152 3269

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Edith Ramirez, Chairwoman

Maureen K. Ohlhausen

Terrell McSweeny

________________________________________________

In the Matter of

ABS CONSUMER PRODUCTS, LLC, a limited

liability company, d/b/a EDEN

BODYWORKS DOCKET NO.

________________________________________________

COMPLAINT

The Federal Trade Commission, having reason to believe that ABS Consumer Products, 

LLC, a limited liability company, has violated the provisions of the Federal Trade Commission 

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

1. Respondent ABS Consumer Products, LLC, also doing business as EDEN BodyWorks, is

a limited liability company with its principal office or place of business at 3634 Park Avenue, 

Memphis, Tennessee 38111.

2. Respondent has advertised, labeled, offered for sale, sold, and distributed products to 

consumers, including Coconut Shea All Natural Curl Defining Cream, Coconut Shea All Natural 

Leave In Conditioner, Coconut Shea Styling Elixir, Jojoba Monoi Moisturizing Shampoo, and 

Jojoba Monoi Revitalizing Conditioner.

3. The acts and practices of Respondent alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act.

4. Respondent advertises the above products on the Internet. They retail for $8.47 to $8.99.

5. Respondent has disseminated or has caused to be disseminated advertisements for

Coconut Shea All Natural Curl Defining Cream, Coconut Shea All Natural Leave In 

Conditioner, Coconut Shea Styling Elixir, Jojoba Monoi Moisturizing Shampoo, and Jojoba 

Monoi Revitalizing Conditioner, including but not necessarily limited to the attached Exhibits AC. These materials contain the following statements:
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Coconut Shea All Natural Curl Defining Cream

Discover EDEN for yourself. EDEN BodyWorks Coconut Shea All Natural Curl 

Defining Cream is a humidity-resistant formulation designed to refine and separate curls 

and waves.

(Exhibit A, Internet webpages www.walmart.com/ip/EDEN-BodyWorksCoconut-Shea-All-Natural-Curl-Defining-Cream (April and May 2015))

Coconut Shea All Natural Leave In Conditioner

Discover EDEN for yourself. EDEN BodyWorks Shea All Natural Leave In Conditioner 

is a daily conditioning treatment formulated with one of nature’s best moisturizers, 

coconut oil, to penetrate and revitalize tresses. It’s blended with shea butter to seal in 

moisture.

(Exhibit B, Internet webpage www.walmart.com/ip/EDEN-BodyWorks-CoconutShea-All-Natural-Leave-In-Conditioner (May 2015))

Coconut Shea

All Natural Styling Elexir

Jojoba Monoi 

All Natural Shampoo

Jojoba Monoi 

All Natural Conditioner

(Exhibit C, product labels displayed on Internet webpages at

www.edenbodyworks.com (May 2015))

Count I

False Claim

6. In connection with the advertising, labeling, promotion, offering for sale, or sale of 

Coconut Shea All Natural Curl Defining Cream, Coconut Shea All Natural Leave In 

Conditioner, Coconut Shea Styling Elixir, Jojoba Monoi Moisturizing Shampoo, and Jojoba 

Monoi Revitalizing Conditioner, Respondent has represented, directly or indirectly, expressly or 

by implication, including through the name of the first two products, that these products are “all 

natural.”
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7. In fact, the above products are not “all natural” because they contain at least one synthetic 

ingredient. Coconut Shea All Natural Curl Defining Cream contains the synthetic ingredient 

Polyquaternium-7. Coconut Shea All Natural Leave In Conditioner contains the synthetic 

ingredients Polyquaternium-7 and Polyquaternium-37. Coconut Shea Styling Elixir contains the 

synthetic ingredients Polyquaternium-37, Polyquaternium-11, Phenoxyethanol, and Caprylyl 

Glycol. Jojoba Monoi Moisturizing Shampoo and Jojoba Monoi Revitalizing Conditioner 

contain the synthetic ingredients Phenoxyethanol and Caprylyl Glycol. Therefore, the “all 

natural” representation set forth in Paragraph 6 is false or misleading.

Violations of Section 5

8. The acts and practices of Respondent as alleged in this complaint constitute unfair or 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal 

Trade Commission Act.

THEREFORE, the Federal Trade Commission this _______ day of _______, 2016, has 

issued this Complaint against Respondent.

By the Commission.

Donald S. Clark

Secretary

SEAL: