FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/30/2021 | OSCAR NO. 601085| Page 1 of 3 | PUBLIC

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Rebecca Kelly Slaughter, Acting Chairwoman 

Noah Joshua Phillips 

Rohit Chopra 

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 

RESPONDENTS’ AMENDED ANSWER 

Respondents Health Research Laboratories, LLC (“HRL”), Whole Body 

Supplements, LLC (“WBS”) and Kramer Duhon (collectively, “Respondents”) file this 

Amended Answer to the Complaint filed by the Federal Trade Commission (“FTC”). 

ANSWER PURSUANT TO 16 CFR § 3.12(b)(2) 

Pursuant to 16 CFR § 3.12(b)(2), Respondents elect not to contest the allegations 

of fact set forth in the complaint. Respondents admit all of the material allegations to be 

true. Pursuant to 16 CFR § 3.12(b)(2), Respondents reserve the right to submit proposed 

findings of fact and conclusions of law. 

LEGAL DEFENSES 

1. Violation of the United States Constitution: The FTC’s administrative process 

violates the Fifth Amendment to the United States Constitution because it seeks to deny 

Respondents of property and rights without due process of law. Further, the FTC 

receives its authority through Article II of the United States Constitution. The FTC’s 

structure violates and is inconsistent with Article II of the United States Constitution 

because the Commissioners and the Administrative Law Judges (“ALJs”) can only be 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/30/2021 | OSCAR NO. 601085| Page 2 of 3 | PUBLIC

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removed by the President for “inefficiency, neglect of duty, or malfeasance in office,” 

which means that the Commissioners and the ALJs are not subject to the supervision and 

authority of the President. 

Dated: March 30, 2021 Respectfully submitted, 

REESE MARKETOS LLP 

By: /s/ Joel W. Reese 

Joel W. Reese 

Texas Bar No. 00788258 

joel.reese@rm-firm.com 

Joshua M. Russ 

Texas Bar No. 24074990 

josh.russ@rm-firm.com 

750 N. Saint Paul St., Suite 600 

Dallas, TX 75201-3201 

Telephone: (214) 382-9810 

Facsimile: (214) 501-0731 

ATTORNEYS FOR RESPONDENTS 

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FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/30/2021 | OSCAR NO. 601085| Page 3 of 3 | PUBLIC

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CERTIFICATE OF SERVICE 

I hereby certify that on March 30, 2021, I filed the foregoing document 

electronically using the FTC’s E-Filing system, which will send notification to: 

April J. Tabor The Honorable D. Michael Chappell 

Acting Secretary Administrative Law Judge 

Federal Trade Commission Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-113 600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 Washington, DC 20580 

ElectronicFilings@ftc.gov email: oalj@ftc.com 

COMPLAINT COUNSEL: 

Elizabeth Averill 

eaverill@ftc.gov 

Jonathan Cohen 

jcohen2@ftc.gov 

/s/ Joel W. Reese 

Joel W. Reese 

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