta 

to be safe dan sorry.” Text accompanied an image of a bottle of Nutra Burst. 

 “Stay COVID-19 Free# Nutraburst clicklinkinbio” 
Some examples of earnings claims made by your business opportunity participants or 

representatives include: 

 A video titled “MAKE MONEY DURING THE QUARANTINE WITH TOTAL 

LIFE CHANGES,” with the statement “I’m providing y’all with the opportunity 

to make money from home, as I am. I’m providing y’all with the opportunity to 

make an extra 100 to 500 dollars a week. Ok?” accompanied by the text “EXTRA 

100-$500 A WEEK” over the image in the video. 

 A video in which the narrator, describing a social media post by a team member 

who previously worked as a DJ, states “We’re in the middle of Corona and... 

there’s no parties there’s no events so he has nothing to DJ. So [the DJ] says... 

‘I’m out of work for seven days and its day one. And I made $200 in just one 

day! If you’re a go getter and ready to invest in yourself and start your at home 

business ask me how now...’ He’s been in the business a very short period of 

time and look, today alone he made $200!” The narrator, describing a second 

team member’s social media post, “She made $100 yesterday just by following 

the plan.” 

 “You call up family and friends and you say, ‘Hey look. I’ve got this business... 

I need you guys to come on in here and do this, because we’re laid off, we’re 

quarantined, we can’t go anywhere, we might as well make some money 

online!’... 50 people, $20 per product sold. That’s $1,000. Ok?... Don’t you want 

to do that? When you sitting around and not making anything? This is some good 

money. Very good money... That is your immune system boosting food that 

everyone needs right now, because of this COVID-19... Why not do this? 

Because you’re either going to sit at home quarantined and do nothing or you’re 

going to sit at home quarantined and get on that phone or your laptop or whatever 

you got at home to be online with and make you some money. I would think 

that’s a pretty good deal, especially when you getting that quick fast money such 

as TLC is paying you. And that’s not including the other three [ways to make 

money in TLC], I just showed you the main two.” 

It is unlawful under the FTC Act, 15 U.S.C. § 41 et seq., to advertise that a product can 

prevent, treat, or cure human disease unless you possess competent and reliable scientific 

evidence, including, when appropriate, well-controlled human clinical studies, substantiating that 

the claims are true at the time they are made. For COVID-19, no such study is currently known 

to exist for the products identified above. Thus, any coronavirus-related prevention or treatment 

claims regarding such products are not supported by competent and reliable scientific evidence. 

You must immediately cease making all such claims. 

Additionally, representations about a business opportunity, including earnings claims, 

violate Section 5 of the FTC Act, 15 U.S.C. § 41 et seq., if they are false, misleading, or 

unsubstantiated and material to consumers. Express and implied earnings claims must be truthful 

and non-misleading to avoid being deceptive, which means that claims about the potential to 

achieve a wealthy lifestyle, career-level income, or significant income are false or misleading if 

business opportunity participants generally do not achieve such results. Even truthful 

testimonials from participants who do earn significant income or more will likely be misleading 

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unless the advertising also makes clear the amount earned or lost by most participants. Your 

business opportunity participants and representatives must immediately cease making all express 

and implied earnings claims that would be false or misleading to current or prospective 

participants. 

You are responsible for the claims of your business opportunity participants and 

representatives. As the FTC stated in the January 2019 Business Guidance Concerning MultiLevel Marketing, the compensation structure of a Multi-Level Marketing entity (“MLM”) may 

create incentives for its participants to make certain representations to current or prospective 

participants. “As a consequence, an MLM should (i) direct its participants not to make false, 

misleading, or unsubstantiated representations and (ii) monitor its participants so they don’t 

make false, misleading, or unsubstantiated representations.” 

You are advised to review all claims relating to your products and business opportunity 

and immediately cease, and require your business opportunity participants and representatives to 

cease, making claims that are not supported by the evidence or substantiation described above. 

Within 48 hours, please send reply via email to COVID-19-Task-Force@ftc.gov 

describing the specific actions you have taken to address the FTC’s concerns. If you have any 

questions regarding compliance with the FTC Act, please contact us at COVID-19-TaskForce@ftc.gov. 

 Sincerely,

 Federal Trade Commission Staff 

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