1 

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

__________________________________________ 

 ) 

FEDERAL TRADE COMMISSION, ) 

) Case No. 

Plaintiff, ) 

 ) 

v. ) COMPLAINT FOR PERMANENT

) INJUNCTION AND OTHER

NATURECITY, LLC, ) EQUITABLE RELIEF

a Florida limited liability company, ) 

 ) 

CARL PRADELLI, individually and as an owner ) 

and officer of NATURECITY, LLC, and ) 

 ) 

BETH PRADELLI, individually and as an owner ) 

and officer of NATURECITY, LLC, ) 

 ) 

Defendants. ) 

__________________________________________) 

Plaintiff, Federal Trade Commission (“FTC” or “Commission”), 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), to obtain 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, in connection with the advertising, marketing, 

distribution, and sale of products purporting to improve cholesterol and triglycerides, relieve 

chronic pain, and mitigate or treat various diseases and health conditions, including ulcerative 

colitis, diabetes, and acid reflux. 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 1 of 31
2 

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C §§ 1331, 1337(a), 

and 1345. 

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

enforces Section 12 of the FTC Act, 15 U.S.C. § 52, which prohibits false advertisements for 

food, drugs, devices, services, or cosmetics in or affecting commerce.

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

attorneys, to enjoin violations of the FTC Act and to secure such equitable relief as may be 

appropriate in each case, including rescission or reformation of contracts, restitution, the refund 

of monies paid, and the disgorgement of ill-gotten monies. 15 U.S.C. § 53(b). 

DEFENDANTS

6. Defendant NatureCity, LLC is a Florida limited liability corporation with its 

principal place of business located at 990 S. Rogers Circle, Unit 1, Boca Raton, Florida 33487. 

NatureCity transacts or has transacted business in this District and throughout the United States. 

At all times material to this Complaint, acting alone or in concert with others, NatureCity has 

advertised, marketed, distributed, or sold TrueAloe and AloeCran to consumers throughout the 

United States.

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 2 of 31
3 

7. Defendant Carl Pradelli is the majority owner, Chief Executive Officer, and 

President of NatureCity. At all times material to this Complaint, acting alone or in concert with 

others, he has formulated, directed, controlled, had authority to control, or participated in the acts 

and practices set forth in this Complaint. For example, Carl Pradelli maintains creative control 

over the company’s advertising and evaluates the results of such advertising. He has held this 

responsibility since at least August 2014. At times, he personally responds to complaint letters 

from NatureCity customers. Defendant Carl Pradelli 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. 

8. Defendant Beth Pradelli is a minority owner, Senior Vice President, and General 

Counsel of NatureCity. At all times material to this Complaint, acting alone or in concert with 

others, she has formulated, directed, controlled, had authority to control, or participated in the 

acts and practices set forth in this Complaint. Beth Pradelli is responsible for reviewing the 

company’s various marketing efforts and has done so since at least August 2014. In addition, 

she personally responded to complaints filed about NatureCity with the Washington Attorney 

General’s Office and the Better Business Bureau. Defendant Beth Pradelli 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. 

COMMERCE

9. 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. 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 3 of 31
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DEFENDANTS’ BUSINESS PRACTICES

10. From May 2002 to the present, Defendants have advertised, marketed, distributed, 

or sold a variety of health-related products, including, but not limited to, TrueAloe and 

AloeCran. 

11. TrueAloe consists of processed Aloe vera and gelatin with a daily serving size of 

two capsules. Defendants sell bottles of 120 TrueAloe capsules for $24.97 each, or $18.73 for 

members of Defendants’ club, plus shipping. 

12. AloeCran is a powdered drink mix consisting of processed Aloe vera, cranberry 

extract, soluble dietary fiber, and other ingredients with a daily serving size of one 6.7 gram 

scoop mixed with water. Defendants sell containers for $29.97 each, or $22.48 for members of 

Defendants’ club, plus shipping. 

13. Defendants have advertised TrueAloe and AloeCran primarily through direct mail 

brochures to consumers in the United States. Defendants also advertise and offer their products 

for sale on their website, www.naturecity.com, through Amazon.com, and on websites 

maintained by other sellers of health-related products. 

14. To induce consumers to purchase TrueAloe and AloeCran, Defendants have 

disseminated or caused to be disseminated advertisements and promotional materials, including, 

but not limited to, the attached Exhibits A through E. These advertisements contain the 

following statements and depictions, among others: 

A. True Aloe direct mail brochure TA59U4, disseminated from October 2014 

to September 2017, with a circulation of over 5.5 million (Exhibit A): 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 4 of 31
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[Exhibit A - 1] 

* * * 

When you’re in pain, polysaccharides send an instant message to 

your NK [“Natural Killer”] cells telling them to destroy what is 

hurting you and put your body back to normal. One teeny capsule 

of TrueAloe floods your body with polysaccharide “Agents of 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 5 of 31

S P E C I A L H E A L T H E D I T I O N N~n,reCity' ··<j,~ 

PAIN SAYS 

GOODBYE 

WHEN YOU 

SAY ALOE! 

Modern science is now rovin 

what these historical leaders 

knew about this legendary plant •.• 

Mahatma lbmlhi 

used It to stay 

atlVe. .• 

Christopher Columbus 

used It to keep him alld 

his crew healthy. •• 

Queen Cleopatra 

said it was her 

beallty secret.-

You'll be amazed to learn 

how it can help your ••• 

• Joint and Muscle Pain 

• Stomach & Elimination Problems 

• Blood Sugar Control & Kidney Stones 

• Cholesterol and Triglycerides 

• Skin Look Younger & Much More! 
6 

Life”...much more than most other Aloe products. Your relief is 

fast...and lasting...as long as you stick with TrueAloe! That’s 

why TrueAloe is so effective in soothing joint and muscle pain... 

[Exhibit A - 6] 

* * * 

TrueAloe contains 10 natural pain and inflammation 

stoppers...with zero side-effects. 

[Exhibit A - 8] 

* * * 

[Exhibit A - 9] 

* * * 

TrueAloe soothes and protects your gut just like your Mom’s 

Aloe healed burns and cuts!

 Plus, the TrueAloe sugar molecules decrease the amount of 

burning acid in your stomach. 

Clinical studies demonstrate Aloe’s power to fix your digestive 

problems.

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 6 of 31

"My husband couldn't get relief until TrueAloe" ~-~ 

"Seveml yems ogo I fell ond crocked my 

back. I had pain all the time. Since I have 

been taking TrueAloe it has quit hurting and 

I take it all the time now. I can't do without 

it! My husband also had pain in his shoulder 

and couldn'l gel any relier unlil I1e slarled Laking TrueAloe. We 

recommend your products highly." 

- Nelle W., Cleveland, TN 

"I was able to quit taking my 

acid reflux medication!" 

"Since Laking TrueAloe, I was able Lo quil 

taking my medication for acid reflux - no more 

problems with that - and have also had a 

noticeable improvement in my blood sugar. I 

have been able to cut my medications in half, 

and am hoping to do without altogether." 

- Mary B., Dresden, OH 
7 

 In a clinical human study, leading scientist Dr. Jeffrey Bland 

from the Linus Pauling Institute found that Aloe vera helps your 

gastrointestinal function 4 ways: 

 1. Makes your digestion easier without causing diarrhea (food 

moves faster, gunk doesn’t stay in your colon, constipation is 

gone!)

 2. Normalizes your pH and balances acid levels in your gut 

(nature’s perfect antacid)

 3. Reduces damaging and painful yeast (boosting your natural 

immunity)

 4. Promotes “good” bacteria and gets ride of “bad” bacteria 

(and probiotics work much better with Aloe!). 

[Exhibit A - 10] 

* * * 

More human studies with Aloe vera were conducted. The 

results were amazing.

 In a randomized, double-blind, placebo-controlled trial, 44 

people suffering from ulcerative colitis (a type of irritable bowel) 

were given Aloe vera or a placebo....in just 4 weeks 47% of the 

lucky folks taking Aloe had a complete remission or 

improvement in their condition...with NO SIDE EFFECTS. 

[Exhibit A - 10] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 7 of 31
8 

[Exhibit A - 11] 

* * * 

 Aloe vera’s power was shown once again in Russia. Ulcer 

patients were given Aloe vera. The researchers found that Aloe 

was just as effective as a commonly used anti-ulcer drug (a proton 

pump inhibitor) with one major difference... 

No toxic side effects!

 Take your pick: A proton pump inhibitor that may give you 

headaches, diarrhea, vomiting, gas, nausea, dizziness, fatigue, 

constipation, breast development in men, or joint pain...or 

soothing Aloe vera with no reported side effects. No matter how 

much you take. 

[Exhibit A - 10-12] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 8 of 31

"At last! NatureCity is truly the best. I'm 

a customer for life!" 

"At last! After dozans of trials with other products from 

other companies. NatureCity really, really delivers what 

you say you can. You are truly the best! 

I have basal joint pain in my riqht thumb. I teach music 

and play piano professionally. I have much better 

movement - very little stiffness - and although there is 

still some pain it is a very small amount. NOTHING has 

helped me nearly as much. You·~e got a customer for I ife''' 

- Russell W., W Henrietta, NY 

"I won't be without it again!" 

'I take T rueAloe for my joint pain. I followed lhe initial dosage of 8 

capsules a day and now take 4 capsules a day. It has totally taken 

away the joint pains in my hands. Once I ran out and the pain returned. 

I won't be without it againW 

Valerie P., Honolulu, HI 

"TrueAloe is the only 

product that works for me!" 

"I started using TrueAloe because of the pain in 

my neck, shoulders, feet and legs. Your product 

is the only one that really works for me. I know, 

because I have tried them all. I'm 80 years old 

and still work on power motors - my hobby after 

I retired n 1998. Now I'm like the little rabbit. I 

just keep going and going!" 

- Hayden C., Leitchfield, KY 
9 

Data confirms Aloe vera helps normalize blood sugar and 

triglyceride levels. 

[Exhibit A - 14] 

* * * 

[Exhibit A - 14] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 9 of 31

"Thanks for a product that works!" 

•My doctor said I needed hip surgery in my 

right hip because nothing could .stop the pain . 

I started taking TrueAloe and mest of the pa1n 

was gone in 2 weeks. My doctor said to keep 

doing what l'ni doing. Thanks for a product that 

worksl" 

- Delbert C., Moun<:ts, OK. 

intake of Aloe vera helped reduce 

level~ or fo~ti rip. blood ~u!'.!ar a 1Jd 

glycawcf hemoglobin 

Data confirms Aloe vera 

helps normalize blood sugar 

and biglyceride levels. 

A douhl e0bli nd smdy of 78 people, 

puhlished in the scientific journal, 

Phrtomedici11e. revealed dramatic. 

and exciting results: 

After si, weel,s of taJ<ing Aloe 

daily, the avera~e blood su!lar level 

of the partidpants in tile test group 

declined 43% anti triglyceride levels 

als,:} decreased 44o,,;). 

The participants who did not 

take the Aloe vcm had an~ 

blood su1,1ar incrense of'.!. 4% and an 

avera!!e increase in blood triglyceride 

lt<veh of 8. 4%. 

And a recent stutlv conduded in 

foxas as rerorted by Dr. Om1hof 

rl:'vealetl these exciting results: 

Type II diabetics with elevated 

levels or blood su(?.u·. insulin 

and tri11lycerill~~ \~ern given a 

cunce1;;1:alt<d ,\lo~ bt'v.;;.age tu take 

every day for eight weeks. 

Aller eight "'iOCks, 80% oJ those. 

drinJ;ing Alo0 hat! no.nnal lcvcls of 

blood sug;ir. in,uli11 ~ntl tl'iglyc"1id1,~. 

... :\"OR.MAL LEVELS' 

Aloe worxed even when blood 

sugar medicine didn't! 

At Vl11hi(Jol f'vkdical lltiivcr,;;il.v. 

Banp_kok, l'C~carcher~ condoctca' 

a triil on paricnts who were 

unresponsive to glibenclamide, .u1 

anti-diabetic medication. 

Those pati cnt~ who received only 

the glibenclamick still suffered from 

the same· high fasting blood glucose 

lt;vd s, high 1.ri gly<;<'-l'idc I cvd~ and 

dangerous chol estcrol levels. 

Those Who received A 1 oc saw a 

48% decrease in bl noo sus.tar levels 

and a _52°,;) decrea5e in tri¥,h:cerjdes~ 

5 plant sterol compounds give 

Aloe its natural atiility to help 

control your blood sugar levels. 

ln .luly 2006, 11 team ,)t Japanese 

researchers published a srudy in 

Rinlogic:ttl & Pliarmllceuticlll 

Bulletin. Thev had suceessfullv 

identified fiv~ phytosteml · 

compounds that heir explain Aloe's 

extraordinary abili'ty to bala.nce your 

hlood sugar safely and effectively. 

In foct. phytostemls are now being 

ndtled to the, foods you eat to help 

lower cholesterol I 

In addition to the 5 plant stcrols, 

Aloe's Jtolysaccha,ri1ks 

delivrr the knock-out punch to 

tle,idly ouj-of-r.oulrul blood s11gi1r! 
10 

[Exhibit A - 15] 

* * * 

Aloe vera may help normalize your cholesterol and protect 

against arterial plaque. 

[Exhibit A - 16] 

* * * 

[Exhibit A - 18] 

* * * 

...for 56 cents a day you’ll “finally” help your body: 

• reduce joint and muscle pain 

• put out the inflammation fire

• restore youthful movement & freedom 

• balance your blood sugar & triglyceride levels 

• normalize dangerous cholesterol levels 

• stop indigestion and burning gut acid 

• get rid of embarrassing gas and bloating 

• get relief from constipation 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 10 of 31

Not a single side-effect. .. or Jteart 

attack! .. after 5 years taking Aloe! 

i\t the end of his landrnark 5 year study of /\k,c vcra, x1-OM Or, 

Dr. Agl)rwal remarked with amazement that: tiJ~ '', .. the mc,l1 interel1ing aspect of tlte l1udy wtts . 

tltat ,w umvautetl .~ide-eflect was noted. tmd all -:5, ::.. 

tlte Jive tlwu.',and patient'/ are .wirviviug to date." ~I?,- Hf:f>-V~ 

"Amazing relief from 

pain and stiffness!' 

"I have pain in my knee and pain 

and stiffness in my neck and 

shoulders and, recently, my right 

foot. Since taking TrueAloe, I have 

had amazing relief from pain and 

stiffness. I no longer take over-thecounter or prescription drugs, since 

I try to avoid their side-effects to mycliver and kidneys.;; 

- Miriam P,, Philadelphia, PA 
11 

• maintain healthy, normal blood pressure 

[Exhibit A - 22-23] 

* * * 

For only 56 cents a day, 4 teeny easy-to-swallow capsules: 

• ease pain and inflammation with 10 natural pain-stoppers... 

• protect your heart and body from deadly diabetes with 5 

natural phytosterols... 

[Exhibit A - 23] 

* * * 

“My wife and I love TrueAloe”

“I have struggled with constipation, pain & inflammation and 

diabetes for 20 years. Since using TrueAloe, I no longer have 

constipation, my pain has decreased at least 75%, my inflammation 

is 80% less, and my blood sugar levels are better. My wife and I 

love your TrueAloe product. It gives us more energy and our 

digestion and constipation improved a lot.” 

-- Ralph B., Pacoima, CA 

[Exhibit A - 26] 

* * * 

You’ll discover...[h]ow TrueAloe works to improve the absorption 

rate of vitamin C by 204% and vitamin E by 269%. 

[Exhibit A - 26] 

 B. TrueAloe direct mail brochure TA62M6, disseminated 

September 2016 to October 2016 (Exhibit B): 

 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 11 of 31
12 

[Exhibit B - 1] 

* * * 

New Scientific Studies, published between 2013 and 2016, help 

confirm the Aloe vera legend is true.

That’s because Science finally woke up to Aloe vera’s ability 

to help... 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 12 of 31

NatureCity ••*~ SPECIAL HEALTH EDITION 

Does Your Pain Relief 

Supplement Pass the 

Longevity Test? 

Imagine waking up every morning and 

feeling refreshed from a good night's sleep 

that wasn't broken up by pain ... 

... or raking leaves in your yard and not 

worrying about being punished with excruciating 

discomfort in your joints and muscles ... 

••• or eating a meal that doesn't repeat 

on you ... 

•.• or being regular, finally ... 

... or just having more energy ... 

and simply feeling great. 

These are some of the round-the-clock 

benefits our clients count on, and is why 

they take our product every single day ... 

. . . some for the past 

12 years (and counting)! 

If you're ready for real relief ... - with no reported side effects .. . 

please discover more inside! 
13 

• Soothe aches and pains in your joints and muscles 

• Battle embarrassing gas, indigestion and stomach upsets 

• Achieve healthier blood sugar, cholesterol and blood pressure 

[Exhibit B - 3] 

* * * 

TrueAloe helps you say goodbye to joint and muscle aches and 

pains.

The published results of exciting human studies reveal that not 

only can Aloe vera help soothe and calm joint and muscle aches and 

pains, these other outstanding and long-term health benefits could 

finally be yours... 

[Exhibit B - 10] 

* * * 

This just in: Aloe helps manage blood sugar levels! 

[Exhibit B - 12] 

* * * 

Another recent study, published in the June 2016 issue of 

Nutrients, confirms Aloe as a beacon of blood sugar hope. 

[Exhibit B - 13] 

* * * 

 But not only can TrueAloe help you keep you[r] blood sugar 

levels where you want them, it’s one of nature’s most effective heart 

health protectors. 

[Exhibit B - 14] 

* * * 

New study reveals Aloe vera battles the 4 biggest threats to your 

heart.

[Exhibit B - 15] 

* * * 

Aloe shown to boost absorption of Vitamin C by 304% and 

Vitamin E by 369% 

[Exhibit B - 22] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 13 of 31
14 

[Exhibit B - 28] 

* * * 

[Exhibit B - 32] 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 14 of 31

"I have real 

PROOF TrueAloe 

works for me!" 

"Two 

some weeks reason. ago, I forgot 

for ~ 

to indude TrueAloe ~- ,, 

capsules. My left _ '\, 

knee and thumbs q 

began to bolher me. 

By the end of the week - \Mthout 

TrueAloe - I was nearly unable to 

walk and almost fell twice. 

"I then realizea I had forgotten 

to indude TrueAloe and knew 

immediately why the pain haa 

returned. I've been back on 

TrueAloe for 3 days now and the 

pail\ is going away. My walking is 

almost back to normal. I know now 

without a doubt that the TrueAloe 

works for me.'' 

- Beverly Et, Biloxi, MS 

Ready to get rid of pain? 

Starting today, how many YEARS 

will it WORK for you? 

Well ••• 

Dudley M. and his wife have h.ud relief from pain for 

the past 12 years, "My wife 1ad a knee replacement anc jont 

pair set in. Your p-oduct knocks OLlt mast o= the inflamma:ion so 

!;hF! r:~, tP.t r3ro1 Jnci ShP. slnf.pP.:i t;1kin!) it r:nr.P. anc1 hP.r kn PP. 

star:ed swellinc. Give it a chaice!" 

Marilyn W. has had relief from joint pain and interrupted sleep for- the past 11 year-s, 'It made 9 difference 

with m~ joint pain! I was atle :o sleep through the night wilhout as 

much pain aid rn~ joints warEn't as tender and sore Y11hen I move 

my hands. I stopped taking it on:e - and everything started hurting again." 
15 

 C. TrueAloe direct mail brochure TA68W7, disseminated from May 2017 to 

August 2017 (Exhibit C): 

[Exhibit C - 1] 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 15 of 31

SPECIAL HEALTH EDITION NarureCiiy • •*~ 

Discovered over 3,500 years ago, 

droves of Americans are experiencing 

a lasting Health Rebirth with 

this Su erfood nicknamed the ... 

''Silent Healer'' 

• Relief from joint aches, 

pain and inflammation 

• Sooth.ing gut· r~i1ef - with no· side' effects . . . • HealthiJ(b~~_bd ~ugar ._ 

• More balanced cholesterol 

and CRP levels 

• Glowing, youthful skin 

INSIDE: Superfood Outrage! Big retailers 

selling phony products! How to spot a fake. 
16 

* * * 

[Exhibit C - 32] 

 D. AloeCran direct mail brochure AC55M5, disseminated from 

July 2015 to November 2016 (Exhibit D): 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 16 of 31

Forget Zantac® 

Forget Prilosec OTC® 

This Su erfood delivers 

continuous, soothing gut relief 

with NO side effects! 

Clinically tested and confirmed! 

"I first started taking it for 

joint pain and then one night 

I realized, 'HEY! I don't have 

reflux anymore!"' 

"This is a multiple benefit 

product. It helps with my 

joint discomfort, and it's 

good for my overall healU, 

- BJrgi! .W.:, I and managing my blood 

CelebntUng h,e! ~O-fe~i { sl!gar. I would recommend it 

Anniversary\!~itt!,•f \ ~ ;.!'nyone, It's natural and a 

" f good product." ~- ) -;,· . .,_-' - Barbara B., 

"' 

~ 

;~! I , Celebrating her 6-year 

Anniversary with u&! 

I .,/¥ . 

'I ~ ! ~t.ike'it'mostly for aches 

1 • and pains - more in my rigt,t 

shoulder. It's great. It helps 

·with digestion, too! 

- Russ R. 

Celebrating his 9-year 

Anniversary with us! 

"If it helps outside your 

body, it can help inside. I 

tried another brand - biggest 

mistake I ever made! That's 

when I called NatureCity and 

reordered their product." 

- Edda M. 

Celebrating her 6-year 

Anniversary with us! 

~ DETAILS INSIDE! 

TURN TO PAGE 2 •.. 
17 

[Exhibit D - 1] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 17 of 31

NATURAL FORMULAS FOR MAXIMUM RESULTS 

Why Have Americans 

Happily Enjoyed 

32 Million Glasses 

of This Drink? 

Here are a few of the reasons .... 

a ••r have more 

ene ro,, ! ,t ,-,. 

- John I •. Frns1h11rg., MD 

11 ".:\ly blood sugar 

is under control" - Lc~tor L.. Sooralllcnto. CA 

Now it's 

EASIER Than Ever 

for YOU to Try! 

Look Inside ... 

H "My cholesterol 

is now normal" - T~rrx C., Austin, TX 

Tum to page 2 to 

discover more ... 
18 

[Exhibit D - 3] 

* * * 

The scientists were surprised to discover Aloe vera boosted absorption 

of vitamin E by 269% and vitamin C by 204%! 

[Exhibit D - 15] 

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 18 of 31

Drinking to Your Health 

Never Tasted So Good ... 

Now You can do it 

completely Guilt Free! 

If You Too Want to 

Do Better than "Just Getting By" ... 

04'ar li'rrcnd. 

The story you ju5t read come5 

fi-om one of our dear clients from 

Iowa. a woman named Virginia. 

She'sjnM nne nfmany, ma.ny 

thm.,sands who gave the AloeCrnn·•~ 

drink a chance over the last 13 years 

and a re now thril kd that they did. 

Jo foc.1. to date our dients have 

drunk over 32 million glasses of 

;\JoeCnm" '. -· 

The truth is ten ve~rs af!.o 

AloeCran" was a ni.,tritiou~ refreshing drink that l can proudly say was 

ahead of its time. 

U' you read om, or our brochures 

bad, then, vou w(iuld have diswvered that AioeCran"' already t'eatured what health experts are touting 

for you Looay sud, as .. 

··uo suuar'· .. :'no anilicial 1wee1-

enen( ... -=~·o pl"eservatives·~ .. . ·'nn 

GMOs" ... '·gluten free·• .. :'all naturar' .. . '"uo fo.C' ... c:lov.' cttlorit( ... ,:fi_ 

be.- enriched'' ... ·'whole food" 

ingredients ... and using the uatura.1 

;wccLcncrs "stcvia and luo han'' 

Even beuer is whal you do ge1 

in each >!lass of ;\JoeCran'" .. which 

is II trea;ure trow of v11luable, health 

benefits that help m .. 

• Relieve occasional heanbum, 

acid re1lu11. and constipation 

• Improve overall digestion 

• ras.:: gM and bloating 

• 8oo~t absorption of key viti,mins 

• SoNhc the stomach lining and 

i rritabl c bowels 

• l'romote '·good bacteria·• in 

intestines 

• Support colon health by increasing stool tran si I ti me, volum c and 

moisrurc 

• Normalize cholesterol aud Lli• 

g1) .;,c·ri de 1cvcfa 

• 8oost ·'gnod" HDL cholesterol 

• Pr0tcct "bad" LDL chol csrcrol 

from oxidation damage 

• Improve C-reac.tive, protein 

(CRP), a llleasure uf ioflmmnation 

• Suppo1t healthy blood sugar 

levels 

• Pro1uole healihy insuliu levels 

• Boost urinary tract health 

• Suppon prosl.1te health in men 

• Reduce the appearance of fm:ial 

3 
19 

This was shown in a study published in Alimentary Pharmacology and 

Therapeutics of people with mild to moderate ulcerative colitis (a type 

of irritable bowels). In just four weeks, 47% of participants taking 

Aloe vera twice a day experienced a complete remission or an 

improvement in symptoms.

[Exhibit D - 16] 

* * * 

“my doctor is amazed how my cholesterol and blood sugar have 

improved” 

- William T., Mitchell, IN

“tests show I’m controlling my blood sugar better” 

- Patricia M., Ballston Spa, NY 

“my acid reflux is gone”

- Erik O., Olathe, KS 

[Exhibit D - 32] 

E. AloeCran direct mail brochure AC57B6, disseminated from November 

2016 to February 2018 (Exhibit E):

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 19 of 31
20 

[Exhibit E - 19]

* * * 

More important are the components of your cholesterol score – you 

want to keep LDL cholesterol and triglycerides down, while boosting 

the “good” HDL cholesterol. 

The ingredients in AloeCran have been shown to help on all counts. 

One interesting study involving ACTIValoe was conducted by 

researchers at the University of California Davis.

The participants in this study had relatively normal cholesterol of 206 

mg/dll, on average. 

After eight weeks of using ACTIValoe, their cholesterol dropped by 

an impressive 20 points to a healthier 186 mg/dll. 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 20 of 31

"I can't believe how 

much AloeCran helped" 

Tm a diabetic and also was diagnosed with an acid 

reflux condition. I liked the idea of no sugar in the 

AloeCran , so I tried it. I'm happy lo report lots of progress thanks to 

AloeCran . My blood sugar is under control a11d my doctor took me 

off my medication. I have an overall feeling of good health at 75~'" 

- Louis S., Seattle, WA 

"No more discomfort and 

no side effects!" "I had severe acid reflux and could not eat rny favorite foods without 

digestive problems. I did not want to take acid blockers with all the side 

effects 'Which I heard could cause long-term damage after a while . 

I now drink a glass of AloeCran every morning and an AloeCran 

'cocktail" before dinner. It tastes delicious and I can now eat and drink 

anything I like with no problems, I'm happy to be getting my fiber also 

with no chalky taste too.I canr1ot lhank you enough for such a wonderful 

pmducl." 

- Maureen S., Las Vegas, NV 

"I Feel So Much Better Without the 

Prescription Medication" 

11:~r"'ii~ "For years I have had many health problems- high blood 

pressure, flu id retention , gastric reflux, hypoglycemia , 

and osteoporosis. I took many prescription medications. 

After two years of drinking AloeCran juice and taking 

some of your other products, I feel so much better and 

don't need tne prescription medication. All thanks to your 

wonderful products.' 

- Myra w., Greenville, SC 
21 

Even better, most of this improvement was in the “bad” LDL 

cholesterol which dropped by 17 points – from 135 to 118. 

[Exhibit E - 19-20] 

* * * 

University of Scranton researchers found that over the course of one 

month, drinking cranberry juice three times a day increased “good” 

HDL cholesterol by 10%. 

How significant is this? Lead researcher Dr. Joe Vinson noted that a 

10% increase in “good” cholesterol has been shown to help slash risk 

of heart disease by an amazing 40%! 

[Exhibit E - 20]

* * * 

[Exhibit E - 20]

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 21 of 31

"Your Product has been a 

Miracle for Me!" 

Tm 60 years old and been struggling with 

high cholesterol, triglycerides and high blood 

pressure for years. Acid reflux has been a problem also. I thought my situation was hopeless. 

After using AloeCran for 30 days. I tested my cholesterol 

and my HDL and LDL were in normal limits. as was my blood 

pressure. My acid reflux isn't as bad either. My doctor said, 

"Whatever you are doing, keep it up Your product has been 

a miracle for me1 • 

- Stan A., Lincoln, NE 
22 

[Exhibit E - 21]

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 22 of 31

Other research. puoli shed in 

the Juumul of'Japwirt,w, Society.for 

the Sr11dy f/f0hes1ty. showed con-

;,uming larger amnunts of Fiher,or•-'.?. 

may produce even better results. 

In th is study, participants drank 

Wg of~ioersol''-2 with each meal. 

And after three months, the results 

were pretty dramatic - a 36% reduction in ''bad" VLOL cholesterol and 

a 30'% drop in triglyceride levels. 

Plus, these folks had a remark.-

able 20% reduction in visc,eral fat. 

This is the fat that can strangle vital 

organs in the gut and Fiberso["-·-2 

helped melt it away! 

< I 

I AloeCran and Your 

Blood Sugar 

"I'm a diabetic and liked 

the idea of no sugar in 

AloeCran, so I tried it. I'm 

happy to report lots of progress thanks to AloeCran. My 

blood sugar is under control 

and my doctor took me off my 

medication." 

That report come~ li·om 

1.ouis. who live, oul in ScaIllc. 

Washington. And it remind~ me lo 

mention that AlocCran'• is diabetic 

;ate because is sugar-free. 

r.ven better. is how the 

ACTTValoc~ a1id 1%crsor'-'.?. help 

you rnaintai n healthy blood sugar 

ancl insulin levels. 

Aloe vcra'; innate abilitv to 

help control blood :mgar was first 

,hown hv resea.rchers 1n Thaila.nd 

and published in the scientific journal Ph,wmedici,w.. 

They conducted a study in people with VERY high blood sngar. 

"I'll Use AloeCran 

the Rest of My Life" 

"I am a lype 2 diabetic. I've been drink 

ing Aloecran juice for 

two years.. It's hard 

to find something 

like AtoeCr.:in that is 

so refreshing, tasty, 

sugar free and yet healthy and good 

for me. 

I most definitely will use your 

product for the rest of my life. Thanl< 

you for making your AloeCran available to me at an economical price. I 

commend you for a superb product: 

- James 0., Hateiusa, HI 

"Thanks to AloeCran 

my Blood Sugar and 

Cholesterol are Down" 

·Being .:i diabetic, the Aloecran is 

great for me, since it doesn't have 

sugar in it. Even better it's helped 

me regulate my blood sugar. Plus, 

a.I my last visit lo my doctor he 

was amazed at how my eholesterol 

improved! 

AloeCran has a great taste to 

enjoy and is so good fer me! I 

wouldn't be without it. Thanks 

AloeCranr' 

- William T., Mitchell, llil 

"Still Getting E 

Favorable _.:, - Readings , -· 

After 1 Year" 'Prior to using AloeCran. rny blood 

sugar readings were a bit higher than 

I wanted. 

After drinking AloeCran. my blood 

sugar readings have gone down 

and have &tayed in a good area. I 

have been using the AloeCran for a 

year and I am still getting favorable 

readin9s." 

• Herbert B., Wheeling, WV 
23 

[Exhibit E - 22]

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 23 of 31

"I tell you I feel wonderful" 

i 

"I am a diabetic and Since I started taking 

.AloeCran my blood sugar has been under 

control between 96 and 120. This morning 

my blood sugar was perfect at 00. No more messing with needles. I feel very young 

again. I wish I had known about AloeCran 

some 15 ye11.rs ll,go, 

Plus the paUJ. UJ. my legs ts gone. This l£ really 

important to me as I am a well known basketball and 

baseball omoial throt1ghout l,jorthern Calitornia. 

I tell you I feel wonderful!" 

- Lester L., Sacramento, CA 

averaging 2.'\0mg/dl, 

Atrer drinking Aloe vera 

_juice daily for six wock~. the 

group improved dramaric.11lly. 

They·re blood SUBar fell a remarkable 

,11% ro I ,12mgidl, Plus, as a honu ~-

their triglyceride levels fell by 44'!-'• 

SooJ1 thereafter. re,earchers at 

Mahidol Uni v~rsity in Thailand did 

a similar :;rudv. and found near identical resul15 -·a 48'!·• improvemenr in 

hlood ~ugar and a 52~-i·) improvement 

in triglycerides. 

Thi, work showed Aloe vera 

cnn help support blood s1.1gar health. 

But drn~s it \.\:ork onJ} .. in people with 

verv high blood sugar lt,ve.ls') 

fo answer 1hi s question, 

researchers a1 the Universitv of 

California Oavi, did a stud;, of people who had just slightly above nornrnl blood sugar. 

Aller 8 weeks of using 

ACTIValoe*, Sludy parlicipallls 

experienced a significant i111prove111et11 in their blood sugar going 

from I 11 mg/dl 10 I 05 mgi(!I Plu~, 

insulin levels improved by 14%. 

going from 18,6 to 16. 

A, important, three ntherte.st 

marker, of blood sugar heallh 

improved by taking ACT1Valoc". 

This indeed c-ontirms the blood 

suua.r henet,ts of Aloe vera - an<l 

SJl;cifically ACT!Valne''. 

A~ I mentioned, 1%erSol"-2 

helps you in this regard too - ir just 

works a little differently. 

WhileA(TJValoe" worh 

to improve fasting blood sugar, 

Fi hers .. r•·-2 help~ crnlrol the blond 

!.:t.lgar :a.nd ins~1lin spike after you eat 

a meal. 

In foc1. a stud, in Jo11mal of 

Nutriliona/ Foo<l~ showed con;uming Sg of H berSoF-2 reduced the 

rise in hlood sugar I>~ al>out 11•••-

0n to1> of this less insulin wa~ needed, as shown hy a 5% im1>mvement 

in iusulin levds. 

Nnw on to some other AloeCnmr" 

benefits ... 
24 

[Exhibit E - 23]

* * * 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 24 of 31

"AloeCran helps keep my 

blood sugar levels 

in the nonnal range." 

•1 have been drinking 

AloeCran for about 2 

ye~r$ now. I am a type 2 

diabe1ic monitoring my 

blood glucose twice daily. 

I find n much easier to 

keep it within the normal 

mngc where my doc1or w.ints it.' 

- Victor F., R3t.ine, WI 

111 was having tremendous 

problems with a gastro- intestinal disorder ... " 

" ... constant gas. bloating, 

stomach cramps. and 

irregulari1y in bowel 

movement with constipation. I received my shipment of AloeCran and 

started d.-inking it that 

day. First the constipalioo left leaving 

me with a no strain bowel movement 

wilh regularity. 

I don't ~vf':n disr,us,i hloating ;::jnd gas 

wilh my doctor anymore. No need to. _ 

it's GONE. I thank God for AloeCran.--

- Clarence G., Grand Prairie, TX 

I "Uris just never 

occur any 

more!" 

"AloeCran is a product I 

will always use. I believe it is one of the 

best products for urinary tract i11fectioris. 

The. urin?jry trar.t inf~r:tions I 11~ecl to 

have just never occur any more. I ~lso_ 

had problems with constipation and acid 

r~flux :md thP.y have improved unh~li~vably.-

- Joy B., Fort Pierce, FL 

"Irregular and miserable 

for 75 years ... AloeCran 

brought blessed relief" 

"I h~ve had problems all 

my life trying to be regular, 

but with no success. 

People 1hat don't have 1he 

problem du nol undersli:!nd 

how miserable it makes 

you feel. I am 75 and tried 

evarythi119 ... but nothing worked. I ~ot a 

notic~ from ynur r.nmpany and rl~r:,dP.d 

to try AloeCran a11d was rewarded with 

blessed relief. II not only tasted good ... 

but boy does it work: Thank you for 

making n,y life so much better ... 

- Ch3rlottc V., Estill Springs, TN 

"If I Id I ~ "I will be using AloeCran cou on Y from now on" choose one 9 ~ 

drink ... l'd want it "I hact H. pylori inf~<.tions I 

C ,, two times and I was to be Aloe ran treated with medications. 

Since I have been using "Ir I could only hctv~ -ont! lhing tu drink AloeCran I have not had 

to feel refreshed after coming in from another attack. Plus, 

the hot and humid outdoors. I'd want it when I went for my check 

to be AloeCran. up my chuleslerul wt:nl dovi111 34 points. 

It's sugar free, relaxing, refreshing 

and gets me ready to do my chores.'' 

- Jean c., Louisville, KY 

So I will be using AloeCri,n from now 

on. Thank you NatureCity for helpini:, 

me 

- Yvon11e 8., E Templeton, MA 

lrdi·,icm:.I rct.ulh:: -nay ,,.,r·t 
25 

[Exhibit E - 25]

15. Defendants have not conducted any studies showing that TrueAloe, AloeCran, or 

any equivalent products provide the benefits described above, let alone any properly designed, 

human clinical trials of such products. 

16. In many instances, Defendants solicit the testimonials contained in their direct 

mail brochures with a promise to provide compensation, including a free lifetime membership to 

the NatureCity Club (which provides discounted products and free shipping, valued in the 

hundreds of dollars) and up to a year’s supply of the product featured in the testimonial, free of 

charge. One of Defendants’ solicitations requests a photo and tells consumers that they “may be 

the next person featured in one of our mailings across the USA.” Further, Defendants influence 

solicited responses by requesting consumers to “imagine” they are “trying to encourage a friend 

to try” one of the products. Defendants state that they will only provide compensation if the 

testimonial is used in their advertising materials, so consumers are incentivized to provide 

positive details to obtain the offered compensation. Defendants do not disclose anywhere in the 

mail brochures that some consumers providing testimonials have received compensation. 

17. Based on the facts and violations of law alleged in this Complaint, the FTC has 

reason to believe that Defendants are violating or are about to violate laws enforced by the 

Commission because, among other things: Defendants engaged in their unlawful acts and 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 25 of 31

fa "I went from taking 8 drugs 

a ~~~ b~! !:e~!~!m ~ ~!~e~!:liments 

- high blood pressure, diabetes. acid reflex. arthritis, and high cholesterol. Since I have been drinking AloeCran 

I went from taking 8 drugs down to laking 3 drugs and I have 

more energy'" 

- John L., Frostburg, MD 
26 

practices repeatedly over a period of at least four years; any modifications Defendants made to

their advertising occurred only after they were informed of the Commission’s investigation; and 

Defendants remain in the health supplements business and maintain the means, ability, and 

incentive to resume their unlawful conduct. 

VIOLATIONS OF THE FTC ACT

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

or practices in or affecting commerce.”

19. Misrepresentations or deceptive omissions of material fact constitute deceptive 

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

20. 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, TrueAloe and AloeCran are either “foods” or “drugs” as 

defined in Section 15(b) and (c) of the FTC Act, 15 U.S.C. § 55(b), (c). 

Count I

False or Unsubstantiated Claims about TrueAloe

21. In numerous instances in connection with the advertising, marketing, offering for 

sale, or sale of TrueAloe, including through the means described in Paragraphs 13-16, including, 

but not limited to, the statements and depictions contained in the advertisements attached as 

Exhibits A through E, Defendants represent or have represented, directly or indirectly, expressly 

or by implication, that TrueAloe:

A. Reduces joint and muscle pain; 

B. Treats diabetes; 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 26 of 31
27 

C. Relieves acid reflux; 

D. Treats ulcers and ulcerative colitis; 

E. Normalizes unhealthy cholesterol and triglyceride levels; 

F. Increases vitamin absorption, including boosting absorption of vitamin C 

by at least 204% and vitamin E by at least 269%; and

G. Is comparable or superior to conventional medical treatments in: 

1) Reducing joint and muscle pain; 

2) Treating diabetes; 

3) Relieving acid reflux; and 

4) Treating ulcers.

22. The representations set forth in Paragraph 21 are false or misleading, or were not 

substantiated, at the time the representations were made.

23. Therefore, the making of the representations as set forth in Paragraph 21 

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 II 

False or Unsubstantiated Claims about AloeCran 

24. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of AloeCran, including through the means described in Paragraph 13-16, 

including, but not limited to, the statements and depictions contained in the advertisements 

attached as Exhibits A through E, Defendants represent or have represented, directly or 

indirectly, expressly or by implication, that AloeCran: 

A. Treats diabetes; 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 27 of 31
28 

B. Relieves acid reflux;

C. Treats ulcerative colitis;

D. Boosts healthy cholesterol levels;

E. Increases vitamin absorption, including boosting absorption of vitamin C 

by 204% and vitamin E by 269%; and

F. Is comparable or superior to conventional medical treatments in: 

1) Treating diabetes; and 

2) Relieving acid reflux. 

25. The representations set forth in Paragraph 24 are false or misleading, or were not 

substantiated, at the time the representations were made.

26. Therefore, the making of the representations as set forth in Paragraph 24 

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 III 

False Claims about TrueAloe and AloeCran

27. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of TrueAloe and AloeCran, including through the means described in 

Paragraph 13-16, including, but not limited to, the statements and depictions contained in the 

advertisements attached as Exhibits A through E, Defendants represent or have represented, 

directly or indirectly, expressly or by implication, that:

A. TrueAloe is clinically or scientifically proven to: 

1) Reduce joint and muscle pain; 

2) Treat diabetes; 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 28 of 31
29 

3) Relieve acid reflux; and

4) Treat ulcers and ulcerative colitis. 

B. AloeCran is clinically or scientifically proven to: 

1) Treat ulcerative colitis; 

2) Boost healthy cholesterol levels.

28. The representations set forth in Paragraph 27 are false or misleading. Therefore, 

the making of the representations set forth in Paragraph 27 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 IV 

Failure to Disclose Material Connections with Consumer Endorsers

29. In numerous instances in connection with the advertising, marketing, promotion, 

offering for sale, or sale of TrueAloe and AloeCran, including through the means described in 

Paragraphs 13-14, including, but not limited to, the statements and depictions contained in the 

advertisements attached as Exhibits A through E, Defendants represent or have represented, 

directly or indirectly, expressly or by implication, that testimonials in their brochures are from 

consumers describing their experiences with the product. 

30. In numerous instances in which Defendants make the representation set forth in 

Paragraph 29, Defendants fail or have failed to disclose or disclose adequately the circumstances 

under which the testimonials were obtained, including that certain individuals quoted in their

brochures were offered incentives or other compensation for their testimonials about TrueAloe 

and AloeCran including through the means described in Paragraph 16. These facts would be 

material to consumers in evaluating the testimonials in connection with deciding whether to 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 29 of 31
30 

purchase TrueAloe or AloeCran, which Defendants advertise, market, promote, offer for sale, or 

sell. 

31. In light of the representation described in Paragraph 29, Defendants’ failure to 

disclose or disclose adequately the material information as set forth in Paragraph 30 constitutes a 

deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a). 

CONSUMER INJURY

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

injury as a result of Defendants’ violations of the FTC Act. 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

33. 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. 

PRAYER FOR RELIEF

Wherefore, Plaintiff FTC, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), 

and the Court’s own equitable powers, requests that the Court: 

A. Enter a permanent injunction to prevent further violations of the FTC Act by 

Defendants; 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 30 of 31
31 

B. Award such relief as the court finds necessary to redress injuries to consumers

resulting from violations of the FTC Act, including rescission or reformation of contracts, 

restitution, the refund of monies paid, and the disgorgement of ill-gotten monies; and 

C. Award Plaintiff the costs of bringing this action, as well as such other and

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

Respectfully submitted, 

ALDEN F. ABBOTT

General Counsel 

Dated: October 10, 2019

AUDREY AUSTIN, Special Bar No. A5502590

aaustin2@ftc.gov; (312) 960-5606

GUY WARD, Special Bar No. A5502078

gward@ftc.gov; (312) 960-5612

Federal Trade Commission

230 S. Dearborn Street, Suite 3030

Chicago, Illinois 60604

Telephone: (312) 960-5634

Facsimile: (312) 960-5600

Attorneys for Plaintiff 

FEDERAL TRADE COMMISSION 

Case 9:19-cv-81387-XXXX Document 1 Entered on FLSD Docket 10/10/2019 Page 31 of 31