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________________________________________________ 

________________________________________________ 

PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro Martin Bedoya 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DOCKET NO. 9397 

SECOND CONSENT MOTION TO WITHDRAW 

MATTER FROM ADJUDICATION FOR THE 

PURPOSE OF CONSIDERING A PROPOSED CONSENT AGREEMENT 

Pursuant to Rules 3.25(b) and (c) of the Commission’s Rules of Practice, 16 C.F.R. § 

3.25(b), (c), Complaint Counsel moves the Commission to extend the withdrawal of this matter 

from adjudication under Docket No. 9397 for the purpose of allowing the Commission to further 

consider a proposed consent agreement. 

In a previous Order issued on January 21, 2022, the Commission granted an application 

to withdraw the matter from adjudication through April 19, 20221 and stayed all proceedings 

before the Administrative Law Judge in this matter pending a determination by the Commission 

1 Complaint Counsel has not communicated with the Commission or their staff, the Office of General Counsel, or 

the Office of Administrative Law Judges about this matter after April 18, 2022. 
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PUBLIC 

with respect to the proposed consent agreement pursuant to Section 3.25(f) of the Commission’s 

Rules of Practice, 16 C.F.R. § 3.25(f). See Attachment A. The Analysis of Proposed Consent 

Order in Aid of Public Comment was published in the Federal Register on March 22, 2022, and 

one comment was received. 

Complaint Counsel has conferred with counsel for the Respondents, Health Research 

Laboratories, LLC, Whole Body Supplements, LLC and Kramer Duhon, and Respondents 

consent to this motion. 

The proposed consent agreement originally filed in this matter on January 19, 2022, and 

re-submitted as Attachment B to this Motion, conforms to the requirements of Commission Rule 

of Practice 2.32, 16 C.F.R. § 2.32, has been fully executed by Complaint Counsel and 

Respondents, and approved by the Bureau of Consumer Protection. The proposed consent 

agreement would resolve the matter before the Commission in its entirety. Accordingly, 

Complaint Counsel respectfully requests that this matter be withdrawn from adjudication until 

the Commission makes a final determination with respect to the proposed consent agreement. 

May 31, 2022 Respectfully submitted, 

s/ Elizabeth J. Averill 

Elizabeth J. Averill 

Federal Trade Commission 

600 Pennsylvania Ave, NW, CC-9528 

Washington, DC 20580 

(202) 326-2993 

eaverill@ftc.gov 

(202) 326-3197 (facsimile) 

Complaint Counsel 

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PUBLIC 

CERTIFICATE OF SERVICE 

I certify that I served a copy of the foregoing Second Consent Motion to Withdraw 

Matter from Adjudication for the Purpose of Considering a Proposed Consent Agreement today 

via electronic mail. 

Joel Reese 

Joshua Russ 

Reese Marketos LLP 

750 N. Saint Paul St., Suite 600 

Dallas, TX 75201 

Joel.reese@rm-firm.com 

Josh.russ@rm-firm.com 

I also served one electronic copy via the Administrative E-Filing System and one electronic 

courtesy copy to the Office of the Secretary via email to ElectronicFilings@ftc.gov. 

I served one electronic courtesy copy via email to the Office of the Administrative Law Judge: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

600 Pennsylvania Ave, N.W., Room H-110 

Washington, DC 20580 

Dated: May 31, 2022 s/ Elizabeth J. Averill 

Elizabeth J. Averill 

Federal Trade Commission 

600 Pennsylvania Ave, NW 

Washington, DC 20580 

(202) 326-2993; eaverill@ftc.gov 

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ATTACHMENT A 
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________________________________________________ 

________________________________________________ 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DOCKET NO. 9397 

ORDER WITHDRAWING MATTER FROM ADJUDICATION FOR THE 

PURPOSE OF CONSIDERING A PROPOSED CONSENT AGREEMENT 

Complaint Counsel having moved that this matter be withdrawn from adjudication in order 

to enable the Commission to consider a proposed consent agreement, and Respondents 

consenting to the motion; and 

Complaint Counsel and Respondents, having submitted a proposed Consent Agreement 

containing a proposed Decision and Order, executed by Respondents and by Complaint Counsel 

and approved by the Director of the Bureau of Consumer Protection that, if accepted by the 

Commission, would resolve the claims against Respondents in their entirety; 

IT IS ORDERED that pursuant to Section 3.25(c) of the Commission’s Rules of Practice, 

16 C.F.R. § 3.25(c), that this matter in its entirety be, and it is hereby withdrawn from 

adjudication until April 19, 2022, and that all proceedings before the Administrative Law Judge 

in this matter are hereby stayed pending a determination by the Commission with respect to the 

proposed Consent Agreement, pursuant to Section 3.25(f) of the Commission’s Rules of 

Practice, 16 C.F.R. § 3.25(f); and 

IT IS FURTHER ORDERED, pursuant to Section 3.25(b) of the Commission’s Rules of 

Practice, 16 C.F.R. § 3.25(b), that the proposed Consent Agreement shall not be placed on the 

public record unless and until it is accepted by the Commission. 

By the Commission. 

SEAL: April J. Tabor 

ISSUED: January 21, 2022 Secretary 
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ATTACHMENT B 
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x180007 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, DOCKET NO. 9397 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, AGREEMENT 

a limited liability company, and CONTAINING CONSENT 

ORDER 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

The Federal Trade Commission ("Commission"), has issued a Complaint challenging 

certain acts and practices ofHealth Research Laboratories, LLC, Whole Body Supplements, 

LLC, and Kramer Duhon, individually and as an officer of Health Research Laboratories, LLC 

and Whole Body Supplements, LLC (collectively, "Respondents"). The Commission's Bureau 

of Consumer Protection ("BCP") and Respondents, individually or through their duly authorized 

officer, enter into this Agreement Containing Consent Order ("Consent Agreement") to resolve 

the allegations in the Complaint through a proposed Decision and Order to present to the 

Commission, which is also attached and made a part of this Consent Agreement. 

IT IS HEREBY AGREED by and between Respondents and BCP, that: 

1. The Respondents are: 

a. Respondent Health Research Laboratories, LLC, a Nevada limited liability company 

with its principal office or place of business at 16250 Knoll Trail Drive, Dallas, TX 

75248. 

b. Respondent Whole Body Supplements, LLC, a Nevada limited liability company with 

its principal office or place of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 
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c. Respondent Kramer Duhon, an officer and managing member of Health Research 

Laboratories, LLC, and an officer and managing member of Whole Body 

Supplements, LLC. Individually or in concert with others, he formulates, directs, or 

controls the policies, acts, or practices of Health Research Laboratories, LLC and 

Whole Body Supplements, LLC. His principal office or place of business is the same 

as that ofHealth Research Laboratories, LLC and Whole Body Supplements, LLC. 

2. Respondents have been served with a copy ofthe administrative Complaint issued by the 

Commission charging them with violations of Sections 5(a) and 12 of the Federal Trade 

Commission Act and have filed answers to the Complaint. 

3. Only for purposes of this action, Respondents admit the facts necessary to establish 

jurisdiction. 

4. Respondents waive: 

a. Any further procedural steps; 

b. The requirement that the Commission's Decision contain a statement of findings of 

fact and conclusions of law; 

c. All rights to seek judicial review or otherwise challenge or contest the validity of the 

Decision and Order issued pursuant to this Consent Agreement; and 

d. any claim under the Equal Access to Justice Act. 

5. This Consent Agreement will not become part of the public record of the proceeding 

unless and until it is accepted by the Commission. Ifthe Commission accepts this Consent 

Agreement, it will be placed on the public record for 30 days and information about it publicly 

released. Acceptance does not constitute final approval, but it serves as a basis for further 

actions leading to final disposition ofthe matter. Thereafter, the Commission may either 

withdraw its acceptance ofthis Consent Agreement and so notify each Respondent, in which 

event the Commission will take such action as it may consider appropriate, or issue and serve its 

decision in disposition ofthe proceeding, which may include an Order. See Section 3.25(f) of 

the Commission's Rules, 16 C.F.R. § 3.25(f) ("Rule 3.25(f)"). 

6. Ifthis Consent Agreement is accepted by the Commission, and if such acceptance is not 

subsequently withdrawn by the Commission pursuant to Rule 3.25(f), the Commission may, 

without further notice to Respondents, (1) issue its Decision and Order; and (2) make 

information about them public. Respondents agree that service of the Order may be effected by 

its publication on the Commission's website (fie.gov), at which time the Order will become final. 

See Rule 2.32( d). Respondents waive any rights they may have to any other manner of service. 

See Rule 4.4. 

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7. When final, the Decision and Order will have the same force and effect and may be 

altered, modified, or set aside in the same manner and within the same time provided by statute 

for other Commission orders. 

8. The Complaint may be used in construing the terms of the Decision and Order. No 

agreement, understanding, representation, or interpretation not contained in the Decision and 

Order or in this Consent Agreement may be used to vary or contradict the terms of the Decision 

and Order. 

9. Each Respondent agrees to comply with the terms of the proposed Decision and Order 

from the date that Respondents sign this Consent Agreement. Respondents understand that they 

may be liable for civil penalties and other relief for each violation of the Decision and Order 

after it becomes final. 

Managing Member and Officer 

Date: /, /1 • ZOZ,-,,. 

3 

FEDERAL TRADE COMMISSION 

By: 

------------ Eliz abet h J. Averill 

Attorney, Bureau of Consumer Protection 

APPROVED: 

James A. Kohm 

Associate Director 

Division of Enforcement 

Samuel Levine 

Director 

Bureau of Consumer Protection 

Date - --------- -

PUBLIC

Digitally signed by ELIZABETH ELIZABETH AVERILL 

Date: 2022.01.18 AVERILL 15:31:45 -05'00' 

JAMES KOHM Digitally signed by JAMES KOHM 

Date: 2022.01.18 15:55:04 -05'00' 

Samuel Levine/IB

1/19/2022
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Attorney for Respondents 

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x180007 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, DECISION AND ORDER 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and DOCKET NO. 9397 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DECISION 

The Federal Trade Commission ("Commission") issued a Complaint challenging certain acts 

and practices of the Respondents named in the caption. The Commission's Bureau of Consumer 

Protection ("BCP") filed the Complaint, which charged the Respondents with violating Sections 

5(a) and 12 ofthe Federal Trade Commission Act. 

Respondents and BCP thereafter executed an Agreement Containing Consent Order 

("Consent Agreement"). The Consent Agreement includes: 1) a statement by Respondents that 

only for purposes of this action, they admit the facts necessary to establish jurisdiction, and 2) 

waivers and other provisions as required by the Commission's Rules. 

This matter was subsequently withdrawn from adjudication in accordance with Section 3.25 

ofthe Commission's Rules, 16 C.F.R. § 3.25. 

The Commission accepted the executed Consent Agreement and placed it on the public 

record for a period of 30 days for the receipt and consideration of public comments. The 

Commission duly considered any comments received from interested persons pursuant to Section 

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2.34 of its Rules, 16 C.F.R. § 2.34. Now, in further conformity with the procedure prescribed in 

Rule 3.25(f), the Commission makes the following Findings and issues the following Order: 

FINDINGS 

1. The Respondents are: 

a. Respondent Health Research Laboratories, LLC, a Nevada limited liability company 

with its principal office or place of business at 16250 Knoll Trail Drive, Dallas, TX 

75248. 

b. Respondent Whole Body Supplements, LLC, a Nevada limite<l liabilily company wilh 

its principal office or place of business at 16250 Knoll Trail Drive, Dallas, TX 75248. 

c. Respondent Kramer Duhon, an officer and managing member of Health Research 

Laboratories, LLC, and an officer and managing member of Whole Body 

Supplements, LLC. Individually or in concert with others, he formulates, directs, or 

controls the policies, acts, or practices of Health Research Laboratories, LLC and 

Whole Body Supplements, LLC. His principal office or place of business is the same 

as that of Health Research Laboratories, LLC and Whole Body Supplements, LLC. 

2. The Commission has jurisdiction over the subject matter of this proceeding and over the 

Respondents, and the proceeding is in the public interest. 

ORDER 

Definitions 

For purposes of this Order, the following definitions apply: 

A. "Covered Product" means any Food or Drug. 

B. "Corporate Respondent" means Health Research Laboratories, LLC, and Whole Body 

Supplements, LLC. 

C. "Dietary Supplement" means: 

1. any product labeled as a dietary supplement or otherwise represented as a dietary 

supplement; or 

2. any pill, tablet, capsule, powder, softgel, gelcap, liquid, or other similar form 

containing one or more ingredients that are a vitamin, mineral, herb or other botanical, 

amino acid, probiotic, or other dietary substance for use by humans to supplement the 

diet by increasing the total dietary intake, or a concentrate, metabolite, constituent, 

extract, or combination of any ingredient described above, that is intended to be ingested, 

and is not represented to be used as a conventional food or as a sole item of a meal or the 

diet. 

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D. "Drug" means: (a) articles recognized in the official United States Pharmacopoeia, 

official Homoeopathic Pharmacopoeia of the United States, or official National 

F ormulary, or any supplement to any ofthem; (b) articles intended for use in the 

diagnosis, cure, mitigation, treatment, or prevention of disease in humans or other 

animals; ( c) articles ( other than food) intended to affect the structure or any function of 

the body of humans or other animals; and ( d) articles intended for use as a component of 

any article specified in (a), (b), or (c); but does not include devices or their components, 

parts, or accessories. 

E. "Essentially Equivalent Product" means a product that contains the identical ingredients, 

except for inactive ingredients (e.g., inactive binders, colors, fillers, excipients), in the 

same form and dosage, and with the same route of administration (e.g., orally, 

sub lingually), as the Covered Product; provided that the Covered Product may contain 

additional ingredients ifreliable scientific evidence generally accepted by experts in the 

field indicates that the amount and combination of additional ingredients are unlikely to 

impede or inhibit the effectiveness of the ingredients in the essentially equivalent 

product. 

F. "Food" means: (a) any article used for food or drink for humans or other animals; (b) 

chewing gum; and ( c) any article used for components of any such article. 

G. "Individual Respondent" means Kramer Duhon. 

H. "Negative Option Feature" means, in an offer or agreement to sell any good of service, a 

provision under which the consumer's silence or failure to take affirmative action to 

reject a good or service or to cancel the agreement is interpreted by the seller or provider 

as acceptance or continuing acceptance of the offer. 

I. "Respondents" means Health Research Laboratories, LLC, Whole Body Supplements, 

LLC, and Kramer Duhon, individually, collectively, or in any combination. 

Provisions 

I. 

IT IS ORDERED that Respondents must not advertise, market, promote, or offer for sale 

any Dietary Supplement or assist others in the advertising, marketing, promoting, or offering for 

sale of any Dietary Supplement. 

II. 

IT IS FURTHER ORDERED that Respondents, whether acting directly or indirectly, in 

connection with the advertising, marketing, promoting, or offering for sale of any product, must 

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not make any representation, expressly or by implication, that a product cures, treats, mitigates, 

prevents, or reduces the risk of any disease. 

III. 

IT IS FURTHER ORDERED that subject to the prohibitions in Parts I and II ofthis 

Order, Respondents, Respondents' officers, agents, and employees, and all other persons in 

active concert or participation with any ofthem, who receive actual notice of this Order, 

whether acting directly or indirectly, in connection with the manufacturing, labeling, 

advertising, promotion, offering for sale, sale, or distribution of any Covered Product, must not 

make any representation expressly or by implication, about the health benefits, safety, 

performance, or efficacy of any Covered Product, unless the representation is non-misleading, 

and, at the time of making such representation, they possess and rely upon competent and 

reliable scientific evidence that is sufficient in quality and quantity based on standards generally 

accepted by experts in the relevant condition or function to which the representation relates, 

when considered in light of the entire body of relevant and reliable scientific evidence, to 

substantiate that the representation is true. 

For purposes of this Provision, "competent and reliable scientific evidence" means tests, 

analyses, research, or studies that (1) have been conducted and evaluated in an objective manner 

by experts in the relevant condition or function to which the representation relates; (2) that are 

generally accepted by such experts to yield accurate and reliable results; and (3) that are 

randomized, double-blind, and placebo-controlled human clinical testing of the Covered Product 

or of an Essentially Equivalent Product, when such experts would generally require such human 

clinical testing to substantiate that the representation is true. In addition, when such tests or 

studies are human clinical tests or studies, all underlying or supporting data and documents 

generally accepted by experts in the field as relevant to an assessment of such testing as set forth 

in Part V ofthis Order must be available for inspection and production to the Commission. 

Respondents have the burden of proving that a product satisfies the definition of Essentially 

Equivalent Product. 

IV. 

IT IS FURTHER ORDERED that subject to the prohibitions in Parts I and II of this 

Order, Respondents, Respondents' officers, agents, employees, and all other persons in active 

concert or participation with any ofthem, who receive actual notice ofthis Order, whether 

acting directly or indirectly, in connection with advertising, marketing, promoting, offering for 

sale, sale, or distribution of any Covered Product must not make any misrepresentations 

expressly or by implication: 

A. That the performance or benefits of any Covered Product are scientifically or 

clinically proven or otherwise established; or 

B. About the existence, contents, validity, results, conclusions, or interpretations of any 

test, study, or other research. 

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V. 

PUBLIC

IT IS FURTHER ORDERED that, with regard to any human clinical test or study ("test") 

upon which Respondents rely to substantiate any claim not banned by Parts I or II, but covered 

by Part III, Respondents must secure and preserve all underlying or supporting data and 

documents generally accepted by experts in the field as relevant to an assessment of the test, 

including: 

A. All protocols and protocol amendments, reports, articles, write-ups, or other 

accounts of the results of the test, and drafts of such documents reviewed by the test 

sponsor or any other person not employed by the research entity; 

B. All documents referring or relating to recruitment; randomization; instructions, 

including oral instructions, to participants; and participant compliance; 

C. Documents sufficient to identify all test participants, including any participants 

who did not complete the test, and all communications with any participants 

relating to the test; all raw data collected from participants enrolled in the test, 

including any participants who did not complete the test; source documents for 

such data; any data dictionaries; and any case report forms; 

D. All documents referring or relating to any statistical analysis of any test data, 

including any pretest analysis, intent-to-treat analysis, or between-group analysis 

performed on any test data; and 

E. All documents referring or relating to the sponsorship ofthe test, including all 

communications and contracts between any sponsor and the test's researchers. 

Provided, however, the preceding preservation requirement does not apply to a reliably 

reported test, unless the test was conducted, controlled, or sponsored, in whole or in part by: 

(1) any Respondent; (2) any Respondent's officers, agents, representatives, or employees; (3) 

any other person or entity in active concert or participation with any Respondent; (4) any person 

or entity affiliated with or acting on behalf of any Respondent; (5) any supplier of any 

ingredient contained in the product at issue to any of the foregoing or to the product's 

manufacturer; or ( 6) the supplier or manufacturer of such product. 

For purposes of this Provision, "reliably reported test" means a report of the test has been 

published in a peer-reviewed journal, and such published report provides sufficient information 

about the test for experts in the relevant field to assess the reliability of the results. 

For any test conducted, controlled, or sponsored, in whole or in part, by Respondents, 

Respondents must establish and maintain reasonable procedures to protect the confidentiality, 

security, and integrity of any personal information collected from or about participants. These 

procedures must be documented in writing and must contain administrative, technical, and 

physical safeguards appropriate to Corporate Respondents' size and complexity, the nature and 

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scope of Respondents' activities, and the sensitivity of the personal information collected from 

or about the participants. 

VI. 

IT IS FURTHER ORDERED that Respondents must notify customers as follows: 

A. Respondents must identify all consumers who purchased Black Garlic Botanicals, BG18, 

The Ultimate Heart Formula, and Neupathic on or after January 17, 2018 ("Eligible 

Customers"). 

1. Such Eligible Customers, and their contact information, must be identified to the 

extent such information is in Respondents' possession, custody or control; 

2. Eligible Customers include those identified at any time through the eligibility period, 

which runs for 1 year after the issuance date of the Order. 

B. Respondents must mail all Eligible Customers the letter in the form shown in Attachment 

A. Each such mailing must comply with the following: 

1. The envelope containing the letter must be in the form shown in Attachment B. 

2. The mailing of the notification letter must not include any other enclosures other than 

a copy of this Order. 

3. The mailing must be sent by first-class mail, postage prepaid, address correction 

service requested with forwarding and return postage guaranteed. For any mailings 

returned as undeliverable, Respondents must use standard address search 

methodologies such as re-checking Respondents' records and the Postal Service's 

National Change of Address database and re-mailing to the corrected address within 8 

days. 

4. Each such notice must be mailed within 120 days after the effective date of this 

Order. 

C. Respondents must report on their notification program under penalty of perjury as 

follows: 

1. Respondents must submit a report at the conclusion ofthe program, but in no event 

later than 180 days after the effective date ofthis Order, detailing its compliance with 

this Provision. 

2. If a representative of the Commission requests any information regarding the 

program, including any ofthe underlying customer data, Respondents must submit 

the requested information within 10 days of the request. 

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3. Failure to provide required notices or any requested information will be treated as a 

continuing failure to obey this Order. 

VII. 

IT IS FURTHER ORDERED that Respondents and their officers, agents, employees, and 

attorneys, and all other persons in active concert or participation with any ofthem, who receive 

actual notice ofthis Order, must not disclose, use, or receive any benefit from customer 

information including the name, address, telephone number, e-mail address, social security 

number, or other identifying information or any data that enables access to a customer's account 

(including a credit card, bank account or other financial account) that any Respondent obtained 

prior to the issuance ofthis Order in connection with sales of Black Garlic Botanicals, BG18, 

The Ultimate Heart Formula, or Neupathic. Respondents must also preserve such identifying 

information together with records of the product(s) individual customers purchased and the date 

and amount of payments made to Respondents until receipt of written notice from Commission 

staff to destroy the information. Once Commission staff notify Respondents to destroy such 

customer information, Respondents will have five days to comply. 

Provided, however, that Respondents may disclose such customer information to the FTC or 

any law enforcement agency, or as required by any law, regulation, or court order. 

VIII. 

IT IS FURTHER ORDERED that, consistent with Part VII, Respondents must immediately 

cancel any subscription plan with a Negative Option Feature related to Black Garlic Botanicals, 

BG18, The Ultimate Heart Formula, or Neupathic. 

IX. 

IT IS FURTHER ORDERED that Respondents obtain acknowledgments ofreceipt ofthis 

Order: 

A. Each Respondent, within 10 days after the effective date ofthis Order, must submit to the 

Commission an acknowledgment ofreceipt of this Order sworn under penalty of perjury. 

B. For 20 years after the issuance date of this Order, the Individual Respondent, for any 

business that such Respondent, individually or collectively with any other Respondent, is 

the majority owner or controls directly or indirectly, and each Corporate Respondent, 

must deliver a copy ofthis Order to: (1) all principals, officers, directors, and LLC 

managers and members; (2) all employees having managerial responsibilities for the 

manufacturing, labeling, advertising, marketing, distribution, or sale of any Covered 

Product, and all agents and representatives who participate in manufacturing, labeling, 

advertising, marketing, distribution, or sale of any Covered Product; and (3) any business 

entity resulting from any change in structure as set forth in Part X. Delivery must occur 

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within 10 days after the effective date of this Order for current personnel. For all others, 

delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which a Respondent delivered a copy ofthis Order, that 

Respondent must obtain, within 30 days, a signed and dated acknowledgment of receipt 

of this Order. 

x. 

IT IS FURTHER ORDERED that Respondents make timely submissions to the 

Commission: 

A. One year after the issuance date ofthis Order, each Respondent must submit a 

compliance report, sworn under penalty of perjury, in which: 

1. Each Respondent must: (a) identify the primary physical, postal, and email address 

and telephone number, as designated points of contact, which representatives ofthe 

Commission may use to communicate with Respondent; (b) identify all of that 

Respondent's businesses by all of their names, telephone numbers, and physical, 

postal, email, and Internet addresses; ( c) describe the activities of each business, 

including the goods and services offered, the means of advertising, marketing, and 

sales, and the involvement of any other Respondent (which Individual Respondent 

must describe if they know or should know due to their own involvement); (d) 

describe in detail whether and how that Respondent is in compliance with each Part 

of this Order, including a discussion of all ofthe changes the Respondent made to 

comply with the Order; and ( e) provide a copy of each acknowledgment ofthe Order 

obtained pursuant to this Order, unless previously submitted to the Commission. 

2. Additionally, the Individual Respondent must: (a) identify all his telephone numbers 

and all his physical, postal, email, and Internet addresses, including all residences; (b) 

identify all his business activities, including any business for which such Respondent 

performs services whether as an employee or otherwise and any entity in which such 

Respondent has any ownership interest; and (c) describe in detail such Respondent's 

involvement in each such business activity, including title, role, responsibilities, 

participation, authority, control, and any ownership. 

B. Each Respondent must submit a compliance notice, sworn under penalty of perjury, 

within 14 days of any change in the following: 

1. Each Respondent must submit notice of any change in: (a) any designated point of 

contact; or (b) the structure of any Corporate Respondent or any entity that 

Respondent has any ownership interest in or controls directly or indirectly that may 

affect compliance obligations arising under this Order, including: creation, merger, 

sale, or dissolution ofthe entity or any subsidiary, parent, or affiliate that engages in 

any acts or practices subject to this Order. 

8 
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2. Additionally, the Individual Respondent must submit notice of any change in: (a) 

name, including alias or fictitious name, or residence address; or (b) title or role in 

any business activity, including (i) any business for which such Respondent performs 

services whether as an employee or otherwise and (ii) any entity in which such 

Respondent has any ownership interest and over which Respondents have direct or 

indirect control. For each such business activity, also identify its name, physical 

address, and any Internet address. 

C. Each Respondent must submit notice of the filing of any bankruptcy petition, insolvency 

proceeding, or similar proceeding by or against such Respondent within 14 days of its 

filing. 

D. Any submission to the Commission required by this Order to be sworn under penalty of 

perjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: "I declare under penalty of perjury under the laws ofthe United States of 

America that the foregoing is true and correct. Executed on: __" and supplying the 

date, signatory's full name, title (if applicable), and signature. 

E. Unless otherwise directed by a Commission representative in writing, all submissions to 

the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or sent by 

overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue 

NW, Washington, DC 20580. The subject line must begin: In re Health Research 

Laboratories, Dkt. 9397. 

XI. 

IT IS FURTHER ORDERED that Respondents must create certain records for 20 years 

after the issuance date of the Order, and retain each such record for 5 years, unless otherwise 

specified below. Specifically, the Corporate Respondents and Individual Respondent for any 

business that such Respondent, individually or collectively with any other Respondents, is a 

majority owner or controls directly or indirectly, must create and retain the following records: 

A. Accounting records showing the revenues from all goods or services sold, the costs 

incurred in generating those revenues, and resulting net profit or loss; 

B. Personnel records showing, for each person providing services in relation to any aspect of 

the Order, whether as an employee or otherwise, that person's: name; addresses; 

telephone numbers; job title or position; dates of service; and (if applicable) the reason 

for termination; 

C. Copies or records of all consumer complaints and refund requests, whether received 

directly or indirectly, such as through a third party, and any response; 

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D. All records necessary to demonstrate full compliance with each Provision ofthis Order, 

including all submissions to the Commission; and 

E. A copy of each unique advertisement or other marketing material making a representation 

subject to this Order. 

F. For 5 years from the date of the last dissemination of any representation covered by this 

Order: 

1. All materials that were relied upon in making the representation; and 

2. All tests, studies, analysis, other research or other such evidence in Respondents' 

possession, custody, or control that contradicts, qualifies, or otherwise calls into 

question the representation, or the basis relied upon for the representation, including 

complaints and other communications with consumers or with governmental or 

consumer protection organizations. 

G. For 5 years from the date created or received, all records, whether prepared by or on 

behalf of Respondents, that tend to show any lack of compliance by Respondents with 

this Order. 

XII. 

IT IS FURTHER ORDERED that, for the purpose of monitoring Respondents' compliance 

with this Order: 

A. Within 10 days of receipt of a written request from a representative ofthe Commission, 

each Respondent must: submit additional compliance reports or other requested 

information, which must be sworn under penalty ofperjury, and produce documents for 

inspection and copying. Respondents will answer interrogatories and sit for 

investigational hearings within 30 days of a written request from Commission staff. 

B. For matters concerning this Order, representatives ofthe Commission are authorized to 

communicate directly with each Respondent. Respondents must permit representatives 

of the Commission to interview anyone affiliated with any Respondent who has agreed to 

such an interview. The interviewee may have counsel present. 

C. The Commission may use all other lawful means, including posing through its 

representatives as consumers, suppliers, or other individuals or entities, to Respondents or 

any individual or entity affiliated with Respondents, without the necessity of 

identification or prior notice. Nothing in this Order limits the Commission's lawful use 

of compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49, 

57b-l. 
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XIII. 

IT IS FURTHER ORDERED that this Order is final and effective upon the date of its 

publication on the Commission's website (www.ftc.gov) as a final order. This Order will 

terminate 20 years from the date of its issuance (which date may be stated at the end of this 

Order, near the Commission's seal), or 20 years from the most recent date that the United States 

or the Commission files a complaint (with or without an accompanying settlement) in federal 

court alleging any violation of this Order, whichever comes later; provided, however, that the 

filing of such a complaint will not affect the duration of: 

A. Any Provision in this Order that terminates in less than 20 years; 

B. This Order's application to any Respondent that is not named as a defendant in such 

complaint; and 

C. This Order if such complaint is filed after the Order has terminated pursuant to this 

Provision. 

Provided, further, that if such complaint is dismissed or a federal court rules that the Respondent 

did not violate any Provision ofthe Order, and the dismissal or ruling is either not appealed or 

upheld on appeal, then the Order will terminate according to this Provision as though the 

complaint had never been filed, except that the Order will not terminate between the date such 

complaint is filed and the later ofthe deadline for appealing such dismissal or ruling and the date 

such dismissal or ruling is upheld on appeal. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

ISSUED: 

11 
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ATTACHMENT A 

PUBLIC

[To be printed on Health Research Laboratories, LLC or Whole Body Supplements, LLC 

letterhead and sent via First Class mail] 

[Date] 

Subject: [Black Garlic Botanicals, BG 18, The Ultimate Heart Formula, or Neupathic] 

[Name of customer] 

[Mailing address of customer 

Including zip code] 

Dear [Name of customer]: 

Our records show that you bought [Black Garlic Botanicals, The Ultimate Heart 

Formula, or N eupathic from Health Research Laboratories] [BG 18 from Whole Body 

Supplements]. 

The Federal Trade Commission sued us for making misleading claims our products 

would prevent, reduce the risk of, treat or cure serious diseases and health conditions such as 

cardiovascular disease, high blood pressure, and diabetic nerve pain without having scientific 

evidence to support those claims. 

The enclosed FTC order requires us to stop selling dietary supplements and claiming 

that our products cure, treat, mitigate, prevent, or reduce the risk of any disease. 

Some products, like vitamins and herbal extracts, may interfere with other treatments 

recommended by your doctor and cause serious health risks. Before you take any 

alternative treatment for a disease, talk to your doctor. 

Learn more about the lawsuit against Health Research Laboratories and Whole Body 

Supplements at https:/lwww.ftc.gov/news-events/press-releases/2020/11/ftc-approvesadministrative-complaint-against-supplement-marketer. 

Sincerely, 

Kramer Duhon 

Health Research Laboratories, LLC 

Whole Body Supplements, LLC 

Enclosure [Enclosed Order] 

12 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 5/31/2022 | Document No. 604738 | PAGE Page 23 of 26 * PUBLIC *; 

ATTACHMENT B 

PUBLIC

The envelope for the notification letter must be in the following form, with the underlined text 

completed as directed: 

[HEALTH RESEARCH LABORATORIES, LLC OR 

WHOLE BODYSUPPLEMENTS, LLC 

Street Address 

City, State and Zip Code] 

FORWARDING AND RETURN POSTAGE GUARANTEED ADDRESS CORRECTION 

SERVICE REQUESTED 

[name and 

mailing address of customer, 

including zip code] 

ABOUT YOUR PURCHASE OF [BLACK GARLIC BOTANICALS/BG18/THE 

ULTIMATE HEART FORMULA, OR NEUPATHIC] 

13 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 5/31/2022 | Document No. 604738 | PAGE Page 24 of 26 * PUBLIC *; PUBLIC

ATTACHMENT C 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 5/31/2022 | Document No. 604738 | PAGE Page 25 of 26 * PUBLIC *; 

________________________________________________ 

________________________________________________ 

PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro Martin Bedoya 

In the Matter of 

HEALTH RESEARCH LABORATORIES, LLC, 

a limited liability company, 

WHOLE BODY SUPPLEMENTS, LLC, 

a limited liability company, and 

KRAMER DUHON, 

individually and as an officer of 

HEALTH RESEARCH LABORATORIES, LLC 

and WHOLE BODY SUPPLEMENTS, LLC. 

DOCKET NO. 9397 

ORDER EXTENDING WITHDRAWAL OF MATTER FROM 

ADJUDICATION FOR THE PURPOSE 

OF CONSIDERING A PROPOSED CONSENT AGREEMENT 

Complaint Counsel having moved that this matter be withdrawn from adjudication in 

order to facilitate the Commission’s further consideration of a Consent Agreement containing a 

proposed Decision and Order, executed by Respondents and by Complaint Counsel and 

approved by the Director of the Bureau of Consumer Protection that would resolve the claims 

against Respondents in their entirety; 

IT IS ORDERED, pursuant to Section 3.25(c) of the Commission’s Rules of Practice, 16 

C.F.R. § 3.25(c), that this matter will be withdrawn from adjudication until such time as the 

Commission makes a final determination with respect to the proposed Consent Agreement; 
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 5/31/2022 | Document No. 604738 | PAGE Page 26 of 26 * PUBLIC *; 

PUBLIC 

IT IS FURTHER ORDERED that all proceedings before the Administrative Law Judge 

in this matter will continue to be stayed pending a final determination by the Commission with 

respect to the proposed Consent Agreement. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

ISSUED: 

2