UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

 

June 5, 2020 

Via Electronic Mail

Isagenix International LLC, 

c/o Justin Powell, General Counsel 

155 E. Rivulon Boulevard 

Gilbert, Arizona 85297 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Powell, 

FTC staff has reviewed social media posts made by Isagenix International LLC

(“Isagenix”) 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 Isagenix 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. 

An example of Coronavirus prevention or treatment claims made by your business 

opportunity participants or representatives include:

• “In the fight against COVID-19 – Keep moving every day and eating healthy! 

Isagenix shakes boost your immunity 500%!” 

Some examples of earnings claims made by your business opportunity participants or 

representatives include: 

• “The last 1 1/2 months of this covid-19 pandemic has made me even more 

GRATEFUL.... We have been able to put [our daughter] through 4 years of 

college @ MSU and give her a head start in her next chapter of life with no 

college debt.... It breaks my heart to see families struggling nutritionally and 

financially, especially when we have such an amazing and LIFE CHANGING 

SOLUTION to help them on all fronts. RESIDUAL INCOME IS A GAME 

CHANGER, and if you are just OPEN to listening, it can change your family’s 

life too.” 

• “Will you get a stimulus check? . . . . [W]ould a extra $4,100 change your family 

lifestyle? Well my firm is offering that and more so who is this firm . . . Text 

Isagenix to [5 digit SMS text number].” 
2

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 

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