UNITED STATES OF AMERICA 

Federal Trade Commission 

WASHINGTON, D.C. 20580 

April 24, 2020 

Via Electronic Mail 

Tranont 

c/o Lorne Berry, CEO 

3451 N. Triumph Blvd. 

Garden Level 

Lehi, Utah 84043 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Mr. Berry, 

FTC staff has reviewed social media posts made by Tranont 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 Tranont 

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: 

 “You’ll need a strong immune system to fight Coronavirus. Get great plant based 

supplements to help support your immune system and the systems of your family 

members.” 

 “Fight the Corona virus by building up your immune system. NEW products 

available now.” 

 “Fight corona virus with beneficial Nitric Oxide (NO) in your body with L-argine 

AAKG and plant based compounds that produce and protect Nitrix Oxide 

production.” 

 “NEW PRODUCT. TECHNO BOOST can help you fight Coronavirus. Order 

yours today.” 

 “Did you know the Coronavirus is a nucleoprotein and other viruses are made up 

of viral proteins? Well I have Restore, Restore is a proteolytic enzyme which 

breaks down proteins. Get yourself some Restore to help you break down the 

proteins in your body.” 
 

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

representatives include: 

 “Maybe some of us have lost our jobs or are trying to figure out how we’re paying 

for childcare now. . . . What I’m going to share with you is something that . . . 

even with the crazy economy, you can build something massive.” [38 minutes 

later] “Whether you want to make an extra $600 a month, an extra $10,000 a 

month, or you want to make over $1 million a year, you can do that...” [5 minutes 

later] “The economy is a little bit unstable right now. . . . This is a way for you to 

have a plan B—for you to take control of whatever it is that you’re looking for. 

Maybe it’s to retire. Maybe it’s to get out of debt. Maybe it’s to pay for college 

. . . . You have an opportunity to take advantage of something massive and help 

people give gifts to everybody that you know: a health gift and financial 

freedom.” 

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. 

2 
 

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 

3