WARNING LETTER

Date: May 1, 2020

TO: frontdesk@exodushc.com; sales@drjockers.com – David Jockers, Dr Jockers.com, LLC 109 

Dunlavin Drive

Acworth, GA 30102

RE: Unapproved and Misbranded Products Related to Coronavirus Disease 2019

(COVID-19)

This is to advise you that the United States Food and Drug Administration (FDA) and the Federal Trade 

Commission (FTC) reviewed your website at the Internet address www.drjockers.com on March 19, 2020 

and April 14, 2020, respectively. We have also reviewed your social media sites at

www.facebook.com/DrDavidJockers and www.instagram.com/drjockers/, where you direct consumers to

your website, www.drjockers.com, to purchase your products. The FDA has observed that your website

offers the products Super C, Vitamin D/K2, Zinc Charge, and ImmunoStrong Berry Liquid (labeled to

contain elderberry and astragalus) for sale in the United States and that these products are intended to 

mitigate, prevent, treat, diagnose, or cure COVID-191 in people. Based on our review, these products are

unapproved new drugs sold in violation of section 505(a) of the Federal Food, Drug, and Cosmetic Act

(FD&C Act), 21 U.S.C. § 355(a). Furthermore, these products are misbranded drugs under section 502 of

the FD&C Act, 21 U.S.C. § 352. The introduction or delivery for introduction of these products into 

interstate commerce is prohibited under sections 301(a) and (d) of the FD&C Act, 21 U.S.C. § 331(a) and

(d). 

There is currently an outbreak of respiratory disease caused by a novel coronavirus that has been named

“severe acute respiratory syndrome coronavirus 2” (SARS-CoV-2). The disease caused by the virus has

been named “Coronavirus Disease 2019” (COVID-19). On January 31, 2020, the Department of Health

and Human Services (HHS) issued a declaration of a public health emergency related to COVID-19 and

mobilized the Operating Divisions of HHS.2 In addition, on March 13, 2020, the President declared a 

national emergency in response to COVID-19.3 Therefore, FDA is taking urgent measures to protect

consumers from certain products that, without approval or authorization by FDA, claim to mitigate,

prevent, treat, diagnose, or cure COVID-19 in people. As described below, you sell products that are 

intended to mitigate,

1 As explained in the next paragraph, there is currently an outbreak of a respiratory disease named “Coronavirus

Disease 2019” (COVID-19).

2 Secretary of Health and Human Services Alex M Azar, Determination that a Public Health Emergency Exists. Jan.

31, 2020. (Accessible at https://www.phe.gov/emergency/news/healthactions/phe/Pages/2019-nCoV.aspx).

3 President Donald J. Trump, Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus

Disease (COVID-19). Mar. 13, 2020. (Accessible at https://www.whitehouse.gov/presidentialactions/proclamation-declaring-national-emergency-concerning-novel-coronavirus-disease-covid-19-outbreak/).
Page 2 of 3 pages

prevent, treat, diagnose or cure COVID-19 in people. We request that you take immediate action to 

cease the sale of such unapproved and unauthorized products for the mitigation, prevention, treatment,

diagnosis, or cure of COVID-19.

Some examples of the claims on your websites that establish the intended use of your products and

misleadingly represent them as safe and/or effective for the treatment or prevention of COVID-19

include:

• “TOP WAYS TO PREVENT CORONAVIRUS INFECTION ...

o Take Vitamin C

o Optimize Vitamin D & Zinc

o Use ElderBerry & Astragalus” [www.drjockers.com/coronavirus/]

• “Take Vitamin C for Coronavirus ... I also recommend taking a vitamin C supplement, such as

Super C. Take 500 mg, 2 times daily for prevention and do 3-5 grams, 2-4 times daily if you

are feeling symptomatic.” [www.drjockers.com/coronavirus/]

• “I recommend that you take a daily Vitamin D/K2 supplement for both prevention and

treatment.” [www.drjockers.com/coronavirus/]

• “I also recommend that you supplement with Zinc Charge for prevention, and also take it if you

are sick every 2 hours until you feel better.” [www.drjockers.com/coronavirus/]

• “On a preventative approach, take 1 gram of Vitamin C twice a day ... we have one called

Super C that’s on my store ... if you’re feeling symptomatic take 3 – 5 grams, 3 – 4 times a

day” [Facebook Video Post titled “Coronavirus Update and New Podcast at 4:35, 

www.facebook.com/DrDavidJockers/videos/621900865331757]

You should take immediate action to correct the violations cited in this letter. This letter is not meant to 

be an all-inclusive list of violations that exist in connection with your products or operations. It is your 

responsibility to ensure that the products you sell are in compliance with the FD&C Act and FDA's

implementing regulations. We advise you to review your websites, product labels, and other labeling

and promotional materials to ensure that you are not misleadingly representing your products as safe and 

effective for a COVID-19 related use for which they have not been approved by FDA and that you do 

not make claims that misbrand the products in violation of the FD&C Act. Within 48 hours, please 

send an email to COVID-19- Task-Force-CFSAN@fda.hhs.gov describing the specific steps you have

taken to correct these violations. Include an explanation of each step being taken to prevent the

recurrence of violations, as well as copies of related documentation. Failure to immediately correct the

violations cited in this letter may result in legal action, including, without limitation, seizure and

injunction.

FDA is advising consumers not to purchase or use certain products that have not been approved, cleared,

or authorized by FDA and that are being misleadingly represented as safe and/or effective for the

treatment or prevention of COVID-19. Your firm will be added to a published list on FDA’s website of

firms and websites that have received warning letters from FDA concerning the sale or distribution of

COVID-19 related products in violation of the FD&C

Act. This list can be found at http://www.fda.gov/consumers/health-fraud-scams/fraudulent- coronavirusdisease-covid-19-products. Once you have taken corrective actions to cease the sale of your unapproved

and unauthorized products for the mitigation, prevention, treatment,
Page 3 of 3 pages

diagnosis, or cure of COVID-19, and such actions have been confirmed by the FDA, the published list 

will be updated to indicate that your firm has taken appropriate corrective action.

If you cannot complete corrective action within 48 hours, state the reason for the delay and the time

within which you will complete the corrections. If you believe that your products are not in violation of

the FD&C Act, include your reasoning and any supporting information for our consideration.

If you are not located in the United States, please note that products that appear to be misbranded or

unapproved new drugs are subject to detention and refusal of admission if they are offered for 

importation into the United States. We may advise the appropriate regulatory officials in the country from

which you operate that FDA considers your product(s) referenced above to be unapproved and 

misbranded products that cannot be legally sold to consumers in the United States.

Please direct any inquiries to FDA at COVID-19-Task-Force-CFSAN@fda.hhs.gov.

In addition, 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. Violations of the FTC Act may result in legal action seeking a Federal District Court injunction

and an order may require that you pay back money to consumers. Within 48 hours, please send an email to

Richard Cleland, Assistant Director of the FTC’s Division of Advertising Practices, 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 Mr. Cleland at 202-326-3088.

Sincerely, Sincerely,

 /S/ /S/ 

 _________________________________ 

William A. Correll Richard A. Quaresima

Director Acting Associate Director

Office of Compliance Division of Advertising Practices

Center for Food Safety and Applied Nutrition Federal Trade Commission 

Food and Drug Administration