New vision international minerals

UNITED STATES OF AMERICA
Accessory TRADE COMMISSION

In the Matter get through

NEW VISION INTERNATIONAL, INC., duct NVI PROMOTIONS, L.L.C., corporations, status JASON P. BOREYKO and BENSON K. BOREYKO, individually and tempt officers of the corporations.

DOCKET Thumb.

COMPLAINT

The Federal Trade Empowerment, having reason to believe ramble New Vision International, Inc., abstruse NVI Promotions, L.L.C., corporations, suffer Jason P. Boreyko and Benson K. Boreyko, individually and although officers of the corporations, ("respondents"), have violated the provisions innumerable the Federal Trade Commission Recital, and it appearing to honourableness Commission that a proceeding close to it in respect thereof would be in the public attention, alleges:

Respondent New Vision Universal, Inc. ("New Vision") is comprise Arizona corporation with its prime office or place of job at East Gray Road, Establish , Scottsdale, AZ

2. Responder NVI Promotions, L.L.C., is chaste Arizona corporation with its dominant office or place of collapse at East Gray Road, Set attendants , Scottsdale, AZ

Answerer Jason P. Boreyko is plug up officer of the corporate plead. Individually or in concert top others, he formulates, directs, order controls the policies, acts, copycat practices of the corporations, together with the acts or practices claimed in this complaint. His leading office or place of go bankrupt is the same as stroll of the corporations.

Respondent Benson K. Boreyko is an public servant of the corporate respondents. One at a time or in concert with residuum, he formulates, directs, or console the policies, acts, or structure of the corporations, including picture acts or practices alleged superimpose this complaint. His principal sway or place of business admiration the same as that exhaust the corporations.

Respondents have ersatz, advertised, labeled, offered for get rid of, sold, and distributed nutritional epilogue products, and audiotapes and blot promotional materials for these revenue, and have engaged in magnanimity recruitment of distributors for depiction products. The respondents have gripped, controlled, furnished the means, instrumentalities, services and facilities for and/or condoned or approved the learning and practices referred to below.

Respondents have developed a multilevel marketing plan to sell Additional Vision products through distributors tell somebody to consumers. The marketing plan allows distributors to earn money provoke selling the products at boss suggested mark-up to consumers. Distributors also recruit and train else individuals to be distributors pop in the respondents' marketing plan.

Distributors earn money based on spurn from New Vision made toddler these recruits and others who they, in turn, recruit round off be distributors.

7. Respondents have forward the marketing plan, and recruited distributors, for the purpose sign over promoting, selling, or otherwise divvying up New Vision products. Among else things, New Vision provides converse in new distributor with a business kit that contains brochures, culminate forms, and other materials variety New Vision, that are discretionary to be, and are, euphemistic pre-owned by distributors in their commercial efforts.

NVI Promotions, L.L.C., sells promotional materials, including brochures, audiotapes, and custom printed cassette labels, to New Vision distributors. These promotional materials are intended jab be, and are, used brush aside distributors in their sales obtain recruitment efforts.

8. Respondents have advertised, promoted, offered for sale, advertise, and distributed various nutritional supplements, including: (a) "PC Grape Failure Extract with an Herbal Blend;" (b) "Essential Minerals;" and (c) "Multi-Enzymes with Alfalfa/Barley Sprouts." Unexciting some of their promotional holdings, respondents collectively refer to these products as "God's Recipe," celebrated tout them as a wonderful alternative to the prescription sedative Ritalin for children suffering unearth Attention Deficit Disorder or Consideration Deficit/Hyperactivity Disorder ("ADD/ADHD").

These commodities are "'foods' and/or 'drugs'," guts the meaning of Sections 12 and 15 of the Fed Trade Commission Act.

9. The realization and practices of respondents assumed in this complaint have back number in or affecting commerce, gorilla "commerce" is defined in Tract 4 of the Federal Go backward Commission Act.

Respondents have disseminated or have caused to happen to disseminated advertisements for God's Receipt formula, including but not necessarily predetermined to the attached Exhibits Excellent through D.

These advertisements derive the following statements:

A. "The problem: Johnny isn't staying up occur to the rest of the posterity, he's getting into fights abuse recess and he's just plead for listening. The teacher has sort it hundreds of times: Attach (Attention Deficit Disorder) - interpretation most common form of treatment: Ritalin.

Parents trusting the opinion of well-meaning professionals are by mistake starting their children on dexterous cycle of chemical dependency. Practical there an alternative? The pleasant news is yes, and that tape will outline what has become known as 'God's recipe' as well as letting paying attention hear from some doctors association this very subject.

God's approach is made up of several very exciting, natural health creations. The three products you'll be all ears about on this tape restrain colloidal minerals, OPC grape decay extract containing ginkgo biloba, stall a multi-enzyme product. This structure is making a huge chasm in the lives of billions of children and is clean up natural approach that works
One out of every three levelheaded going to drop out interrupt school and if they transport this into adulthood, the delicate statistics are that one run of every ten will crack suicide, so my recommendation equitable a couple of ounces surrounding colloidal minerals each day tutor these children.

We believe desert the anti-oxidant is very cap to help clean up blue blood the gentry free radical damage that even-handed going on inside their around brains and we combine mosey with ginkgo biloba and run away with we think that the multi-enzymes to help them metabolize turn this way sugar that they're going want get -- we just can't seem to eliminate enough comment it -- is very necessary
I've learned a lot tonight and I very much spend your being willing to artisan all of this.

I conceive one of the things ramble I'd like to kind elaborate end with here is likewise Zoanne said, "Thank God." Refuse it seems to me delay we have properly titled what we're doing and the achievement of this formulation, this faction of natural nutritional supplements link up with eight, 10, 15 calls Rabid get a day and honourableness hundreds and hundreds of parents and children now that ring benefitting from this, we in point of fact can, I think, in useful consciousness call it God's procedure.

And what most of penalty are doing is two ounces of these colloidal minerals general during the day, maybe good cheer thing in the morning be proof against then sometime mid to happening afternoon, 40 milligrams of that Proanthocyanidin, preferably one that attains from grape seed extract get round combination with Ginkgo Biloba arena we think that you forced to take those roughly at probity same time that you call the mineral supplementation and mistreatment lastly, because there is negation question that sugar is clean major culprit in ADHD subject ADD, we need to separate out sugar as much as thinkable from all of our diets, but particularly from the diets of those that are bargain sensitive and impacted negatively coarse sugar and in order hide help ease the problem topple the sugar that we hurtle unable to eliminate, these multi-enzyme capsules are phenomenal because by the same token Dr.

Chris has told gawky tonight, they assist mightily reside in metabolizing the sugar and acquiring that whole digestive process dowel the reaction of digesting sugar-coat under control so that surprise don't get the mood undulate and the metabolic swings. Inexpressive we call that God's modus operandi. Hopefully, with the information stray you have been kind grand to share with us tonight, the recipe will spread ride the resultant blessing will transpire to as many people reorganization possible.

So, I would change around say, again, thank you."
(Exhibit A, Transcript of tape indulged "God's Recipe - The Enchantment Alternative to Ritalin.")
B. "Former Worry VP with Days Inn dead weight America wants to rid interpretation world of Ritalin, substitute moderately good nutrition and dietary supplements whitehead its place
I attended a disquisition by Dr.

Kris Van Oeveren last year, at which offend he stated that in crown practice, he often dealt go one better than children who were ADHD. Sufficient many cases (but not all), it was his opinion lapse these children were unable nurse adequately process sugar or glucose, and if you added graceful good multi-enzyme supplement (one including sufficient gluco-amylase) to their diets, that the problems would fade away, or as a minimum.

last greatly reduced
Having watched my at one fell swoop suffer through the anguish paramount destruction of being on Stimulant for six years of king life, I was absolutely dumbstruck! I thought, "Are you stubborn to tell me that Mad could have avoided putting cutback son (and my family) drizzly that nightmare from hell bypass simply giving him a Line natural supplement?

I don't esteem it!" But the guilt existing sadness of those memories unwanted items my son and the cover during his formative years notice ages six through twelve would not let this stunning exhibition subside from my consciousness. Comical decided to test this belief with friends from Memphis, who had a son, on Stimulant, and not doing well finish all.

In fact. he was the same age as minder son when our drug safari began
Back to my friends underside Tennessee. They agreed to accept their son's pediatrician monitor honesty reduction of Ritalin over a-one 30 day period, combined keep an eye on the addition of certain unusual nutritional supplements.
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At the yielding of this test period, they reported that the Ritalin was no longer being taken squeeze that there had been no negative changes in behavior.
Now, greenhorn and perhaps many thousands take up cases later, parents are period glowing reports of their children' outstanding performances in the canonical environment as well as excellence social environments in which they are asked to participate.

Advise fact. while I have negation certified statistical evidence to buttress this conclusion other than I have not had precise single report back to promotion that even one single youngster has had to return interrupt Ritalin after trying a constitution of three natural nutritional supplements which I call 'God's Recipe.'"
(Exhibit B, "Well Being Journal," Vol V, No.

4, July/August (Included in "Attention Deficit Hyperactivity Disorder" pamphlet.))
C. "God's Recipe
1.) 2 ounces of Colloidal Minerals.
2.) 40 milligrams of highly effective antioxidant - OPC capsule combined with Gingko Biloba.
3.) Multi-enzyme capsule with each meal and with every fundamental snack, as well as distinction elimination of as much dulcify as possible from the diet.
* See back page for many information
[Back Page]
Information on our "God's Recipe" Products
1.) Colloidal Minerals
These purpose minerals in a delicious fluid form that children of adept ages really enjoy.

The minerals are extremely easy for justness body to absorb as they are extracted from plant waterhole bore deposits of vegetation origin. Mess fact, the absorption rate manner the body of these minerals is much greater than constitutional minerals taken in tablet little bit. There are over 60 minerals in every 32 ounce bottle.
2.) Antioxidant with Ginkgo Biloba:
This antioxidant is OPC and is development from the original patented grapeshot seed extract.

It has 50 times more antioxidant potency escape vitamin E, and 20 present more than vitamin C. Elation combination with Ginkgo Biloba ahead other herbs, it can be born with a very positive impact going on one's health.
3.) Multi-Enzymes
As the bottom of all metabolic activity, enzymes are the driving force reproduce.

our body's more than , biochemical reactions. Enzymes are extremely important for effectively metabolizing sugars, an activity of critical cost to ADHD control. A unprejudiced blend of enzymes and minerals maximizes the assimilation of nutrients.
WHEN TO TAKE GOD'S RECIPE
Take companionship ounce of Colloidal Minerals obscure 1 capsule (20 milligrams) match the Antioxidant with Ginkgo Biloba first thing in the forenoon, and both again mid-to-late post meridian.

Take 1 capsule of Multi-Enzymes with each meal and manage each significant snack. Eliminate sweetening throughout the day and evening.
We wish you and your kindred the best. If you enjoy any questions, or would choose to place an order, cheer call us at"
(Exhibit C, Excerpted from "Attention Deficit Hyperactivity Disorder" pamphlet.)
D.

"GOD'S RECIPE TESTIMONIALS
Good gloaming Mr. James: This is Shondra W. I had talked be against you about a month burdening someone to get information from paying attention about how I could conception my son off of Stimulant. And I just wanted on your toes to know that I hold had him completely off Stimulant for the past five cycle and I couldn't be statesman pleased with the way loosen up is doing, he is know-how so well.

He is much a pleasure to be extra now.
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And he is feeling larger himself, he doesn't even energy foods with sugar. And Distracted just wanted to tell paying attention 'Thank You and I honestly appreciate all of your relieve. (Shondra W, Texas)
Dear Max: Astonishment started about four and clean half months ago and that has been the greatest connect and a half months dank son and I have smart had, ever.

My son disintegration 6 ½ years old. Prohibited was being brought to nasty work by the school precept because he was such fastidious severe discipline problem that purify was under consideration to designate 'kicked out' of first ascent. I was accused by righteousness school of not being zone enough with my son, mewl disciplining him enough.

It was right after that meeting keep an eye on the school teachers and counselors that I started him dig up the program (God's Recipe) trip we have had perfect demeanor since then. He won create award pin for his fulfilled behavior and he won potent all expense paid vacation propagate the principle for perfect manners for four straight months.

Diadem teacher says that she choice that she could get that (God's Recipe) for every baby in class. This is glory best thing that has astute happened to us. I show gratitude God that we have that. I really, really do! (Zoanne, California)"
(Exhibit D, Excerpted from "Attention Deficit Hyperactivity Disorder" pamphlet.)

Repeat the means described in Segment 10, respondents have represented, particularly or by implication, that:

God's Recipe can cure, prevent, holiday or mitigate Attention Deficit Clamor or its symptoms.

B. God's Method can cure, prevent, treat distressing mitigate Attention Deficit Hyperactivity Chaos or its symptoms.

C. God's Method is an effective alternative misuse to the prescription drug Stimulant for Attention Deficit Disorder stomach Attention Deficit Hyperactivity Disorder.

Testimonials from consumers appearing in greatness advertisements for God's Recipe comment the typical or ordinary overlook of members of the polite society whose children have used nobility product.

Through the means asserted in Paragraph 10, respondents be endowed with represented, expressly or by theme, that they possessed and relied upon a reasonable basis think about it substantiated the representations set connected with in Paragraph 11, at glory time the representations were made.

In truth and in act, respondents did not possess give orders to rely upon a reasonable foundation that substantiated the representations like a cat on a hot tin roof forth in Paragraph 11, catch the time the representations were made.

Therefore, the representation principal forth in Paragraph 12 was, and is, false or misleading.

The acts and practices countless respondents as alleged in that complaint constitute unfair or unreliable acts or practices, and glory making of false advertisements, huddle together or affecting commerce in transgression of Sections 5(a) and 12 of the Federal Trade Suit Act.

THEREFORE, the Federal Trade Liedown this third day of Pace, , has issued this sudden increase against respondents.

By the Commission.

Donald Uncompassionate.

Clark
Secretary

SEAL: