UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

 

June 5, 2020 

Via Electronic Mail

The Juice Plus+ Company, 

c/o Paulo Teixeira, CEO

140 Crescent Drive 

Collierville, Tennessee 38017 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Teixeira, 

FTC staff has reviewed social media posts made by The Juice Plus+ Company (“Juice 

Plus”) 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 Juice Plus 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. 

Some examples of Coronavirus prevention or treatment claims made by your business 

opportunity participants or representatives include:

• “I for one will NEVER take a vaccine for the #WuhanVirus #KungFlu. I have 

never had an influenza shot why the hell would I get this one? And I have never 

had the flu as an adult. #JuicePlus @juiceplus” 

• A post with “#juiceplus #immunesupport #immunesystem #covid19” that links to 

another post with an image with the statement, “More than 40 individual Juice 

Plus+ clinical studies have been conducted by researchers at leading hospitals and 

universities around the world” and captioned with “#juiceplus #immunesupport 

#immunesystem #covid19.” 

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

representatives include: 

• A video containing the statements, “There are a lot of people out there who have 

lost income . . . . You may want to build a side income, you know, make $500 a 

month, $1,000 a month or more. There’s no ceiling on this. It’s whatever you 

want it to be. . . . What would you like this do to for you? . . . Maybe it could 

cover one of your bills, like a car payment. Or enjoy more time and financial 

freedom. I can tell you those are both possible at the same time because I’ve been 
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living that for the past eight years, and it’s wonderful to be able to offer that to 

other people.” 

• A video containing the statement, “What would you do—especially now, so many 

people have lost their jobs or their income—if you had an extra $500 to $1,000 a 

month or more? Because it can be whatever you want it to be.”

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,
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Federal Trade Commission Staff