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COURTNEY A. ESTEP (pro hac vice) 

cestep@ftc.gov; (202) 326-2788 

SHIRA D. MODELL (pro hac vice) 

smodell@ftc.gov; (202) 725-2162 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Fax: (202) 326-3259 

Aaron Schue (Local Counsel) (Bar No. 338760) 

aschue@ftc.gov; (310) 824-4306

Federal Trade Commission 

10990 Wilshire Blvd., Suite 400 

Los Angeles, CA 90024 

Fax: (310) 824-4380 

ATTORNEYS FOR PLAINTIFF 

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

FEDERAL TRADE COMMISSION, 

Plaintiff,

v. 

REJUVICA LLC, a California limited 

liability company, also d/b/a Rejuvica 

Health; 

KYLE ARMSTRONG, individually 

and as an owner, officer, or member of 

Rejuvica LLC; and

KYLE DILGER, individually and as 

an owner, officer, or member of 

Rejuvica LLC, 

Defendants.

Case No. 8:23-cv-1286

COMPLAINT FOR 

PERMANENT INJUNCTION,

MONETARY RELIEF, AND

OTHER RELIEF 

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 1 of 21 Page ID #:1
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Plaintiff, the Federal Trade Commission (“FTC”), for its Complaint alleges:

1. The FTC brings this action under Sections 5(a)(1), 12, 13(b), and 19 of the 

FTC Act, 15 U.S.C. §§ 45(a)(1) 52, 53(b), and 57(b), and Section 8023 of the 

Opioid Addiction Recovery Fraud Prevention Act of 2018 (“OARFPA”), P.L. 115-

271, 15 U.S.C § 45d, to obtain permanent injunctive relief, monetary relief, and 

other relief for Defendants’ acts or practices in violation of Sections 5(a) and 12 of 

the FTC Act and Section 8023 of OARFPA. Defendants’ OARFPA violations are 

in connection with the marketing of Sobrenix Advanced Alcohol Support 

(“Sobrenix”). 

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 

1337(a), and 1345.

3. Venue is proper in this District under 28 U.S.C. § 1391(b)(2) and (d) and 15 

U.S.C. § 53(b). 

PLAINTIFF

4. The FTC is an independent agency of the United States Government created 

by the FTC Act, which authorizes the FTC to commence this district court civil 

action by its own attorneys. 15 U.S.C. §§ 41–58. The FTC enforces Section 5(a) 

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

practices in or affecting commerce. The FTC also enforces Section 12 of the FTC 

Act, 15 U.S.C. § 52, which prohibits false advertisements for food, drugs, devices, 

services, or cosmetics in or affecting commerce. The FTC also enforces OARFPA, 

which prohibits unfair or deceptive acts or practices in connection with substance 

use disorder treatment products and services.

DEFENDANTS

5. Corporate Defendant Rejuvica LLC (“Rejuvica”), also d/b/a Rejuvica

Health, is a California limited liability company with its principal place of business 

at 17791 Mitchel North, Ste C., Irvine, California 92614. Rejuvica transacts or has 

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transacted business in this District and throughout the United States. At times 

relevant to this Complaint, acting alone or in concert with others, Rejuvica has 

advertised, marketed, distributed, or sold numerous products, most of which are 

liquid tinctures, to consumers throughout the United States. 

6. Defendant Kyle Armstrong (“Armstrong”) owns 50 percent of Rejuvica and 

is the company’s Chief Executive Officer. At all times material to this Complaint, 

acting alone or in concert with others, Defendant Armstrong has formulated, 

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

practices of Rejuvica, including the acts and practices set forth in this Complaint. 

Defendant Armstrong is actively involved in directing the company’s business 

affairs and formulating corporate policy and strategic decisions. He manages and 

is responsible for approving the company’s website design and copy, managing 

Rejuvica’s advertising staff, and approving the company’s advertising copy. 

Defendant Armstrong resides in this District and, in connection with the matters 

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

the United States.

7. Defendant Kyle Dilger (“Dilger”) owns 50 percent of Rejuvica and is the 

company’s Chief Operating Officer. At all times material to this Complaint, acting 

alone or in concert with others, Defendant Dilger has formulated, directed, 

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

Rejuvica, including the acts and practices set forth in this Complaint. Defendant 

Dilger is actively involved in directing the company’s business affairs and 

formulating corporate policy and strategic decisions. He manages and is 

responsible for approving advertising copy and design and manages Rejuvica’s 

advertising, purchasing, and placement decisions. In connection with the matters 

alleged herein, Defendant Dilger transacts or has transacted business in this 

District and throughout the United States.

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COMMERCE

8. At all times relevant 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.

DEFENDANTS’ BUSINESS ACTIVITIES

9. Defendants manufacture, label, advertise, offer for sale, and sell herbal 

tinctures, including products marketed to provide various health benefits. 

10. Since at least 2017, Defendants manufactured, labeled, advertised, offered 

for sale, and sold Sobrenix to consumers. Defendants claimed that Sobrenix was 

designed to reduce or eliminate alcohol cravings and manage alcohol consumption. 

Defendants ceased selling the product in 2021 after the FTC notified the company 

it was investigating advertising claims for Sobrenix.

11. Sobrenix contained a blend of kudzu root, milk thistle seed, angelica root, 

chanca piedra herb, artichoke leaf, and dandelion root, and also contained Vitamins 

B6 and B12, Thiamin, and Folic Acid. The Sobrenix label advised users to “take

[Sobrenix] once daily in the morning and then 30 minutes before drinking, or any 

time you have cravings.” Exhibit A. 

12. Defendants sold Sobrenix through their own website, Amazon.com, and 

Walmart, and charged $34.00 for a 2-ounce bottle of Sobrenix.

13. Defendants advertised Sobrenix through various means, including through 

Internet advertising on Amazon.com, the Sobrenix website, the Rejuvica website, 

and a website designed to appear to be an independent review website, which was 

in fact owned and operated by Rejuvica; and through television appearances by 

paid spokespersons disguised as news content. The core message of the 

advertising was that Sobrenix eliminated cravings for alcohol and enabled users to 

reduce or eliminate their consumption of alcohol, thereby controlling unwanted 

drinking and treating alcohol use disorder or the symptoms of alcohol use disorder. 

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14. Defendants disseminated or caused to be disseminated advertisements for 

Sobrenix, including, but not limited to, the attached Exhibits B through K. Those 

advertising materials contained the following statements and depictions, among 

others:

A. Amazon.com (Exhibit B): 

o “STRUGGLING TO CONTROL YOUR ALCOHOL 

CONSUMPTION? Sobrenix is designed to reduce 

alcohol cravings and help you detoxify your body so you 

can successfully manage alcohol consumption. Even 

better, taken before drinking, Sobrenix’s ingredients help 

you stop before you’ve had too much.” 

B. Amazon.com (Exhibit C): 

o “After a week and a half or so, I no longer have the 4 pm 

cravings and the car doesn’t automatically drive to the 

liquor store after work anymore.”

C. Sobrenix Website (Exhibit D): 

o “Are You Ready To Stop Cravings Once And For All?”

o “Imagine A Solution To STOP Cravings In Their 

Tracks”

o

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o “Get The Life You Deserve With Sobrenix” 

o Voiceover from embedded video (Exhibit E): 

Does alcohol negatively affect your life? Do you find 

yourself drinking more than you want to? Waking up 

with regrets from the night before? Has alcohol 

affected relationships with friends and family or hurt 

your job performance?....Almost 30% of Americans 

admit to having trouble with controlling alcohol 

consumption at some point in their lives....Whether 

it’s a big problem or a small problem, there’s no 

shame in admitting alcohol has more control on your 

life than you want it to. There’s a huge genetic 

component to alcoholism, as well, so on some level 

it’s not your fault....Here’s the good news: there’s a 

natural, inexpensive way to help you take back control 

of your alcohol use. It’s not a time-consuming 12-

step program, it’s not hypnosis, and it’s not an 

expensive rehab center, either. It’s the safe, healthy, 

all-natural option that thousands of those in the know 

successfully use to help get a handle on their alcohol 

consumption or quit altogether without turning their 

lives upside down.... Formulated by top health 

experts and researchers, with a half-million dollar 

budget.... This formula has shocked thousands who 

now, for the first time in years, find themselves able 

to stop drinking when they want to. The most 

common feedback from Sobrenix users is “When I 

take Sobrenix, I just don’t feel like drinking.”.... 

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Here’s how Sobrenix’s three-step process works... 

The third step is Sobrenix’s secret weapon....Step 

three: craving killer kudzu makes moderation easy....

Imagine cutting your alcohol consumption in half and 

imagine how much better you’d feel and how much 

more you could accomplish! Best of all [in the 

Harvard study] kudzu cut drinking in half for a group 

that wasn’t even trying to moderate their drinking; 

imagine how much it would help someone like you, 

who is focusing on it.... So, to put it all together, 

Sobrenix is the premier alcohol management formula, 

with three goals in mind....most importantly, help 

reduce your desire to drink. Getting your alcohol use 

under control by using Sobrenix, you can start to live 

life to the fullest again....Give Sobrenix a shot today, 

and break free from the ball and chain of alcohol once 

and for all.”

D. AlcoholSupportSupplements.com (Exhibit F)

o “If you’re looking for a better craving support 

supplement, look no further!” 

o “If you’ve had trouble with drinking, you’re certainly not 

alone. Almost 30% of Americans admit to having 

trouble with their alcohol consumption at some point in 

their lives, and 14% said they had two or more symptoms 

of alcohol use disorder.

The point at which alcohol becomes a serious problem is 

different for each individual. For some, they simply want 

to cut back. For others, they want to curb their alcohol 

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cravings. And lastly, some want to give up alcohol 

together.” 

o “How Do I know if I Need to Control My Drinking?” 

o “Does alcohol negatively affect your life?”

o “Are There Any Natural Supplements that Help with 

Alcohol Control?”

o The website purported to review five alcohol support 

supplements. Sobrenix received the highest rating of the 

five products reviewed, 94% out of 100%, and was 

described as the “clear winner.” 

Sobrenix Advertising Masquerading as Objective News Content

15. Defendants also advertised Sobrenix through appearances on local television 

news stations in the United States and Canada by paid spokespersons. 

16. In April 2019, Rejuvica entered into an Agreement for Services (“AFS”) 

with Media Relations, Inc., also d/b/a Media Relations Agency (collectively, 

“MRI”), to produce a publicity campaign for Sobrenix. The AFS called for MRI to 

secure media placements for Sobrenix on various mediums, including television. 

These media placements are often referred to as “earned media,” which is publicity 

gained from methods other than traditionally paid advertising. 

17. MRI prepared a Campaign Communications Overview for Sobrenix. The 

Overview set forth the “Top 3 Primary Value Points or Key Messaging Themes,” 

the first of which was “Sobrenix is an herbal tincture designed to help those who 

want to regain control of their alcohol consumption but struggle with alcohol 

cravings.” 

18. Defendants Armstrong and Dilger were MRI’s main contacts at Rejuvica

during the course of the Sobrenix publicity campaign. Defendant Armstrong 

worked with MRI on product messaging, while Defendant Dilger analyzed the 

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impact of the MRI publicity campaign on Sobrenix sales, and authorized payment 

of all MRI invoices.

19. MRI engaged Bryce Wylde (“Wylde”), a Canadian alternative health 

“expert,” and Jonny Bowden (“Bowden”), a board-certified nutritionist, as the 

spokespersons for the Sobrenix campaign. MRI secured television appearances on 

various networks in markets in the United States and Canada pursuant to the AFS, 

designed to appear to be general interest segments, but that were in reality 

appearances of Rejuvica’s paid spokespersons promoting Sobrenix. 

20. MRI billed Rejuvica for Wylde’s and Bowden’s travel and hotel 

accommodations, as well as “honoraria” for their appearances. MRI also billed 

Rejuvica for each television “placement” it secured for Wylde and Bowden, which 

served as MRI’s compensation for securing the placement. Defendant Dilger 

approved and paid each MRI invoice.

21. Wylde appeared on at least seven television news programs. At no time 

during any of his television appearances did Wylde state that he was being paid to 

promote Sobrenix. During these segments, in which a bottle of Sobrenix was 

clearly shown on camera, Wylde touted the ability of Sobrenix to reduce alcohol

consumption. In some of those appearances, he also stated that Sobrenix reduced 

cravings for alcohol; in others, he said Sobrenix had been proven to reduce alcohol 

consumption. Illustrative efficacy claims made in various TV markets include:

A. San Antonio (Exhibit G): 

“Studies show – a Harvard study actually showed – that when 

these college students were allowed to drink as much beer as 

they wanted but half of them took this kudzu, this Sobrenix, 

before drinking, the other half took a placebo. It turned out that 

the group that took the kudzu plant extract Sobrenix, before 

drinking, drank half. They drank 50% as much when allowed 

to drink as much as they wanted. So effortless. [describes 

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putting a couple of drops of Sobrenix in water and drinking it 

all day, and advising his patients to do the same] You’ll notice 

your cravings for alcohol just go right down.” 

B. Toronto (Exhibit H): 

“Sobrenix. . .did a double-blinded, placebo-controlled Harvard 

trial, so this is legit stuff, two pools, students, college students. . 

.One group got water, the other group got this stuff [pointing to 

Sobrenix bottle.] The group that was active, that got this kudzu 

ingredient, they drank half as much at free will, half as much. . 

.it cuts cravings.”

C. Houston (Exhibit I): 

“[Taking Sobrenix a half hour before drinking] is going to 

reduce your cravings for alcohol and have you drinking less ...”

D. Denver (Exhibit J): 

“Harvard study – they double-blind, placebo controlled, two 

groups, college students – they said ‘go and drink as much as 

you want’...one was given Sobrenix. They didn’t drink nearly 

as much alcohol...wonderful stuff.”

22. Rejuvica’s Director of Marketing emailed that Wylde’s Toronto appearance 

was “basically a Sobrenix commercial.” Defendant Armstrong directed employees 

to post the video on the Sobrenix landing page, which they did, without disclosing 

that Wylde was a paid spokesperson for the company. 

23. Rejuvica also embedded an excerpt of several of Wylde’s video appearances 

on Amazon.com without disclosing that Wylde was a paid spokesperson for the 

company. 

24. MRI advised Defendants to promote a Wylde TV appearance by treating it 

as if it were a surprise. In an email from MRI to Defendants, MRI said, “now we 

want to make sure that when we amplify [a Wylde TV appearance promoting 

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Sobrenix] we keep it true to being earned media[,] not advertising. We will 

accomplish by treating like it was a pleasant surprise to be included in a segment 

on the power of plants and cravings[.]” Defendants implemented the suggested 

strategy by posting a video of one of Wylde’s television appearances on the 

company’s Facebook page, along with the statement: 

“I wanted to share a recent (dated November 2020) local news 

segment from WOAI San Antonio featuring Bryce Wylde 

talking about dopamine levels, cravings, Kudzu, and sobrenix 

(sic) itself! 

Give it a watch!”

Defendants did not disclose anywhere in the post that Wylde was a paid 

company spokesperson.

25. Pursuant to Rejuvica’s agreement with MRI, Bowden appeared on at least 

two television programs promoting Sobrenix. At no time during any of his 

television appearances did Bowden state that he was being paid to promote 

Sobrenix. During at least one of these segments, in which a bottle of Sobrenix was 

clearly shown on camera, Bowden touted the ability of Sobrenix to reduce the 

desire to drink alcohol. Bowden also referred to Sobrenix being tested in the 

Harvard study. (Exhibit K) 

26. Rejuvica embedded excerpts of video appearances by Wylde and Bowden 

on the Sobrenix website without disclosing that Wylde and Bowden were paid 

spokespersons for the company. For example, Rejuvica stated: 

“Sobrenix was recently featured on KATU & CITY TV

Our product was recognized by health experts Jonny Bowden & 

Bryce Wylde as a product to help reduce and control cravings. We 

are so excited to share this video with you!” (Exhibit D). 

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Fake Review Websites For Sobrenix and Other Products

27. In 2016, Defendants Armstrong and Dilger jointly decided to create and 

launch dozens of websites that falsely purported to provide objective reviews of 

health-related products, including Sobrenix and other health-related tinctures. 

Defendant Armstrong drafted the content of these websites (hereafter “product 

comparison websites”), and none of the products was reviewed by anyone with 

expertise in the relevant medical field or anyone unconnected with Rejuvica. The 

websites included “AlcoholSupportSupplements.com,”

“LiverSupportReviews.com,” “MaleVitalityReport.com,” “ThyroidRemedy.com,” 

and “NerveRemedyReviews.com,” among others. (Examples of such websites are 

attached as Exhibits F and L-O.) These fake review websites shared a number of 

common features including the following: 

A. A badge at the top of the website stating that the content was an 

“expert review,” despite the fact that no expert reviewed any of 

the content Rejuvica posted to any of the product comparison 

websites; 

B. A statement that the review had been posted by “Paul 

Grudnitsky” (a fictional pen name used by a member of 

Rejuvica’s marketing staff), or had been “Written by the 

Editors,” or “By Editors at [the name of the website]” or 

“Posted by the Senior Editor at [the name of the website]” 

(emphasis in original), rather than a truthful statement that 

Rejuvica owned the website and wrote its content; 

C. Ratings for five products purportedly reviewed on each site, 

which included identical descending percentages or star ratings 

for the reviewed products, and always listed the Rejuvica 

product as obtaining the highest score: a 94% score (or 5/5 

stars) for the first place product; 82% (or 4/5 stars) for the 

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second place product; 63% (or 3/5 stars) for the third place 

product; 41% (or 2/5 stars) for the fourth place product; and 

31% (or 1/5 stars) for the fifth place product; 

D. Nearly identical criteria against which the products in question 

were purportedly evaluated (including liquid formulation, 24-

hour customer support, and a 100% return policy), all of which 

the Rejuvica product always met;

E. First place and the “Gold Award” always going to the Rejuvica 

product.

Defendants Marketed Sobrenix as a Substance Use Disorder Product

28. The Diagnostic and Statistical Manual of Mental Disorders (Fifth Edition) 

(“DSM-5TM”), identifies alcohol-related disorders as substance-related 

disorders. According to the DSM-5TM, “alcohol use disorder” is “a problematic 

pattern of alcohol use leading to clinically significant impairment or distress, as 

manifested by at least two of [eleven identified criteria], occurring within a 12-

month period.” Those criteria include: drinking more or over a longer period than 

intended; a persistent desire or unsuccessful efforts to cut down or control alcohol 

use; and craving or a strong desire to use alcohol. 

29. Throughout the course of the Sobrenix marketing campaign discussed supra, 

with repeated references to cravings, reduced consumption (or quitting altogether), 

and regaining control over one’s life, Defendants consistently marketed Sobrenix 

as an alcohol use disorder treatment product. For example, on the Sobrenix 

website, Defendants asked, 

“Does alcohol negatively affect your life? Do you find yourself 

drinking more than you want to? Waking up with regrets from the 

night before? Has alcohol affected relationships with friends and 

family or hurt your job performance?...Whether it’s a big problem or a 

small problem, there’s no shame in admitting alcohol has more 

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control on your life than you want it to. There’s a huge genetic 

component to alcoholism, as well, so on some level it’s not your 

fault...” (Exhibit E)

30. Based on the facts and violations of law alleged in this Complaint, the FTC 

has reason to believe that Defendants are violating or are about to violate laws 

enforced by the Commission because, among other things: Defendants stopped 

advertising and selling Sobrenix only after they learned that the FTC was 

investigating the claims being made for the product; and Defendants’ deceptive 

product comparison website practices continued for their other products. Those 

practices continued for approximately eight months after Defendants learned of the 

FTC’s initial investigation; those review practices only ceased after the FTC 

notified them in December 2021 that it was broadening its investigation to include 

those practices. 

VIOLATIONS OF THE FTC ACT

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

deceptive acts or practices in or affecting commerce.”

32. Misrepresentations or deceptive omissions of material fact constitute 

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

33. 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. For the purposes of Section 12 of the FTC Act, 15 U.S.C. § 52, 

Sobrenix is a “drug” as defined in Section 15(c) of the FTC Act, 15 U.S.C. § 55(c).

COUNT ONE—DECEPTIVE ALCOHOL CRAVINGS 

AND CONSUMPTION CLAIMS 

34. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

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described in Paragraphs 10-29 of this Complaint, Defendants have represented, 

directly or indirectly, expressly or by implication, that Sobrenix:

A. Reduces or eliminates cravings for alcohol; 

B. Enables users to substantially reduce or eliminate their 

consumption of alcohol; 

C. Assists users to regain control of their problematic drinking; 

and

D. Treats alcohol use disorder or the symptoms of alcohol use 

disorder. 

35. The representations set forth in Paragraph 34 were false or misleading or 

were not substantiated at the time the representations were made. 

36. Therefore, the making of the representations as set forth in Paragraph 34 

constitutes a deceptive act or practice in violation of Sections 5(a) and 12 of the 

FTC Act, 15 U.S.C. §§ 45(a) and 52.

COUNT TWO – FALSE PROOF CLAIMS

37. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29, Defendants represented, directly or indirectly, 

expressly or by implication, that Sobrenix was proven to reduce alcohol cravings 

and consumption. 

38. In truth and in fact, in numerous instances in which Defendants have made 

the representations set forth in Paragraph 37, Sobrenix was not proven to reduce 

alcohol cravings and consumption.

39. Therefore, the making of the representations set forth in Paragraph 37 

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.

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 15 of 21 Page ID #:15
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COUNT THREE –DECEPTIVELY FORMATTED ADVERTISING

40. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29, Defendants represented, directly or indirectly, 

expressly or by implication, that the statements about Sobrenix made by Bryce 

Wylde and Jonny Bowden during their television appearances were independent 

opinions by impartial experts.

41. In truth and in fact, the statements about Sobrenix made by Bryce Wylde 

and Jonny Bowden during their television appearances were not independent 

opinions by impartial experts; they were paid commercial advertising. 

42. Therefore, the making of the representations set forth in Paragraph 40

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 FOUR – DECEPTIVE ENDORSEMENTS 

43. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Rejuvica products, including through the 

means described in Paragraphs 10-29, Defendants represented, directly or 

indirectly, expressly or by implication, that:

A. The reviewing entities, including but not limited to

“AlcoholSupportSupplements.com,” 

“LiverSupportReviews.com,” “MaleVitalityReport.com,” 

“ThyroidRemedy.com,” and “NerveRemedyReviews.com,”

were independent organizations providing objective 

information about the products they reviewed; and

B. The product reviews on those websites reflected the opinion of 

experts in the medical fields at issue. 

44. In truth and in fact, the reviewing entities were not independent 

organizations providing objective information and the product reviews on their 

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 16 of 21 Page ID #:16
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websites did not reflect the opinion of experts in the medical fields at issue. 

Instead, it was disguised advertising for Rejuvica products.

45. Therefore, the making of the representations set forth in Paragraph 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.

VIOLATIONS OF THE OPIOID ADDICTION RECOVERY FRAUD

PREVENTION ACT OF 2018

46. The Opioid Addiction Recovery Fraud Prevention Act of 2018 

(“OARFPA”), P.L. 115-271, 15 U.S.C § 45d, was enacted on October 24, 2018. 

OARFPA 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). OARFPA defines “substance use disorder treatment 

product” to mean “a product for use or marketed for use in treatment, cure, or 

prevention of a substance use disorder, including an opioid use disorder.” P.L. 

115-271 § 802, 15 U.S.C § 45d. 

47. As described in paragraphs 10-29 above, Defendants have marketed 

Sobrenix as a substance use disorder treatment product. 

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

treated as a violation of a rule under Section 18(a) of the FTC Act, 15 U.S.C. § 

57a(a), regarding unfair or deceptive acts or practices.

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

the OARFPA, 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 OARFPA. 

50. Defendants made deceptive substance use disorder treatment claims for 

Sobrenix from 2017 until approximately March 8, 2021. 

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 17 of 21 Page ID #:17
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COUNT FIVE – DECEPTIVE ALCOHOL CRAVINGS AND 

CONSUMPTION CLAIMS (OARFPA)

51. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29 of this Complaint, Defendants have represented, 

directly or indirectly, expressly or by implication, that Sobrenix:

A. Reduces or eliminates cravings for alcohol; 

B. Enables users to substantially reduce or even eliminate their 

consumption of alcohol; 

C. Assists users to regain control of their problematic drinking; 

and

D. Treats alcohol use disorder or the symptoms of alcohol use 

disorder. 

52. The representations set forth in Paragraph 51 were false or misleading or 

were not substantiated at the time the representations were made. 

53. Therefore, the making of the representations as set forth in Paragraph 51 

constitutes a deceptive act or practice with respect to a substance use disorder 

treatment product in violation of Section 8023(a) of OARFPA, 15 U.S.C. § 45d(a).

COUNT SIX – FALSE PROOF CLAIMS (OARFPA)

54. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29, Defendants represented, directly or indirectly, 

expressly or by implication, that Sobrenix was proven to reduce alcohol cravings 

and consumption. 

55. In truth and in fact, Sobrenix was not proven to reduce alcohol cravings and 

consumption. 

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 18 of 21 Page ID #:18
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56. Therefore, the making of the representations set forth in Paragraph 54 

constitutes a deceptive act or practice with respect to a substance use disorder 

treatment product in violation of Section 8023(a) of OARFPA, 15 U.S.C. § 45d(a). 

COUNT SEVEN – DECEPTIVE ENDORSEMENTS (OARFPA) 

57. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29, Defendants represented, directly or indirectly,

expressly or by implication, that:

A. The reviewing entity AlcoholSupportSupplements.com was an

independent organization providing objective information about 

the products it reviewed; and

B. The product reviews on that website reflected the opinion of 

experts in the field of alcohol use disorder. 

58. In truth and in fact, AlcoholSupportSupplements.com was not an 

independent organization providing objective information and the product reviews 

on that website did not reflect the opinion of experts in the field of alcohol use 

disorder. Instead, it was disguised advertising for Sobrenix. 

59. Therefore, the making of the representations set forth in Paragraph 57 

constitutes a deceptive act or practice with respect to a substance use disorder 

treatment product in violation of Section 8023(a) of OARFPA, 15 U.S.C. § 45d(a). 

COUNT EIGHT –DECEPTIVELY FORMATTED ADVERTISING 

(OARFPA)

60. In numerous instances in connection with the advertising, marketing, 

promotion, offering for sale, or sale of Sobrenix, including through the means 

described in Paragraphs 10-29, Defendants represented, directly or indirectly, 

expressly or by implication, that the statements about Sobrenix made by Bryce 

Wylde and Jonny Bowden during their television appearances were independent 

opinions by impartial experts.

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 19 of 21 Page ID #:19
Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 20 of 21 Page ID #:20

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Respectfully submitted, 

61. In truth and in fact, the statements about Sobrenix made by Bryce Wylde 

and Jonny Bowden during their television appearances were not independent 

opinions by impartial experts; they were paid commercial advertising. 

62. Therefore, the making of the representations set forth in Paragraph 60 

constitutes a deceptive act or practice with respect to a substance use disorder 

treatment product in violation of Section 8023(a) of OARFPA, 15 U.S.C. § 45d(a). 

CONSUMER INJURY 

63. Consumers have suffered and will continue to suffer substantial injury as a 

result of Defendants' violations of the FTC Act and OARFPA. Absent injunctive 

relief by this Court, Defendants are likely to continue to injure consumers and 

harm the public interest. 

PRAYER FOR RELIEF 

Wherefore, Plaintiff requests that the Court: 

A. Enter a permanent injunction to prevent future violations of the 

FTC Act and the OARFPA by Defendants; 

B. Award monetary and other relief within the Court's power to 

grant; and 

C. A ward any additional relief as the Court determines to be just 

and proper. 

23 Dated: July 18, 2023 

24 

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FOR THEE ERAL TRADE 

COMMIS I N 

COURTNEY A. ESTEP 

cestep@ftc.gov; (202) 326-2788 

SHIRA D. MODELL 

smodell@ftc.gov; (202) 326-3116 

Federal Trade Commission 

-20-
-21-

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600 Pennsylvania Ave., NW

Washington, DC 20580

Fax: (202) 326-3259

AARON SCHUE (Local Counsel) (Bar No.

338760) 

aschue@ftc.gov; (310) 824-4306

Federal Trade Commission

10990 Wilshire Blvd., Suite 400

Los Angeles, CA 90024

Fax: (310) 824-4380

ATTORNEYS FOR PLAINTIFF

Case 8:23-cv-01286 Document 1 Filed 07/18/23 Page 21 of 21 Page ID #:21
Case 8:23-cv-01286 Document 1-1 Filed 07/18/23 Page 1 of 2 Page ID #:22

EXHIBIT A 
Exhibit A -22-

Case 8:23-cv-01286 Document 1-1 Filed 07/18/23 Page 2 of 2 Page ID #:23

CON Fl DENTIAL FTC-REJ-0000223 
EXHIBIT B

Case 8:23-cv-01286 Document 1-2 Filed 07/18/23 Page 1 of 2 Page ID #:24
Exhibit B

-23-

Case 8:23-cv-01286 Document 1-2 Filed 07/18/23 Page 2 of 2 Page ID #:25

CON Fl DENTIAL 

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FTC-REJ-0000230 
EXHIBIT C

Case 8:23-cv-01286 Document 1-3 Filed 07/18/23 Page 1 of 2 Page ID #:26
Exhibit C -24-

Case 8:23-cv-01286 Document 1-3 Filed 07/18/23 Page 2 of 2 Page ID #:27

_____ obrenix 

"After a week and a half or so, I no 

longer have the 4pm cravings 

and the car doesn't automati 1-

ly drive to the liquor store after 

work anymore:' 

CON Fl DENTIAL FTC-REJ-0000226 
EXHIBIT D

Case 8:23-cv-01286 Document 1-4 Filed 07/18/23 Page 1 of 2 Page ID #:28
Exhibit D

-25-

Case 8:23-cv-01286 Document 1-4 Filed 07/18/23 Page 2 of 2 Page ID #:29

CONFIDENTIAL 

0 

Placebo Group 

ei~~e)I 

Why Do liquid Formulations 

Ou1pref01m Capsules In Every Category? 

6 More Reasons You'll Love Sobrenix 

___ --""' .. __ .,.,, ---- """"""'""" ConuolYourL.111 

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Frequently Asked Questions 

....:::.-~""":!..~:m- BRIGHTEN YOURFUTlJRE ,.. ~'=-~~~~ 

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FTC-REJ-0000234 
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT E 

Exhibit E -26-

Case 8:23-cv-01286 Document 1-5 Filed 07/18/23 Page 1 of 1 Page ID #:30
EXHIBIT F

Case 8:23-cv-01286 Document 1-6 Filed 07/18/23 Page 1 of 2 Page ID #:31

		



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Case 8:23-cv-01286 Document 1-6 Filed 07/18/23 Page 2 of 2 Page ID #:32

() 

-

() 

-

-
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT G 

Exhibit G -28-

Case 8:23-cv-01286 Document 1-7 Filed 07/18/23 Page 1 of 1 Page ID #:33
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT H 

Exhibit H -29-

Case 8:23-cv-01286 Document 1-8 Filed 07/18/23 Page 1 of 1 Page ID #:34
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT I 

Exhibit I -30-

Case 8:23-cv-01286 Document 1-9 Filed 07/18/23 Page 1 of 1 Page ID #:35
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT J 

Exhibit J -31-

Case 8:23-cv-01286 Document 1-10 Filed 07/18/23 Page 1 of 1 Page ID #:36
PLACEHOLDER FOR 

ELECTRONIC MEDIA 

EXHIBIT K 

Exhibit K -32-

Case 8:23-cv-01286 Document 1-11 Filed 07/18/23 Page 1 of 1 Page ID #:37
EXHIBIT L

Case 8:23-cv-01286 Document 1-12 Filed 07/18/23 Page 1 of 2 Page ID #:38
	




	 



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Case 8:23-cv-01286 Document 1-12 Filed 07/18/23 Page 2 of 2 Page ID #:39

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Case 8:23-cv-01286 Document 1-13 Filed 07/18/23 Page 2 of 2 Page ID #:41

I gap I I 

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EXHIBIT N

Case 8:23-cv-01286 Document 1-14 Filed 07/18/23 Page 1 of 4 Page ID #:42
 Exhibit N -35-

Case 8:23-cv-01286 Document 1-14 Filed 07/18/23 Page 2 of 4 Page ID #:43

~ThyroidRemedy.com • PROOUCT OOM"""50N 

Top 5 Thyroid Support Supplements 

of 2021: Which Brands Think You're 

Stupid? 

If you found this page, you're probably searching for an easier 

way to speed up and maintain a fast and healthy thyroid. See 

what our research team found out when they dove into the data. 

Posted by the Senior Editor at ThyroidRemedy.com 

Nearly 20 million Americans 

suffer from some sort of officially 

diagnosed thyroid disorder 

(called hypothyroidism or 

hashimoto's disease) while 

millions more live with a slow 

and sluggish thyroid: 

See how we make our pick: 

You gain weight even though 

you're eating Jess and 

exercising. 

.com 

• You feel tired all day even though you're getting plenty of sleep. 

You feel depressed fo r no apparent reason. 

• You have 'brain fog' and don't feel as sharp as you usually do. 

You feel colder even in room temperature. 

The good news is: natural remedies can and do help thousands regain speedy 

thyroid function every year, but before anyone can get results they have to ask: 

"How Do You Separate The Good Products From The 

Junk?" 

This is the billion dollar question, and that's why we went out and compared some 

of the top natural thyroid support remedies to see which ones really worked and 

which ones we can throw in the garbage. 

Here's What We Looked for in a Product: 

The 'BIG FIVE' Ingredients: Our research team, with its years of experience, dove 

into stacks of medical journals, positive consumer reports, and studied exactly 

how certain vitamins and herbs can bring a sluggish thyroid back online. We 

narrowed the list 5 ESSENTIAL ingredients that no effective prostate remedy 

would ever be without: 

We gave heavy favoritism to liquid extracts, and it was fo r good reason. Pills and 

capsules have to be digested, liquids do not. Liquids are formulated for optimal 

bioavailability, and their ingredients can get to work fast. Liquids are also 

portable, require no water, they're easy to digest, and they're easy on the stomach. 

Iodine 

T Click to expand T 

Selenium 

T Click to expand T 

L-Tyrosine 

T Click to expand T 

Coleus Forskohlii 

T Click to expand T 

Ashwagandha 

T Click to expand T 

Liquid Formula 

OOIUlY 

RESEAIOI EXPO!I REVIEWS EDITOR'S Ml1NG 

What You Will Learn: 

Estimated 

Read Time 5 

minutes 

0 How The Thyroid ACTUALLY 

Works! 

0 The Most Effective Ingredients 

For The BEST Results! 

0 How to Choose a Supplement 

That Delivers! 

Our Main Sources 

PDR ~ lnfotmation or better health 

ThyroidRemedy.com 

is not officially affiliated with these 

sites. 

Top 3 Thyroid Remedies: 

Thyrobin 

■ . 

Thyroid Support 

Thyroid Support 

El 
 Exhibit N -36-

Case 8:23-cv-01286 Document 1-14 Filed 07/18/23 Page 3 of 4 Page ID #:44 T Click to expand T 

What We Looked For In A Brand: 

Strength of Money-Back Guarantee: A money-back guarantee shows the 

manufacturer is so confident in the product that they're willing to put their 

money where their mouth is. There's simply no reason to trust a product 

that doesn't offer a money-back-guarantee. 

24 Hour Customer Support: A 24-hour customer-support service shows a 

manufacturer's commitment to their customers, because 24-hour support 

isn't cheap. With any remedy, you're likely to have questions, and those 

questions can arise at any time of the day or night; 24-hour customer service 

offers a peace-of-mind knowing the answers are only a phone call away. 

What We Discovered: 

We were shocked to find out that some products used the exact same formula, as 

if they're all getting these pills from a big supplier, slapping a new label on them, 

and pricing them at completely different rates ... 

... This was a bit of a red flag for us. It shows the company didn't want to take the 

time to do the research themselves and look for new ways to improve their 

product and help their customers. 

That's why, for us, there was a clear winner that stood out amongst the imitators: 

Our Top 5 Reviewed Thyroid Support 

Supplements of 2021 

Thyrobin Our Rating 

v' L Liquid Delivery: Yes 

v' 2. Ingredients: 4 of 4 

v' 3. Money-Back Guarantee: 

Yes 

v' 4. 24-Hour Support: Yes 

Thyroid Support Our 

■ Rating 

x L Liquid Delivery: No 

2. Ingredients: 2 of 4 

x 3. Money-Back Guarantee: No 

v' 4. 24-Hour Support: Yes 

Thyroid Support Our 

■ Rating 

x L Liquid Delivery: No 

M,t!,r,s .!Jeslf' - 2. Ingredients: 2 of 4 

THYROID SU PP Of..T x 3. Money-Back Guarantee: No 

x 4. 24-Hour Support: No 

Thyroid Support Our 

■ Rating 

- ~~:cio ■·-·._· SU P P Of T 
Exhibit N -37-

Case 8:23-cv-01286 Document 1-14 Filed 07/18/23 Page 4 of 4 Page ID #:45

""" 

" 1. L1qum ueuvery: 1~0 

2. Ingredients: 2 of 4 

X 3. Money-Back Guarantee: No fl X 4. 24-Hour Support: No 

Thyroid Energy Our 

■ Rating 

X 1. Liquid Delivery: No 

- 2. Ingredients: 2 of 4 

x 3. Money-Back Guarantee: No 

x 4. 24-Hour Support: No 

■ If a condition persists. please contact your physician. The information provided by this website or this 

company is not a substitute for a face-to-face consultation with your physician. and should not be construed 

as individual medical advice. Individual customer experiences with all products listed may vary.~ 

Extended Disclaimer 

*These statements have not been evaluated by the Food and Drug Administration. 

These products are not intended to diagnose, treat, cure or prevent any disease. 

While the reviews on this page are based on accurate information as far as it is available, this website and its 

owners do have a financial interest in one or more available products listed. This includes, but is not limited to 

an affiliate commission paid for referring customers. 

r,JThyroidRemedy.com 
EXHIBIT O

Case 8:23-cv-01286 Document 1-15 Filed 07/18/23 Page 1 of 5 Page ID #:46
 Exhibit O -38-

Case 8:23-cv-01286 Document 1-15 Filed 07/18/23 Page 2 of 5 Page ID #:47

NERVE.REMEDY 

REVIEWS.COM • PROOUCT COIIPMISON 

Top 5 Nerve Support Supplements of 

2021: Which Brands Think You're 

Stupid? 

If you're looking for a better nerve support supplement, look no 

further! 

Posted by the Senior Editor at NerveRemedyReviews.com 

Can you really unclog your nerves 

and get back on your feet like 

before? 

Solving nerve-related discomfort 

is like trying to solve a rubicks 

cube - there's such a tangled web 

of contributing factors that 

science can't really offer any 

crystal-clear answers, but with 

the right twists and turns, you 

might be surprised. 

See how we make our pick: 

Let's reverse-engineer this problem from the discomfort all the way to the nerve 

itself and see how: 

« SkiP- To Our TOP- Reviewed Nerve SUP-P-Ort SUP-P-lement » 

''What Causes Neuropathy?" 

According to the MayoClinic, neuropathy forms because high blood sugar 

interferes with the nerves ability to transmit signals. Additionally, it weakens the 

walls of the small blood vessels that carry oxygen and nutrients to the nerves, and 

without those nutrients and oxygen the nerve cannot properly maintain healthy 

function. 

Other factors that can contribute to neuropathy are: 

Inflammation of Nerves: Inflammation of Nerves: In simple terms, 

neuropathy is inflammation of the nerves. Inflammation is the characterized 

by swelling, redness, heat, and pain.1 

Vitamin Deficiencies: Vitamin B12 deficiency causes a wide range of 

hematological, gastrointestinal, psychiatric and neurological disorders.2 

Alcohol abuse: Drinking too much - on a single occasion or over time - can 

take a serious toll on your health. Drinking too much can weaken your 

immune system, making your body a much easier target for disease.3 

Now that we know what's happening to the nerves, it's easy to speculate as 

to why neuropathy causes tingling, numbness, and pain: 

The tingling sensation is the undernourished nerves misfiring, the 

numbness is a starved group of nerves without enough blood flow to 

function at all, and the pain is the body alarm system signaling that 

something is going wrong.* 

Given what we know about the cause of neuropathy, what are the 

mainstream solutions? 

OONJTY 

RESEARCH OIPOII REVIEWS EOllOR'S Ml1NG 

What You Will Learn: 

Estimated 

Read Time 5 

minutes 

0 What Causes Neuropathy 

0 How Nerve Health Is Supported 

0 Is There A Nerve Support 

Supplement Delivers? 

Our Main Sources 

PDR ~ Information or better health 

NerveRemedyReviews.com 

is not officially affiliated with these 

sites. 

Top 3 Reviewed Nerve 

Supplements 

Nerve Factor 

Nerve Shield 

Healthy Feet & Nerves 
 Exhibit O -39-

Case 8:23-cv-01286 Document 1-15 Filed 07/18/23 Page 3 of 5 Page ID #:48

"How is Neuropathy Supported?" 

The current medical treatments focus almost entirely on reducing the symptom 

of neuropathy: chronic pain. But they tend to focus on making the symptoms 

more bearable without treating nerve health at all, and unfortunately, they're 

expensive and come at the cost of some nasty side effects: 

Antidepressants: Antidepressants are commonly used in the treatment of 

neuropathy, with meta-analyses supporting the use oftricyclic 

antidepressants and selective norepinephrine serotonin reuptake 

inhibitors.4 

Anticonvulsants: Antiepileptic drugs are widely used in pain clinics to treat 

neuropathic pain. They have a long track record in this regard, phenytoin 

having first been used in the early 1940s for the treatment of trigeminal 

neuralgia.This has led to their use in other neuropathic pain conditions such 

as post-stroke pain, phantom limb pain and pain following spinal injury 

although the published evidence for their use in these conditions is less 

robust.5 

Painkillers: prescription painkillers are used to treat and manage 

neuropathic pain. These painkillers are generally regarded as terrible for 

long-term pain management because users quickly develop a tolerance -

meaning higher doses are required to achieve the same effect. This makes 

prescription painkillers extremely addictive and even life threatening. 6 

What do all of these options have in common? 

They're unnatural, pharmaceutical drugs* 

• They're expensive* 

They don't address nerve health* 

They all come with serious side effects* 

So, the real question is: 

"How Do You Separate The Good Products From The 

Junk?" 

We have a passion for natural health and many of us have suffered from nerverelated discomfort ourselves. That's why we went out and compared some natural 

nerve support supplements to see which ones delivered and which ones we can 

throw in the garbage. 

Here's What We Looked for in a Product 

With years of experience, our research team dove into stacks of medical journals 

and consumer reports and studied exactly how certain vitamins and herbs can 

help sooth nerve discomfort and rebuild healthy nerves. We narrowed the list to 4 

ESSENTIAL ingredients that no effective nerve support supplement would be 

without:* 

Alpha Lipoic Acid 

T Click to expand T 

B-Vitamins 

T Click to expand T 

Omega-3 Fatty Acids 

T Click to expand T 

Turmeric 

T Click to expand T 

Liquid Formula 

T Click to expand T 

What We Looked For In A Brand: 

Strength of Money-Back Guarantee: A money-back guarantee shows the 

manufacturer is so confident in the product that they're willing to put their 

money where their mouth is. There's simply no reason to trust a product 

■ . 

Our Evaluation Method: 

We Evaluate Products Basted on 

the Following Criteria: 

0 Liquid Delivery 

0 Ingredients 

0 Money-Back Guarantee 

0 24-Hour Support 

Senior Editor at 

Nerve Remedy Reviews 

We are committed to providing 

you with accurate and up-Iodate information so you can 

make an informed choice when 

it comes to your health. 

If you have any questions, 

comments, concerns, or if you'd 

like to recommend a product for 

us to review, please contact us 

at: 

info@NerveRemedyReviews.co 

m 
 Exhibit O -40-

Case 8:23-cv-01286 Document 1-15 Filed 07/18/23 Page 4 of 5 Page ID #:49 that doesn't otter a money-back-guarantee. 

24 Hour Customer Support: A 24-hour customer-support service shows a 

manufacturer's commitment to their customers, because 24-hour support 

isn't cheap. With any remedy, you're likely to have questions, and those 

questions can arise at any time of the day or night; 24-hour customer service 

offers a peace-of-mind knowing the answers are only a phone call away. 

What We Discovered: 

What we found is that there are a number of good choices for natural nerve 

support, but some were certainly better than others. For us, there was a clear 

winner ... 

Top 5 Nerve Support Supplements of 2021 

NERVEREMEDY 

REVIEWS.roM 

Nerve Factor 

v' L Liquid Delivery: Yes 

v' 2. Ingredients: 4 of 4 

v' 3. Money-Back Guarantee: 

Yes 

v' 4. 24-Hour Support: Yes 

Nerve Shield 

x L Liquid Delivery: No 

- 2. Ingredients: 3 of 4 

v' 3. Money-Back Guarantee: 

Yes 

x 4. 24-Hour Support: No 

Healthy Feet & Nerves 

...11t.NERVE.RE.MEDY ..._ REV1F'¥5.COM 

x L Liquid Delivery: No 

- 2. Ingredients: 2 of 4 

v' 4. Money-Back Guarantee: 

Yes 

x 5. 24-Hour Support: No 

Neuroplenish 

x L Liquid Delivery: No 

- 2. Ingredients: 1 of 4 

v' 4. Money-Back Guarantee: 

Yes 

v' 5. 24-Hour Support: Yes 

Nerve Support Formula 

Our Rating 

■ -

Our Rating 

■ -

Our Rating 

■ -

Our Rating 

■ -

Our Rating 
Exhibit O -41-

Case 8:23-cv-01286 Document 1-15 Filed 07/18/23 Page 5 of 5 Page ID #:50

X 1. Liquid Delivery: No 

- 2. Ingredients: 1 of 4 

v' 4. Money-Back Guarantee: 

Yes 

- 5. 24-Hour Support: NIA 

■ . 

If a condition persists, please contact your physician. The information provided by this website or this 

company is not a substitute for a face-to-face consultation with your physician, and should not be construed 

as individual medical advice. Individual customer experiences with all products listed may vary. Read Our 

Extended Disclaimer 

*These statements have not been evaluated by the Food and Drug Administration. 

These products are not intended to diagnose, treat, cure or prevent any disease. 

While the reviews on this page are based on accurate information as far as it is available, this website and its 

owners do have a financial interest in one or more available products listed. This includes, but is not limited to 

an affiliate commission paid for referring customers. 

CO NerveRemedyReviews.com