EXHIBIT H

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United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580

Serena Viswanathan

Acting Associate Director 

 Division of Advertising Practices 

July 29, 2020

WARNING LETTER

VIA EMAIL TO customer.care@xlear.com, facebook@xlear.com

Xlear Inc.

723 S Auto Mall Dr

American Fork, UT 84003

Re: Unsubstantiated claims for Coronavirus prevention or treatment

To Whom It May Concern:

This is to advise you that FTC staff reviewed your website at https://xlear.com/xlear/ on

July 24, 2020. We also reviewed your social media website at 

www.facebook.com/xylitol.experts/ and your YouTube channel at 

https://www.youtube.com/channel/UCHq_XCdQIFfAf0L-_X6dJfg, where you direct consumers 

to your website, https://xlear.com/xlear/, to purchase Xlear Sinus Care nasal sprays. We have 

determined that you are unlawfully advertising that certain products prevent Coronavirus Disease 

2019 (COVID-19).

Some examples of Coronavirus prevention or treatment claims include:

Your web page https://xlear.com/xlear/ states:

“XYLITOL SINUS STUDIES

Xylitol and Upper Respiratory Health: 5 Studies You Should Know

READ THE STUDIES” [links to https://www.dontgetsickclub.com/studies, which 

states:]

“USU Study Summary/Synopsis

Virucidal Activity of Xlear Compounds vs SARS-CoV-2 Virus and Rhinovirus-16 -

Jonna B. Westover, Ph.D., Utah State University, Institute for Antiviral Research

Overview:

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At Utah State University’s Institute of Antiviral Research, Jonna Westover, Ph.D. and her 

team performed a study to identify if a xylitol saline solution had any effect on COVID19.

Results:

The study compared the effect of four different saline solutions with xylitol against 

chlorhexidine and ethanol, with water as a control. The four different solutions with 

xylitol were: 1) saline and xylitol alone, 2) saline and xylitol with added essential oils1, 

3) saline and xylitol with essential oils and liquid silver, and 4) saline and xylitol with 

chlorpheniramine maleate. The results were astounding. Each of the four saline and 

xylitol solutions significantly reduced the virus to ‘an undetectable amount.’

Why is this important? 

With government agencies and pharmaceutical companies pumping so much money and 

energy into finding a solution for COVID-19, this study shows a simple, safe, and cheap 

option that could be an effective solution to the pandemic.”

In a video titled, “There is a Simpler, Cheaper Way to Deal with COVID-19,” posted on

the Xlear Inc YouTube channel on July 21, 2020, you state:

Text of video description: “Xlear Inc

While billions of dollars are being spent to find a vaccine for COVID-19, medical 

professionals and researchers may have found a better way to treat the virus--a simple, 

natural nasal spray.”

Text of video: “We are spending billions on a COVID-19 vaccine but is there a simpler, 

less expensive way? More and more medical professionals and researchers realize 

treating COVID-19 through the NOSE is the best option....

Senior co-author of the UNC Chapel Hill study, Dr. Richard Boucher: ‘If the nose is the 

dominant initial site from which lung infections are seeded, then... nasal irrigation or 

antiviral nasal sprays, could be beneficial.’

90% of viral load is in the nose. If washing hands is so important, shouldn’t you...

WASH YOUR NOSE? For the best nasal cleanse, choose Xlear Sinus Care [graphic 

shows bottle of Xlear sprayed into a nose and Coronavirus-type molecules disappearing 

from inside the nose].

A Utah State University study found that a nasal spray like Xlear reduced the COVID-19

virus to ‘an undetectable amount’ in 15 minutes.

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Breathe Better. Feel Better with Xlear Sinus Care.”

[https://www.youtube.com/watch?v=qgi_MPvXeNQ]

“As Coronavirus cases rise in many states, Dr Jones suggests washing your nose with 

xylitol to subdue COVID-19. ‘Your nasal passages are a primary defense against 

viruses, especially if they’re working optimally...xylitol-saline washes and hydrates 

the nasal mucosa to assist the immune system in cleaning out bacteria viruses, and 

pollutants before they have a chance to infiltrate the lungs.’ - Dr. Jones...

[links to an article titled, “Immune Intelligence in a Time of Coronavirus” at 

https://goodmenproject.com/featured-content/immune-intelligence-in-a-time-ofcoronavirus/]

#Xlear #LiveXlear #Covid19 #Coronavirus”

[post dated July 16, 2020 on www.facebook.com/xylitol.experts/]

“Researchers at the University of North Carolina conducted a major study of the 

coronavirus infection in human airways. The finding suggest [sic] the virus tends to 

become established first in the nasal cavity. 

Besides washing your hands frequently and avoiding touching your face, you need to 

wash your nose too! 

Check out this to learn more: https://unc.live/3fxxEIt [link to an article titled, 

“Researchers map how coronavirus infection travels through cells of nasal cavity and 

respiratory tract”] #Xlear #LiveXlear #Coronavirus #Covid19”

[post dated June 18, 2020 on www.facebook.com/xylitol.experts/]

“In this craziness surrounding #Covid19, we all know washing our hands and social 

distancing is a great way to avoid the virus. But it's also extremely important to keep 

your airways hydrated. Xlear is an awesome product to help. It's [sic] xylitol 

ingredient can literally help wash away a virus! Let's all do our part to combat this 

thing and get back to life as we know it. Go get your #Xlear today! - @ross_stripling

#LiveXlear”

[post dated April 14, 2020 on www.facebook.com/xylitol.experts/] “Naturopathic Family Health has a couple recommendations to prevent the spread of 

#COVID19. Besides washing your hands frequently and avoid touching your face, they 

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recommend using @Xlear to clear your nose passages. The nose is a major entry for 

respiratory viruses and is important to keep clean! #LiveXlear”

[post dated March 19, 2020 on www.facebook.com/xylitol.experts/]

It is unlawful under the FTC Act, 15 U.S.C. § 41 et seq., to advertise that a product 

or service 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 product identified above. Thus, any 

coronavirus-related prevention claims regarding such products are not supported by 

competent and reliable scientific evidence. You must immediately cease making all such 

claims.

You are also advised to review all other claims for your products and services and 

immediately cease making claims that are not supported by competent and reliable scientific

evidence.

Within 48 hours, please send a message to Richard Cleland, Assistant Director via 

electronic mail at rcleland@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 Richard Cleland at 202-326-3088.

Very truly yours,

Serena Viswanathan

Acting Associate Director

Division of Advertising Practices

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