UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TENNESSEE

UNITED STATES OF AMERICA,

Plaintiff,

v.

DALAL A. AKOURY, also d/b/a AWAREmed 

Health and Resource Center;

DALAL AKOURY MD, PLLC, a South 

Carolina limited liability company, also d/b/a 

AWAREmed Health and Resource Center; and

AWAREMED WHOLISTIC URGENT CARE,

PLLC, a South Carolina limited liability 

company, also d/b/a AWAREmed Health and 

Resource Center,

Defendants.

Case No. 2:23-CV-00026

COMPLAINT FOR PERMANENT 

INJUNCTION, CIVIL 

PENALTIES, MONETARY 

RELIEF, AND OTHER RELIEF

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (“FTC”), for its Complaint alleges:

1. Plaintiff brings this action under Sections 5(a)(1), 5(m)(1)(A), 12, 13(b), 16(a), and 

19 of the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §§ 45(a)(1), 45(m)(1)(A), 52, 

53(b), 56(a), and 57b, and Section 8023 of the Opioid Addiction Recovery Fraud Prevention Act 

of 2018 (“Opioid Act”), 15 U.S.C. § 45d, to obtain a permanent injunction, civil penalties, and 

other relief for violations of the FTC Act and the Opioid Act committed by Defendants Dalal A. 

Akoury, Dalal Akoury MD, PLLC, and AWAREmed Wholistic Urgent Care, PLLC.

2. Defendants operate the AWAREmed Health and Wellness Resource Center 

(“AWAREmed”), which purports to offer medical and other treatment services to those suffering 

from addiction (including substance use disorders), cancer, and chronic illnesses such as 

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Parkinson’s disease and Alzheimer’s disease. Since at least early 2018, Defendants have used 

several advertising platforms to recruit prospective patients, misleadingly claiming, among other 

things, that virtually every patient treated for any condition improves under AWAREmed’s care. 

In reality, Defendants lacked any reasonable basis for making these advertising claims to the 

public. Defendants were warned by the FTC on multiple occasions that it is unlawful to make false 

and unsubstantiated claims in connection with advertising. Nevertheless, Defendants continued to 

disseminate misleading advertising claims. Therefore, Plaintiff files this lawsuit to recover civil 

penalties and to permanently halt the Defendants’ deceptive advertising.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 

1331, 1337(a), 1345, and 1355, because it involves claims arising under federal laws regulating 

commerce and is commenced by the United States. 

4. Venue is proper in this District under 28 U.S.C. §§ 1391(b)(2) and 1395(a), as well 

as 15 U.S.C. § 53(b), because Defendants transact business in this District and a substantial part 

of the events or omissions giving rise to the claims occurred in this District. 

DEFENDANTS

5. Defendant Dalal A. Akoury, also doing business as AWAREmed, has a primary 

business address of 1604 Lamons Lane, #202, Johnson City, Tennessee. Akoury’s previous 

business address was 4710 Oleander Drive, Myrtle Beach, South Carolina. Akoury transacts or 

has transacted business in this District and throughout the United States. At all times material to 

this Complaint, acting alone or in concert with others, Akoury has advertised AWAREmed 

treatment services for those suffering from addiction (including substance use disorders), cancer, 

Parkinson’s disease, and Alzheimer’s disease, within this District and throughout the United 

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States. Akoury is the sole proprietor of and medical provider for AWAREmed, which operated in 

South Carolina until 2020 when it was relocated to Tennessee. Akoury has the sole responsibility 

for reviewing and evaluating health claims made on the awaremed.com website, and on social 

media such as the AWAREmed Facebook page. 

6. Defendant Dalal Akoury MD, PLLC (“Akoury PLLC”), is a professional limited 

liability company organized by Akoury in the state of South Carolina. Akoury is its sole officer

and owner. At all times material to the allegations in this Complaint, acting alone or in concert 

with others, Akoury PLLC has also done business as AWAREmed. Akoury has formulated, 

directed, controlled, had the authority to control, or participated in the acts and practices of Akoury 

PLLC, including the acts and practices set forth in this Complaint. In connection with the matters 

alleged herein, Akoury PLLC transacts or has transacted business in this District and throughout 

the United States.

7. Defendant AWAREmed Wholistic Urgent Care, PLLC (“AWAREmed PLLC”) is

a professional limited liability company organized by Akoury in the state of South Carolina. 

Akoury and her husband, Samy Akoury, are the sole officers and owners of AWAREmed PLLC. 

Upon information and belief, at all times material to the allegations in this Complaint, acting alone 

or in concert with others, AWAREmed PLLC has also done business as AWAREmed. Akoury has 

formulated, directed, controlled, had the authority to control, or participated in the acts and 

practices of AWAREmed PLLC, including the acts and practices set forth in this Complaint. In 

connection with the matters alleged herein, AWAREmed PLLC transacts or has transacted 

business in this District and throughout the United States.

8. At all times material to the allegations in this Complaint, Akoury has had all 

decision-making authority over Akoury PLLC and AWAREmed PLLC, and upon information and 

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belief, both companies play integral parts in AWAREmed’s business. Akoury PLLC pays 

AWAREmed clinic expenses and receives clinic receipts. AWAREmed PLLC lends its name to 

AWAREmed’s advertising and website.

COMMERCE

9. At all times material to this Complaint, Defendants have maintained a substantial

course of trade in or affecting commerce, as “commerce” is defined in Section 4 of the FTC Act,

15 U.S.C. § 44. 

THE FTC ACT

10. Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), prohibits “unfair or deceptive acts 

or practices in or affecting commerce.” 

11. Misrepresentations or deceptive omissions of material fact constitute deceptive acts 

or practices prohibited by Section 5(a) of the FTC Act.

12. Section 12 of the FTC Act, 15 U.S.C. § 52, prohibits the dissemination of any false 

advertisement in or affecting commerce for the purpose of inducing, or which is likely to induce, 

the purchase of food, drugs, devices, services, or cosmetics. The offering for sale and sale of 

Defendants’ purported disease treatments are “services” for purposes of Section 12. 

THE OPIOID ACT

13. The Opioid Act, Pub. L. No. 115-271, 15 U.S.C § 45d, was enacted on October 24, 

2018. The Opioid Act prohibits unfair or deceptive acts or practices with respect to any substance 

use disorder treatment service or substance use disorder treatment product. 15 U.S.C. § 45d(a). 

Section 8022 of the Opioid Act defines “substance use disorder treatment service” as “a service 

that purports to provide referrals to treatment, treatment, or recovery housing for people diagnosed 

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with, having, or purporting to have a substance use disorder, including an opioid use disorder.” 

Pub. L. No. 115-271 § 8022. 

14. Pursuant to 15 U.S.C. § 45d(b)(1), a violation of 15 U.S.C. § 45d(a) is treated as a 

violation of an FTC rule under Section 18(a) of the FTC Act, 15 U.S.C. § 57a(a), regarding unfair 

or deceptive acts or practices.

DEFENDANTS’ UNLAWFUL CONDUCT

15. Since at least early 2018, Defendants have advertised medical and other treatment 

services to patients suffering from addiction (including substance use disorders), cancer, and other 

chronic diseases, including Parkinson’s disease and Alzheimer’s disease. Defendants have 

promoted these services, which are provided by AWAREmed, through the awaremed.com website, 

YouTube videos, social media, and paid media interviews. 

16. To induce prospective customers to use AWAREmed services, Defendants’ have 

claimed that virtually every patient treated for any condition at AWAREmed improves under 

Akoury’s care. Alongside those claims, Defendants provide pricing information and encourage 

viewers to contact AWAREmed to schedule a consultation. 

17. As set forth below, Defendants asserted their advertising claims without any 

reasonable basis for believing they were true at the time the claims were made. Moreover, 

Defendants continued to disseminate their misleading claims despite warnings from the FTC that 

making false and unsubstantiated claims in connection with advertising is unlawful. 

Addiction Recovery Advertising

18. Defendants have advertised the AWAREmed addiction treatment program through 

various advertising platforms, including through the awaremed.com website and YouTube videos 

embedded on that website. The core message of this advertising is that AWAREmed’s addiction 

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treatment program provides quick, painless recovery with greater success and at less cost than 

traditional addiction treatment programs. 

19. Defendants’ awaremed.com website contained numerous implicit or explicit claims 

regarding AWAREmed’s effectiveness at treating addiction generally and substance use disorders 

in particular. For example, Defendants claimed:

a. Alongside the phrase “Addiction Recovery,” that AWAREmed was the

“Most Effective Medical Clinic . . . Anywhere” with “a 98%* Improvement Rate Treating Just 

About . . . Anything.” Ex. A at 1.

b. That “There IS Light at the End of the Tunnel” and that prospective patients

could “Experience Rapid, Painless Detox and Recovery From ANY Addiction” including “Drugs, 

Alcohol, Food, Sex, Gambling.” Id. at 2.

c. That AWAREmed had a “painless detox outpatient program” allowing

patients to return “back-to-work in 3 days for severe addictions of drug, alcohol, food, sex, and 

gambling.” Id. at 3.

d. That the AWAREmed addiction treatment program allowed patients to 

“Detox without pain, illness, sleep-loss, or anxiety.” Id. at 4.

e. That the AWAREmed addiction treatment program allowed for “Rapid 

Recovery” where patients could “Attain work-ready functionality in only 3 days” and “Return 

home again in only 10 days.” Id.

f. That the AWAREmed addiction treatment program was “Affordable” and 

patients could “Get better results in 1/3 the time, at comparable or less cost than other ‘traditional’ 

risky, painful, lower-success 30-day programs.” Id.

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g. That AWAREmed “Offer[s] the ONLY Highly-Discreet 10-Day Outpatient 

Program with a 90% Improvement Rate*.” Id. at 5.

20. Defendants’ website also embedded YouTube videos from “others just like you

who have completed the program.” Id. at 6. One of those videos was captioned “2 Year Methadone 

Addict Painless Withdraw [sic] in 1 Day, Recovers in Just 1 Week.” Id. The video features a 

conversation between Akoury and an individual who reports suffering from methadone addiction 

before being treated at AWAREmed. Among other things, the video includes the following 

testimonial about that individual’s first day at AWAREmed:

Patient: That was a tough day. But that was the only tough day that I ever had. 

By the next day I was a lot better. 

Akoury: Really? It took just one day and the craving was gone? 

Patient: The craving was gone. And within a few days there were no side effects. 

The chills were gone, the aches were gone.

Cancer Treatment Advertising

21. Defendants have also advertised the AWAREmed cancer treatment program

through various advertising platforms, including through the awaremed.com website and YouTube 

videos embedded on that website. The core message of this advertising is that nearly every 

AWAREmed cancer patient improves significantly, with many—including patients with Stage IV 

cancer—becoming cancer-free. 

22. Defendants’ website contained numerous implicit or explicit claims regarding 

AWAREmed’s effectiveness at treating cancer. For example, Defendants claimed:

a. Alongside the phrase “Cancer Remission,” that AWAREmed was the “Most 

Effective Medical Clinic . . . Anywhere” with “a 98%* Improvement Rate Treating Just About . . . 

Anything.” Ex. B at 1. 

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b. That “Virtually everyone, at any stage of illness or condition improves 

moderately to significantly after visiting [AWAREmed’s] clinic. This includes remission of 

illnesses considered by most to be ‘incurable’ such as . . . terminal cancers” and “This is why many 

so [sic] doctors send their patients to AWAREmed, when everything else has failed to help.” Id.

c. That AWAREmed’s “treatments are so fast and effective that the total 

treatment cost is typically a fraction of the typical ‘slow bleed’ approach used by most other clinics 

and hospitals.” Id.

d. Alongside the phrase “Cancer Remission,” that AWAREmed offers “State 

of the art treatment, with compassion” so that a prospective patient could “Improve [their] 

condition or extend [their] life and regain [their] quality of living, pain-free.” Id. at 2.

23. Defendants’ website also embedded YouTube videos, including one captioned 

“Advanced Cancer VS. Advanced Treatment. CANCER LOOSES [sic] . . . Now CANCER 

FREE!” Id. at 3. The video features a conversation between Akoury and several individuals who 

purport to be former patients. One individual states that he is resuming work and global travel, 

while mentioning two other success stories from the AWAREmed program. Another individual 

describes a successful Stage IV cancer patient at the clinic who has resumed her regular work and 

social engagements. Among other things, the video includes the following testimonials:

Male Patient: Particularly when you have two success stories sitting here.

Akoury: Tons!

Male Patient: More than two, right? Yeah. Tons all over the world, I’m sure. Other 

people that--

Akoury: we’ve had here, you’ve seen six or eight within two months--

Female Patient: Six weeks

Akoury: Six weeks you’ve been here. I mean, the six or eight people that have been 

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here, but every single one of them is better. So, somehow better. Somewhere better. 

I mean, we have that young lady, a friend of ours, that graduated so long ago and 

she’s still doing great.

Female Patient: She’s wonderful.

Akoury: Stage four! Much better, right?

Female Patient: She’s great. She had a wonderful Christmas, and parties at her 

house. And--

Akoury: And she’s working.

Female Patient: She’s working full time.

Akoury: She is!

Female Patient: How can you go wrong? So many people don’t even have a clue 

that there is another option. Because when you go to the oncologist, when you’re 

first diagnosed there is such a spirit of fear that comes over the entire room.

24. In another embedded YouTube video captioned “Healing Breast Cancer After a 

‘Cancer Dream,’” Akoury interviews a woman who claims she has just completed her cancer 

treatment and who thanks AWAREmed’s clinic for her success and endorses AWAREmed’s 

treatment over conventional chemotherapy for breast cancer. Id. at 4. Among other things, the 

video includes the following testimonial:

Patient: I’ve been the other route. I went conventional the first time and it didn’t 

work.

Akoury: But do you really think this is helping you, emotionally, mentally, 

physically? Do you -- do you feel improvement?

Patient: Yeah. I feel improvement. I can tell a difference.

Akoury: Tell me something that would make people want to do it. Why? Is it the 

love that is in offices like ours? Is it the treatments? Is it the less side effects? 

What is it?

Patient: All of it. All of those together, really. The less side effects helps. Having 

-- Not having the caustic poisons going into your system. That’s a big thing for me.

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Alzheimer’s Disease and Parkinson’s Disease Advertising

25. Defendants have also advertised AWAREmed’s chronic disease and pain treatment 

program through various advertising platforms, including through the awaremed.com website and 

YouTube videos embedded on that website. The core message of this advertising is that 

AWAREmed effectively treats, among other things, Parkinson’s disease and Alzheimer’s disease.

26. Defendants’ website contained numerous implicit or explicit claims regarding 

AWAREmed’s effectiveness at treating Parkinson’s disease and Alzheimer’s disease. For 

example, Defendants claimed:

a. That “Virtually everyone, at any stage of illness or condition improves 

moderately to significantly after visiting [AWAREmed’s] clinic. This includes remission of 

illnesses considered by most to be ‘incurable’ such as Parkinson’s [disease and] Alzheimer’s 

[disease]” and “This is why many so [sic] doctors send their patients to AWAREmed, when 

everything else has failed to help.” Ex. C at 1.

b. Alongside the phrase “Chronic Disease & Pain,” that viewers could 

“Eliminate, reduce pain, Heart/cardio, diabetes, cortisol, fiber myalgia [sic], high blood pressure, 

obesity, insomnia, gastro, Parkinson’s [disease] and Alzheimer’s [disease].” Id. at 2.

c. Alongside the phrase “Chronic Disease & Pain,” that AWAREmed is the

“Most Effective Medical Clinic . . . Anywhere” with “a 98%* Improvement Rate Treating Just 

About . . . Anything.” Id. at 3.

Paid Television Advertising

27. Akoury has also paid to appear in numerous news segments on a FOX-affiliated 

local Myrtle Beach television station, WFXB. Those segments featured Akoury being interviewed 

by a news reporter and lasted approximately three to five minutes. 

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28. The segments appeared to be objective news interviews or public information spots 

and were not identifiable as commercial advertising. See Ex. D at 1. At the end of each segment, 

Akoury gave viewers her AWAREmed contact information. 

29. These segments were paid advertisements, but at no point in any of them does the 

station, the interviewer, or Akoury clearly and prominently disclose this fact.

Defendants’ Treatment Claims Are Unsubstantiated

30. Defendants lack any reasonable basis to support their express and implied claims 

regarding the effectiveness of AWAREmed’s treatments. Defendants do not possess any

competent and reliable scientific studies assessing the efficacy of AWAREmed’s treatments, 

including their ability to cure, treat, or mitigate addiction (including substance use disorders), 

cancer, Alzheimer’s disease, or Parkinson’s disease. 

31. Furthermore, there are no competent and reliable scientific studies in the scientific 

literature establishing that Defendants’ treatments are effective to cure, treat, or mitigate addiction 

(including substance use disorders), cancer, Alzheimer’s disease, or Parkinson’s disease

Defendants Refusal to Cease Deceptive Advertising

32. In or around April 2020, AWAREmed received a warning letter from the FTC in 

connection with its COVID-19 treatment and prevention advertising. That letter stated:

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.

33. On April 27, 2021, and again on May 10, 2021, Akoury was notified in writing that 

making false, misleading, or unsubstantiated claims concerning addiction recovery services also

violates the Opioid Act and may be subject to civil penalties. Specifically, the FTC advised 

Akoury:

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Our purpose is to determine whether the Company, as defined in the enclosed CID 

Schedule, you, or other unidentified persons or entities, have made false, 

misleading, or unsubstantiated representations in violation of . . . Section 8023 of 

the Opioid Addiction Recovery Fraud Prevention Act (“OARFPA”) of 2018, 15 

U.S.C. § 45d, in connection with the advertising, marketing, or sale of addiction 

recovery services . . . and whether Commission action to obtain monetary relief, 

including civil penalties under OARFPA, would be in the public interest. 

34. Despite the FTC’s warnings, Defendants continued to disseminate false and 

unsubstantiated advertisements until at least June 16, 2022. 

COUNT 1

Deceptive Substance Use Disorder Treatment Advertising

35. In numerous instances, Defendants have represented, expressly or by implication, 

that:

a. AWAREmed’s addiction treatment program successfully treats every type 

of substance use disorder, including drug and alcohol addiction; 

b. Patients with substance use disorders who enter AWAREmed’s addiction 

treatment program will be ready to return to work in only 3 days, and will be free of their addiction 

in 10 days; 

c. AWAREmed’s addiction treatment program enables individuals with 

substance use disorders to detoxify in 3 days without pain, illness, sleep loss, or anxiety; 

d. Ninety percent of the individuals with substance use disorders who go 

through AWAREmed’s 10-day addiction treatment program recover from their addiction; and

e. AWAREmed’s 10-day addiction treatment program produces better results 

at less cost for individuals with substance use disorders than conventional 30-day recovery 

programs. 

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36. The representations set forth in Paragraph 35 are false or were not substantiated at 

the time the representations were made. 

37. Therefore, the making of the representations as set forth in Paragraph 35 constitutes 

a deceptive act or practice with respect to a substance use disorder treatment service or substance 

use disorder treatment product in violation of Section 8023(a) of the Opioid Act, 15 U.S.C. 

§ 45d(a). 

38. Defendants violated the Opioid Act with the knowledge required by Section 

5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), and are therefore liable for civil penalties. 

COUNT 2 

Deceptive Addiction Treatment Advertising

39. In numerous instances, Defendants have represented, directly or indirectly, 

expressly or by implication, that: 

a. AWAREmed’s addiction treatment program successfully treats every type 

of addiction, including addiction to drugs and alcohol; 

b. Patients who enter AWAREmed’s addiction treatment program will be 

ready to return to work in only 3 days, and will be free of their addiction in 10 days; 

c. AWAREmed’s addiction treatment program enables individuals to detoxify

in 3 days without pain, illness, sleep loss, or anxiety; 

d. Ninety percent of individuals who go through AWAREmed’s 10-day 

addiction treatment program recover from their addiction during that program; and 

e. AWAREmed’s 10-day addiction treatment program produces better results 

at less cost than conventional 30-day recovery programs. 

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40. The representations set forth in Paragraph 39 are false or were not substantiated at 

the time the representations were made. 

41. Therefore, the making of the representations as set forth in Paragraph 39 constitutes

a deceptive act or practice and the making of false advertisements in violation of Sections 5(a) and 

12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

COUNT 3 

Deceptive Cancer Treatment Advertising

42. In numerous instances, Defendants have represented, expressly or by implication, 

that AWAREmed’s cancer treatment program: 

a. Successfully treats all forms of cancer; and 

b. Is more effective than conventional chemotherapy for patients with breast 

cancer. 

43. In numerous instances, Defendants have also represented, expressly or by 

implication, that 98 percent of AWAREmed’s cancer patients, including those with advanced or 

Stage 4 cancer: 

a. Will have their cancer go into remission; or 

b. Will at least experience improved quality and length of life after leaving 

AWAREmed, including being able to resume work and engage in regular social activities.

44. The representations set forth in Paragraphs 42 and 43 are false or were not 

substantiated at the time the representations were made. 

45. Therefore, the making of the representations as set forth in Paragraphs 42 and 43 

constitutes a deceptive act or practice and the making of false advertisements in violation of 

Sections 5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

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COUNT 4 

Deceptive Alzheimer’s Disease and Parkinson’s Disease Advertising

46. In numerous instances, Defendants have represented, expressly or by implication, 

that AWAREmed can successfully treat patients who suffer from Alzheimer’s disease and from

Parkinson’s disease.

47. The representation set forth in Paragraph 46 is false or was not substantiated at the 

time the representation was made. 

48. Therefore, the making of the representation as set forth in Paragraph 46 constitutes 

a deceptive act or practice and the making of false advertisements in violation of Sections 5(a) and 

12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

COUNT 5 

Deceptively Formatted Advertising

49. In numerous instances, Defendants have represented, expressly or by implication, 

that some of Akoury’s appearances on local FOX news television station WFXB were objective 

news or informational programming.

50. In truth and in fact, in numerous instances, Akoury’s television appearances were 

not objective news or informational programming; they were paid commercial advertising. 

Therefore, the making of the representation set forth in Paragraph 49 constitutes a deceptive act or 

practice and the making of false advertisements in or affecting commerce, in violation of Sections 

5(a) and 12 of the FTC Act, 15 U.S.C. §§ 45(a) and 52. 

CONSUMER INJURY

51. Consumers are suffering, have suffered, and will continue to suffer substantial 

injury as a result of Defendants’ violations of the FTC Act and the Opioid Act. Absent injunctive 

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relief by this Court, Defendants are likely to continue to injure consumers, reap unjust enrichment,

and harm the public interest. 

THE COURT’S POWER TO GRANT RELIEF

52. Section 13(b) of the FTC Act, U.S.C. § 53(b), empowers this Court to grant 

injunctive and such other relief as the Court may deem appropriate to halt and redress violations 

of any provision of law enforced by the FTC, including the FTC Act and the Opioid Act.

53. Section 5(m)(1)(A) of the FTC Act, 15 U.S.C. § 45(m)(1)(A), as modified by 

Section 4 of the Federal Civil Penalties Inflation Adjustment Act of 1990, 28 U.S.C. § 2461, the 

Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, Pub. L. No. 114-74 

§ 701, 129 Stat. 599 (2015), and Section 1.98(d) of the FTC’s Rules of Practice, 16 C.F.R. § 

1.98(d), authorizes this Court to award monetary civil penalties of not more than $50,120 for each 

violation of the Opioid Act committed with actual knowledge or knowledge fairly implied. 

54. Each dissemination of an advertisement in which Defendants violated the Opioid 

Act by making one or more of the deceptive representations described occurring after October 24, 

2018, constitutes a separate violation for which Plaintiff seeks monetary civil penalties.

55. Section 19(b) of the FTC Act, 15 U.S.C. § 57b(b), and Section 8023(b) of the 

Opioid Act, 15 U.S.C. § 45d(b), authorize this Court to grant such relief as the Court finds 

necessary to redress injury to consumers resulting from Defendants’ violations of the Opioid Act, 

including rescission or reformation of contracts, the refund of money or return of property, the 

payment of damages, and public notification respecting Defendants’ violations, or unfair or 

deceptive acts or practices.

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PRAYER FOR RELIEF

Wherefore, Plaintiff requests that the Court:

A. Enter judgment against Defendants in favor of Plaintiff for each violation of the 

FTC Act and the Opioid Act alleged in this Complaint;

B. Enter a permanent injunction to prevent future violations of the FTC Act and the 

Opioid Act by Defendants; 

C. Award Plaintiff monetary civil penalties from Defendants for each violation of the 

Opioid Act alleged in this Complaint;

D. Award monetary and other relief within the Court’s power to grant; and 

E. Award any additional relief the Court determines to be just and proper. 

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Dated: March 16, 2023

Of Counsel: 

SERENA VISWANATHAN 

Associate Director

RICHARD A. QUARESIMA

Assistant Director

JAMES A. PRUNTY 

SHIRA MODELL

ELIZABETH JONES SANGER

Attorneys 

Division of Advertising Practices

Federal Trade Commission

600 Pennsylvania Avenue, N.W. 

Mail Stop CC-5201 

Washington, D.C. 20580 

Tel: 202-326-2438 (Prunty) 

Tel: 202-326-3116 (Modell) 

Tel: 202-326-2757 (Sanger) 

jprunty@ftc.gov 

smodell@ftc.gov 

esanger@ftc.gov 

Respectfully submitted,

FOR THE UNITED STATES OF AMERICA:

BRIAN M. BOYNTON

Principal Deputy Assistant Attorney General 

Civil Division

ARUN G. RAO 

Deputy Assistant Attorney General

AMANDA N. LISKAMM 

Director 

Consumer Protection Branch 

GABRIEL H. SCANNAPIECO

Assistant Director 

Consumer Protection Branch 

 /s/ Zachary L. Cowan 

ZACHARY L. COWAN (NCBN #53432)

AMY P. KAPLAN (DCBN #1010279) 

Trial Attorneys 

Consumer Protection Branch 

U.S. Department of Justice 

450 5th Street, N.W. 

Washington, D.C. 20530 

Tel: 202-353-7728 (Cowan) 

Tel: 202-598-8153 (Kaplan) 

Fax: 202-514-8742 

Zachary.L.Cowan@usdoj.gov 

Amy.P.Kaplan@usdoj.gov 

FRANCIS M. HAMILTON III

United States Attorney

Ben D. Cunningham (TN BPR #030122) 

Alexa Ortiz Hadley (TN BPR #036892) 

Assistant United States Attorneys

800 Market Street, Suite 211 

Knoxville, Tennessee 37902 

Tel: 865-545-4167 

Ben.Cunningham@usdoj.gov 

Alexa.Hadley@usdoj.gov

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