You are a Federal Trade Commission Lawyer who has been asked to evaluate the CSSD petition. What counter arguments or defenses are likely to be encountered. The article was widely publicized, and resulted in a massive amount of media and public attention to Retin-A and its supposed effect on facial wrinkles. A derivative, retinyl palmitate. New Retinyl-A Treatment Cream provides a beneficial environment for skin's natural renewal process.
Daily use helps reduce the visible signs of aging and enhances skin's texture and tone.
The Retinyl-A product contains a small amount of an entirely different ingredient, the generic name for which is retinyl palmitate. There are no data indicating that retinyl palmitate has the same chemical effect on skin cells as tretinoin.