UNITED STATES OF AMERICA 

Federal Trade Commission 

WASHINGTON, D.C. 20580 

April 24, 2020 

Via Electronic Mail 

Arbonne International, LLC 

c/o Bernadette Chala, Chief Legal Officer 

 & General Counsel 

9400 Jeronimo Rd. 

Irvine, CA 92618 

Warning Regarding Health and Earnings Claims Related to Coronavirus 

Disease 2019 (COVID-19) 

Dear Ms. Chala: 

Federal Trade Commission (“FTC”) staff has reviewed social media posts made by 

Arbonne International, LLC, (“Arbonne”) 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 Arbonne business opportunity 

participants are likely to earn substantial income. This letter is to provide you with information 

about laws and regulations enforced by the FTC that may bear upon your business activities, 

including the activities of your business opportunity participants and representatives. 

Some examples of COVID-19 prevention or treatment claims made by your business 

opportunity participants or representatives include: 

 “I’ll be going live on my #IGTV in a couple of hours talking about a product 

which we’ve got over at #Arbonne called ‘Immunity Support’. Drop me a 

message if you’re interested in finding out more & how you can boost up your 

immune system right now. #CoronaVirus #ImmuneSystem” 

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

representatives include: 

 “...Living in quarantine and where 14 million people applied for unemployment 

just last week ... I’ll stick with the opportunity to change people’s lives ... turn a 

small investment into six figures .... #arbonne ... #quarantine #2020” 

 “We have been thrown into the massive economic collapse in the past 13 years. 

... Arbonne is a legitimate business, that rewards you for your hard work. In a 

little over one year, my wife [] is about 6 months away from replacing her income 

from working 40 hours/week [at a] local college. In addition, the possibilities are 

endless, I have met those who make $22,000/month as national vice presidents. 
 

 

Has this shutdown given you the ability to make a small investment into a big 

future and let you own your own business?” 

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

prevent, treat, or cure human disease unless you possess competent and reliable scientific 

evidence, including, when appropriate, well-controlled human clinical studies, substantiating that 

the claims are true at the time they are made. For COVID-19, no such study is currently known 

to exist for the products identified above. Thus, any coronavirus-related prevention or treatment 

claims regarding such products are not supported by competent and reliable scientific evidence. 

You must immediately cease making all such claims. 

Additionally, representations about a business opportunity, including earnings claims, 

violate Section 5 of the FTC Act, 15 U.S.C. § 41 et seq., if they are false, misleading, or 

unsubstantiated and material to consumers. Express and implied earnings claims must be truthful 

and non-misleading to avoid being deceptive, which means that claims about the potential to 

achieve a wealthy lifestyle, career-level income, or significant income are false or misleading if 

business opportunity participants generally do not achieve such results. Even truthful 

testimonials from participants who do earn significant income or more will likely be misleading 

unless the advertising also makes clear the amount earned or lost by most participants. Your 

business opportunity participants and representatives must immediately cease making all express 

and implied earnings claims that would be false or misleading to current or prospective 

participants. 

You are responsible for the claims of your business opportunity participants and 

representatives. As the FTC stated in the January 2019 Business Guidance Concerning MultiLevel Marketing, the compensation structure of a Multi-Level Marketing entity (“MLM”) may 

create incentives for its participants to make certain representations to current or prospective 

participants. “As a consequence, an MLM should (i) direct its participants not to make false, 

misleading, or unsubstantiated representations and (ii) monitor its participants so they don’t 

make false, misleading, or unsubstantiated representations.” 

You are advised to review all claims relating to your products and business opportunity 

and immediately cease, and require your business opportunity participants and representatives to 

cease, making claims that are not supported by the evidence or substantiation described above. 

Within 48 hours, please send reply via email to COVID-19-Task-Force@ftc.gov 

describing the specific actions you have taken to address the FTC’s concerns. If you have any 

questions regarding compliance with the FTC Act, please contact us at COVID-19-TaskForce@ftc.gov. 

 Sincerely,

 Federal Trade Commission Staff 

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