United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580

Serena Viswanathan

Associate Director

Division of Advertising Practices

December 29, 2021

CEASE AND DESIST DEMAND

VIA EMAIL TO Health@TheDrsWolfson.com and health@naturalheartdoctor.com

Dr. Jack Wolfson, D.O.

Dr. Heather Wolfson, D.C.

The Drs. Wolfson, LLC

10585 N. Tatum Blvd, Suite D-135 

Paradise Valley, AZ 85253

Re: Unsubstantiated claims for Coronavirus prevention and treatment

Dear Drs. Wolfson:

This is to advise you that FTC staff has reviewed your websites at

https://thedrswolfson.com/ and https://naturalheartdoctor.com/ in December 2021. We also 

reviewed your social media websites at https://www.instagram.com/thedrswolfson/, 

https://www.instagram.com/natural_heart_doctor/, https://www.facebook.com/TheDrsWolfson, 

https://www.youtube.com/user/TheDrsWolfson, where you direct consumers to your websites

https://thedrswolfson.com/ and https://naturalheartdoctor.com/ to purchase products, including 

supplements. We have determined that you are unlawfully advertising that certain products treat 

or prevent Coronavirus Disease 2019 (COVID-19).

Some examples of Coronavirus prevention or treatment claims include:

• In an email sent to consumers on August 27, 2021 with the subject line, “3 

Strategies Besides Ivermectin,” you state:

“We are getting tons of emails about ivermectin. Does it work? Is it safe? What other 

options exist?

First, it appears ivermectin works and is safe for most people.

But if you know me, I really don’t like taking out my prescription pad.

So here are 3 things YOU can do without a script to accomplish the same things as 

ivermectin.
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 2

1. Eat plenty of wild seafood and pasture-raised meat. We love this source

[affiliate link to https://www.vitalchoice.com/] for the best seafood and 

meat in the world. Also, get the chemicals out of your food by eating only 

organic. 

2. Get sunshine and get sleep. Sunshine creates vitamin D and THIS may be 

the single best strategy for immune support. Sleep allows your body to 

recover. Make sure you get 8 hours. 

3. Natural supplements will help do the same thing as ivermectin. 

Glutathione, zinc, vitamin A, C and D are all anti-viral and help support 

our body against the daily onslaught of environmental toxins.

We have a package called Immune Basics [link to 

https://shop.thedrswolfson.com/products/immune-basics-bundle, where the Immune 

Basics Bundle, including Super C, Super D, Zinc, Liquid A, and N-Acetyl-Cysteine,

is available for purchase] that contains all the above. And with every purchase, you 

get a FREE bottle of Quercetin by Pure Encapsulations. Quercetin may be the silver 

bullet in the recent pandemic according to this research paper [link to https://journalinflammation.biomedcentral.com/articles/10.1186/s12950-021-00268-6, an article 

titled “Anti-inflammatory potential of Quercetin in COVID-19 treatment” from 

Journal of Inflammation].

Get your Immune Basics bundle here [link to 

https://shop.thedrswolfson.com/products/immune-basics-bundle].

In Health,

Jack Wolfson D.O., FACC

The Natural Heart Doctor.”

• On your website at https://thedrswolfson.com/a-note-on-ivermectin/, you state:

“A Note on Ivermectin...

Updated: August 25, 2021...

We get a ton of questions about ivermectin for the prevention and treatment of 

COVID. Many people ask for a prescription for this pharmaceutical....

Does Ivermectin Work for COVID?

A July 2021 review in the American Journal of Therapeutics was very favorable on 

the use of ivermectin for the prevention and treatment of COVID.
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 3

This table demonstrates an 86% reduction in COVID infection among those who 

received ivermectin versus placebo....

The authors of the above review conclude, ‘The findings indicate with moderate 

certainty that ivermectin treatment in COVID-19 provides a significant survival 

benefit.’...

Conclusion: 

Personally, I do not take ivermectin. If I still worked in a hospital or area with 

rampant sickness, I may change my tune. But I think natural immune support is 

always the answer. Ivermectin is still pharma. I trust nature.

To that end, I take my NAC every day. You can buy the best brand [link to 

https://shop.thedrswolfson.com/products/nac] here. 1 cap 1-2x per day is the standard 

dose. I suggest stocking up on NAC [link to 

https://shop.thedrswolfson.com/products/nac] as the above FDA may limit its use.

I also suggest our Viral Protection Kit [link to 

https://shop.thedrswolfson.com/products/viral-protection-kit, where the Viral 

Protection Kit and Protocol, including Multi Multivitamin, Omega DHA, Daily

Defense, and Gut Flora 30 Billion, is available for purchase] and take the 

components every day. There are many, many benefits to this protection kit for 

overall health and wellness....”

• On your website at https://thedrswolfson.com/nac-and-your-heart/, you state:

“NAC and Your Heart...

Updated: May 18, 2021...

What is NAC?

Cysteine is an amino acid essential for the production of many proteins. It is also a 

major component of glutathione, the main antioxidant of the body....

NAC may also help with COVID prevention and treatment in people with COVID.

NAC appears to fight other viruses too.

Ways to Benefits from NAC (and glutathione)...

Whey protein as a supplement is an excellent source of glutathione building blocks. 

That is why I included New Zealand grass-fed whey in our Daily Defense [link to 

https://shop.thedrswolfson.com/products/daily-defense-grass-fed-whey-protein-
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 4

shake]. I think Daily Defense is our single best source of heart, lung and total body 

protection. You can read more here [link to 

https://shop.thedrswolfson.com/products/daily-defense-grass-fed-whey-proteinshake].

N-acetyl cysteine supplements are a proven strategy. We have an excellent source for 

you [link to https://shop.thedrswolfson.com/products/n-acetyl-cysteine-nac-this-itemis-in-stock]. High dose, one cap by mouth per day.

You can nebulize glutathione too. BUT ONLY THIS BRAND goes in the nebulizer

[link to https://shop.thedrswolfson.com/products/l-glutathione-plus].

Our Detoxicore [link to https://shop.thedrswolfson.com/products/detoxicore] also 

contains NAC and many other nutrients to support body health and wellness. 

Excellent for immune and detox support....”

• On your website at https://thedrswolfson.com/can-beetroot-powder-protect-youfrom-coronavirus/, you state:

“Can Beetroot Powder Protect You from Coronavirus?

Dr. Jack Wolfson...

Updated: March 19, 2020...

Who would have thought that beetroot can protect you from a virus? Actually, it is 

the end-product, nitric oxide, made from nitrates from food like beets that are 

antiviral. 

A couple of studies seem to point to nitric oxide as protective against certain viruses. 

Corona is one of them....

How NO Works to Fight Viruses

One study that you can find here discovered the following: 

1. Nitric oxide or its derivatives can reduce viral spike protein which affects the 

fusion of the virus and its receptor, angiotensin converting enzyme 2. ([T]his 

receptor appears to be increased in users of ACE inhibitors, who are at a 

300% higher risk of viral pneumonia death or intubation.[)]

2. Nitric oxide or its derivatives cause a reduction in viral RNA production in 

the early steps of viral replication.

The same authors published another article on the topic as well. You can read more 

here. Here is a 3rd study you can review about nitric oxide and virus control. 
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 5

Boost Nitric Oxide Naturally...

Nitrate-rich foods- Nitrates (NO3) from foods like beets and green leafy vegetables 

are converted to nitrite (NO2) by oral bacteria and then to NO by stomach acid. Two 

problems here: People have low levels of good oral bacteria AND have decreased 

amounts of stomach acid. This is why we need probiotics and digestive enzymes. 

(Read on for my product recommendations for both of those.) Aside from eating the 

beets and greens, I suggest organic beetroot powder and an organic greens powder. 

(Read on for my product recommendations for both of those.)...

Crank Up Your NO for Viral Protection and More

Eat beets and leafy greens. Consume protein rich foods like liver and seafood for 

amino acids. Get sunshine whenever possible. Everyone should follow these steps. 

But you can also supplement with food-based nutrients and here is my plan for viral 

protection, heart health and SO much more. 

1. Heart Beet [link to https://shop.thedrswolfson.com/products/beetroot-powder] 

– 1 heaping teaspoon daily

2. Daily Greens [link to https://shop.thedrswolfson.com/products/daily-greensdrink] – 1 heaping teaspoon daily

3. Vessel Support [link to https://shop.thedrswolfson.com/products/vesselsupport] – 1 level teaspoon daily. Vessel Support is arginine, citrulline and 

taurine plus grapeseed extract to prevent the breakdown of nitric oxide

4. Heart Helpers [link to https://shop.thedrswolfson.com/products/heart-helpersprobiotic] is a top quality probiotic. Take one capsule daily.

5. Digest [link to https://shop.thedrswolfson.com/products/digest] is our 

digestive enzymes. Most people need more than 35 digestive enzymes for 

immune system health and Digest delivers. Take two caps daily.

I take the powdered drinks and mix them in 8-12 ounces of water or add them to a 

smoothie. 

I have packaged these 5 products together in our Nitric Oxide Viral Protection Kit. 

You save 20% when you buy them as a kit. Ordering information and more details 

here [link to https://shop.thedrswolfson.com/products/nitric-oxide-viral-protectionkit]....”

• On your website at https://naturalheartdoctor.com/nac-for-afib/, you state:

“NAC for AFIB?...

October 19, 2021...
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 6

What is NAC?

Cysteine is an amino acid essential for the production of many proteins. It is also a 

major component of glutathione, the main antioxidant of the body.

NAC is the standard version of cysteine used in supplements and the version used in 

100s of medical and scientific studies....

NAC may also help with COVID prevention and treatment in people with COVID.

NAC appears to fight other viruses too.

FDA threatens to ban NAC.

The product appears to be so effective, they want to control its distribution.

Better secure your supply quickly.

We love this NAC product [link to https://shop.thedrswolfson.com/products/nac-120-

caps-please-call-for-pricing-480-535-6844-1, where NAC 120 Caps are available for 

purchase]. You will too.

Again, make sure you take the best. Buy your NAC here [link to 

https://shop.thedrswolfson.com/products/nac-120-caps-please-call-for-pricing-480-

535-6844-1].”

• On your website at https://naturalheartdoctor.com/covid-and-vitamin-d/, you state:

“COVID and Vitamin D

Dr. Jack Wolfson DO, FACC

September 6, 2021...

Vitamin D Deficiency and COVID

Vitamin D deficiency is a worldwide pandemic....

Vitamin D deficiency markedly increases our risk of viral, bacterial, fungal, and 

parasitic infections.

Vitamin D deficiency and COVID lead to:

1. More hospitalizations

2. More cytokine storm, higher CRP, and higher D-dimer
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 7

3. More ICU admissions

4. More deaths- 3x more

Vitamin D Works (Science Alert)

Vitamin D:

1. Is a key regulator of the renin-angiotensin system that is exploited by SARSCoV-2 for entry into the host cells.

2. Modulates multiple mechanisms of the immune system to contain the virus 

that includes dampening the entry and replication of SARS-CoV-2

3. Reduces concentration of pro-inflammatory cytokines and increases levels of 

anti-inflammatory cytokines,

4. Enhances the production of natural antimicrobial peptides and activates 

defensive cells such as macrophages that could destroy SARS-CoV-2.

How to prevent vitamin D deficiency...

1. Get sunshine – smart sunshine while avoiding sunburn is the key here. The 

more time outside, the better.

2. Eat seafood and meat- vitamin D only comes from animal sources. Check out 

this page for more information [affiliate link to 

https://www.vitalchoice.com/].

3. Get a lamp- Yes, a vitamin D producing lamp is very beneficial. Check out 

this product here [affiliate link to https://www.sperti.com/].

4. Take supplements- During the winter months, load up on vitamin D from 

food, your lamp, and from a bottle. Our patients get the best with our Super D 

liquid [link to https://naturalheartdoctor.com/product/super-d/, where Super D 

is available for purchase].

5-10 drops per day in the winter usually suffices. Get your levels checked and stay 

above 40. Take Super D with a quality multivitamin [link to 

https://naturalheartdoctor.com/product/cardio-multi/] loaded with K2 as well. See our 

MULTI [link to https://naturalheartdoctor.com/product/cardio-multi/].”

• On your website at https://naturalheartdoctor.com/japanese-natto-will-this-nutrientdense-food-help-with-covid/, you state:

“Japanese Natto: Will This Nutrient Dense Food Help with Covid?

Dr. Jack Wolfson DO, FACC and Ali Richmond, FNTP

August 17, 2021...
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 8

Are you concerned about contracting viruses such as covid? Do you have loved ones 

who have had the J & J, AstraZeneca or really, any of the so-called ‘shots’?

Read on to find out how you can help yourself and your loved ones, and share this 

information on a simple Japanese food/common supplement....

What is Natto?

Natto is a traditional Japanese fermented soybean which has proven to be beneficial 

for health. The texture is slimy, sticky and stringy, but don’t let that deter you as it’s 

benefits far outweigh any opposition to eating it. Fortunately, we can also just take it 

in pill form. It is rich in nutrients including manganese, magnesium, potassium, zinc 

and more....

Natto and Covid

Scientists discovered Natto breaks down spike proteins on the surface of the Covid 

virus which prevents the virus from spreading within the body. It can also limit 

infections from other viruses.

In those who contract covid, elevated blood viscosity is the primary cause of 

thrombotic complications of Covid-19. Survivors of covid are at an increased risk for 

blood clots so using Nattokinase or our product called FLOW [link to 

https://naturalheartdoctor.com/product/flow/] is a perfect way to include some 

powerful protection by keeping blood flowing well.

Keep in mind that the J & J, AstraZeneca and the other gene therapy ‘solutions’ to 

covid also produce harmful thrombotic reactions. Why? Because these jabs don’t 

stay locally at the injection site. Instead, the components including the spike proteins 

(which are the toxin) make their way to the blood and build up primarily within your 

blood vessels (also in your organs). This equates to a very high risk for blood clots, 

strokes and pulmonary embolisms to name a few. If you know anyone who has 

gotten one of these, please share this information.

Nattokinase (FLOW) supports healthy blood flow by acting as an anticoagulant and 

breaking up fibrous clots. It is also anti-athersosclerotic and protective of your blood 

vessels. Ideal dosing is 1-2 caps per day, depending on need (and if you’ve had a 

jab)....”

• On your website at https://naturalheartdoctor.com/are-you-in-imminent-dangercovid-19-and-cardiovascular-conditions/, you state: 

“Are You in Imminent Danger? Covid 19 and Cardiovascular Conditions
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 9

Dr. Jack Wolfson DO, FACC

May 5, 2021...

[Graphic of a large red round object with spikes, identifiable as a coronavirus, with 

the text: “COVID-19 CoronaVirus”]

Fear can make you sick; a virus will not if you keep your body in the best of shape. 

The fear that has been perpetuated over the last year will only serve to undermine 

your immune system. I want to help you Bulletproof Your Immune System....

Did you know that humans host 300,000,000,000 viral particles. You heard that 

right. We have coexisted with viruses since the beginning of time. So why are people 

so afraid? And what can we do?

The answer is simple, maintain a healthy immune system in order to keep ALL the 

viruses and other co-inhabitants in your body balanced....

I want you to know that your body is your hero. It is fully capable of fighting a virus 

when equipped to do so. Stop fearing a virus and know that you can be invincible. 

Will we get sick from time to time? Sure! And we will recover. Let’s make sure we 

prepare ourselves every day to keep viruses, bacteria and everything else in check.

Boost Your Immune System to Annihilate Fear!...

Sadly, even the best diets are deficient in nutrients. The soil is lacking, the air is 

polluted and the water is poisonous. This is why we recommend support from 

supplements in addition to taking the above steps.

1. Protection Kit to support your body on a daily basis. For this kit purchase: 

Heart Defense [link to https://naturalheartdoctor.com/product/heart-defense/],

Cardio Multi [link to https://naturalheartdoctor.com/product/cardio-multi/], 

CardiOmega [link to https://naturalheartdoctor.com/product/cardiomega/], and 

Heart Helpers [link to https://naturalheartdoctor.com/product/heart-helpersprobiotic/]

2. Emergency Kit to provide maximum benefit in a time of need. For this kit 

purchase: Super C [link to https://naturalheartdoctor.com/product/super-c/], 

Argentyn [link to https://naturalheartdoctor.com/product/argentyn-silverhydrosol/], Berbe [link to https://naturalheartdoctor.com/product/berbeberberine/], Lauricidin [link to 

https://naturalheartdoctor.com/product/lauricidin-the-natural-heart-doctor/], 

and Liquid A [link to https://naturalheartdoctor.com/product/liquid-a/].”
Drs. Jack and Heather Wolfson

The Drs. Wolfson, LLC

December 29, 2021

Page 10

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 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 for such products are not 

supported by competent and reliable scientific evidence. You must immediately cease and 

desist making all such claims.

You are also advised to review all other claims for your products and services and 

immediately cease and desist claims that are notsupported by competent and reliable

scientific evidence. 

Violations of the FTC Act may result in legal action seeking a Federal District Court 

injunction. In addition, pursuant to the COVID-19 Consumer Protection Act, Section 1401, 

Division FF, of the Consolidated Appropriations Act, 2021, P.L. 116-260, marketers who make 

deceptive claims about the treatment, cure, prevention, or mitigation of COVID-19 are subject to 

a civil penalty of up to $43,792 per violation and may be required to pay refunds to consumers or 

provide other relief pursuant to Section 19(b) of the FTC Act, 15 U.S.C. § 57b(b).

Within 48 hours, please send a message to Mr. Richard Cleland via electronic mail at 

rcleland@ftc.gov certifying that you have ceased making unsubstantiated claims for the products

identified above. If you have any questions regarding compliance with the FTC Act, please 

contact Mr. Cleland at 202-326-3088.

Very truly yours,

Serena Viswanathan

Associate Director

Division of Advertising Practices