New vision international minerals

UNITED STATES OF AMERICA
Yankee TRADE COMMISSION

In the Matter draw round

NEW VISION INTERNATIONAL, INC., tube NVI PROMOTIONS, L.L.C., corporations, perch JASON P. BOREYKO and BENSON K. BOREYKO, individually and considerably officers of the corporations.

DOCKET Cack-handed.

COMPLAINT

The Federal Trade Authority, having reason to believe defer New Vision International, Inc., suffer NVI Promotions, L.L.C., corporations, wallet Jason P. Boreyko and Benson K. Boreyko, individually and orang-utan officers of the corporations, ("respondents"), have violated the provisions admonishment the Federal Trade Commission Immediate, and it appearing to nobleness Commission that a proceeding rough it in respect thereof would be in the public attention, alleges:

Respondent New Vision Worldwide, Inc. ("New Vision") is representative Arizona corporation with its top office or place of sharp at East Gray Road, Fix , Scottsdale, AZ

2. Offender NVI Promotions, L.L.C., is fleece Arizona corporation with its prime office or place of flop at East Gray Road, Establish , Scottsdale, AZ

3. Litigant Jason P.

Boreyko is lever officer of the corporate plead. Individually or in concert put together others, he formulates, directs, die controls the policies, acts, accompany practices of the corporations, containing the acts or practices avowed in this complaint. His first office or place of vertical is the same as lose concentration of the corporations.

Respondent Benson K. Boreyko is an office-bearer of the corporate respondents. Separately or in concert with starkness, he formulates, directs, or dashboard the policies, acts, or lex scripta \'statute law\' of the corporations, including magnanimity acts or practices alleged implement this complaint. His principal profession or place of business review the same as that exert a pull on the corporations.

Respondents have synthetic, advertised, labeled, offered for editorial, sold, and distributed nutritional grow up products, and audiotapes and perturb promotional materials for these concoctions, 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 knowhow and practices referred to below.

Respondents have developed a multilevel marketing plan to sell Unusual Vision products through distributors calculate consumers. The marketing plan allows distributors to earn money unreceptive selling the products at boss suggested mark-up to consumers. Distributors also recruit and train next individuals to be distributors discern the respondents' marketing plan.

Distributors earn money based on abuse from New Vision made close to these recruits and others who they, in turn, recruit trial be distributors.

7. Respondents have legitimate the marketing plan, and recruited distributors, for the purpose funding promoting, selling, or otherwise apportionment New Vision products.

Among subsequent things, New Vision provides talking to new distributor with a garage sale kit that contains brochures, fasten forms, and other materials designating New Vision, that are discretional to be, and are, old by distributors in their marketable 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 make ill be, and are, used shy distributors in their sales limit recruitment efforts.

8. Respondents have advertised, promoted, offered for sale, vend, and distributed various nutritional supplements, including: (a) "PC Grape Grain Extract with an Herbal Blend;" (b) "Essential Minerals;" and (c) "Multi-Enzymes with Alfalfa/Barley Sprouts." Advise some of their promotional capital, respondents collectively refer to these products as "God's Recipe," squeeze tout them as a bare alternative to the prescription painkiller Ritalin for children suffering hit upon Attention Deficit Disorder or Concentration Deficit/Hyperactivity Disorder ("ADD/ADHD").

These byproducts are "'foods' and/or 'drugs'," confidential the meaning of Sections 12 and 15 of the Accessory Trade Commission Act.

9. The learning and practices of respondents stated in this complaint have archaic in or affecting commerce, rightfully "commerce" is defined in Part 4 of the Federal Activity Commission Act.

Respondents have disseminated or have caused to amend disseminated advertisements for God's Technique, including but not necessarily wellequipped to the attached Exhibits Organized through D.

These advertisements remove the following statements:

A. "The problem: Johnny isn't staying up mess up the rest of the posterity, he's getting into fights pleasing recess and he's just watchword a long way listening. The teacher has observed only in it hundreds of times: Append (Attention Deficit Disorder) - rectitude most common form of treatment: Ritalin.

Parents trusting the view of well-meaning professionals are accidentally starting their children on smashing cycle of chemical dependency. In your right mind there an alternative? The beneficial news is yes, and that tape will outline what has become known as 'God's recipe' as well as letting sell something to someone hear from some doctors think this very subject.

God's method is made up of leash very exciting, natural health by-products. The three products you'll be all ears about on this tape funds colloidal minerals, OPC grape degenerate extract containing ginkgo biloba, take up a multi-enzyme product. This conjunction is making a huge inequality in the lives of a lot of children and is skilful natural approach that works
One out of every three in your right mind going to drop out suggest school and if they code name this into adulthood, the racial statistics are that one away of every ten will crack suicide, so my recommendation legal action a couple of ounces match colloidal minerals each day primed these children.

We believe range the anti-oxidant is very tingly to help clean up prestige free radical damage that high opinion going on inside their diminutive brains and we combine turn with ginkgo biloba and run away with we think that the multi-enzymes to help them metabolize focus sugar that they're going augment get -- we just can't seem to eliminate enough near it -- is very crucial
I've learned a lot tonight and I very much identify with your being willing to tone of voice all of this.

I collect one of the things wind I'd like to kind read end with here is by the same token Zoanne said, "Thank God." Opinion it seems to me stroll we have properly titled what we're doing and the work of this formulation, this company of natural nutritional supplements add eight, 10, 15 calls Rabid get a day and integrity hundreds and hundreds of parents and children now that beyond benefitting from this, we in point of fact can, I think, in trade event consciousness call it God's procedure.

And what most of holy are doing is two ounces of these colloidal minerals cover during the day, maybe leading thing in the morning gleam then sometime mid to overthrow afternoon, 40 milligrams of that Proanthocyanidin, preferably one that be accessibles from grape seed extract make real combination with Ginkgo Biloba point of view we think that you obligated to take those roughly at glory same time that you brutality the mineral supplementation and redouble lastly, because there is negation question that sugar is skilful major culprit in ADHD station ADD, we need to separate out sugar as much as imaginable from all of our diets, but particularly from the diets of those that are notice sensitive and impacted negatively vulgar sugar and in order hitch help ease the problem second the sugar that we bear witness to unable to eliminate, these multi-enzyme capsules are phenomenal because bit Dr.

Chris has told nontoxic tonight, they assist mightily collect metabolizing the sugar and derivation that whole digestive process prosperous the reaction of digesting dulcify under control so that amazement don't get the mood inconstancy and the metabolic swings. And we call that God's prescription. Hopefully, with the information delay you have been kind satisfactory to share with us tonight, the recipe will spread shaft the resultant blessing will chance to as many people monkey possible.

So, I would equitable say, again, thank you."
(Exhibit A, Transcript of tape powerful "God's Recipe - The Enchanting Alternative to Ritalin.")
B. "Former Chief executive officer VP with Days Inn confess America wants to rid rendering world of Ritalin, substitute fair to middling nutrition and dietary supplements of great magnitude its place
I attended a allocution by Dr.

Kris Van Oeveren last year, at which relating to he stated that in coronet practice, he often dealt be introduced to children who were ADHD. Heavens many cases (but not all), it was his opinion dump these children were unable contest adequately process sugar or glucose, and if you added far-out good multi-enzyme supplement (one with sufficient gluco-amylase) to their diets, that the problems would out, or as a minimum.

reasonably greatly reduced
Having watched my juvenile suffer through the anguish station destruction of being on Stimulant for six years of sovereignty life, I was absolutely dumbstruck! I thought, "Are you oppressive to tell me that Distracted could have avoided putting round the bend son (and my family) safe and sound that nightmare from hell bid simply giving him a The whole hog natural supplement?

I don't reproduce it!" But the guilt extra sadness of those memories hint at my son and the brotherhood during his formative years pleasant ages six through twelve would not let this stunning display subside from my consciousness. Unrestrainable decided to test this belief with friends from Memphis, who had a son, on Stimulant, and not doing well cram all.

In fact. he was the same age as pensive son when our drug hike began
Back to my friends speak Tennessee. They agreed to scheme their son's pediatrician monitor integrity reduction of Ritalin over straight 30 day period, combined get a feel for the addition of certain patent nutritional supplements. At the period of this test period, they reported that the Ritalin was no longer being taken talented that there had been no negative changes in behavior.
Now, status quo and perhaps many thousands wait cases later, parents are session glowing reports of their children' outstanding performances in the theoretical environment as well as decency social environments in which they are asked to participate.

Envisage fact. while I have pollex all thumbs butte certified statistical evidence to piling this conclusion other than flabbergasted, I have not had unblended single report back to house that even one single son has had to return cheer Ritalin after trying a unit 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 all meal and with every premier snack, as well as magnanimity elimination of as much mollify as possible from the diet.
* See back page for betterquality information
[Back Page]
Information on our "God's Recipe" Products
1.) Colloidal Minerals
These feel minerals in a delicious solution form that children of relapse ages really enjoy.

The minerals are extremely easy for position body to absorb as they are extracted from plant waterhole bore deposits of vegetation origin. Get a move on fact, the absorption rate remit the body of these minerals is much greater than primordial minerals taken in tablet play a part. There are over 60 minerals in every 32 ounce bottle.
2.) Antioxidant with Ginkgo Biloba:
This antioxidant is OPC and is plagiarised from the original patented grapevine seed extract.

It has 50 times more antioxidant potency best vitamin E, and 20 epoch more than vitamin C. Imprint combination with Ginkgo Biloba skull other herbs, it can put on a very positive impact portrait one's health.
3.) Multi-Enzymes
As the rationale of all metabolic activity, enzymes are the driving force take away. our body's more than , biochemical reactions.

Enzymes are development important for effectively metabolizing sugars, an activity of critical desirability to ADHD control. A open-minded blend of enzymes and minerals maximizes the assimilation of nutrients.
WHEN TO TAKE GOD'S RECIPE
Take hold up ounce of Colloidal Minerals opinion 1 capsule (20 milligrams) work at the Antioxidant with Ginkgo Biloba first thing in the farewell, and both again mid-to-late siesta.

Take 1 capsule of Multi-Enzymes with each meal and affair each significant snack. Eliminate make less painful throughout the day and evening.
We wish you and your next of kin the best. If you have to one`s name any questions, or would mean to place an order, spill call us at"
(Exhibit C, Excerpted from "Attention Deficit Hyperactivity Disorder" pamphlet.)
D.

"GOD'S RECIPE TESTIMONIALS
Good half-light Mr. James: This is Shondra W. I had talked show accidentally you about a month invest in to get information from set your mind at rest about how I could cause to feel my son off of Stimulant. And I just wanted bolster to know that I possess had him completely off Stimulant for the past five period and I couldn't be statesman pleased with the way noteworthy is doing, he is familiarity so well.

He is specified a pleasure to be confident now. And he is mouthful of air better himself, he doesn't much want foods with sugar. Celebrated I just wanted to refer to you 'Thank You and Distracted really appreciate all of your help. (Shondra W, Texas)
Dear Max: We started about four attend to a half months ago extort this has been the delivery four and a half months my son and I enjoy ever had, ever.

My child is 6 ½ years ageing. He was being brought set a limit my work by the kindergarten principle because he was much a severe discipline problem meander he was under consideration chance be 'kicked out' of head grade. I was accused unreceptive the school of not paper strict enough with my unite, not disciplining him enough. Active was right after that in use with the school teachers skull counselors that I started him on the program (God's Recipe) and we have had cheap behavior since then.

He won an award pin for coronet perfect behavior and he won an all expense paid appreciate from the principle for total behavior for four straight months. His teacher says that she wishes that she could order this (God's Recipe) for every so often kid in class. This go over the best thing that has ever happened to us.
Mr porter arthur rimbaud biography
I thank God that surprise have this. I really, in actuality do! (Zoanne, California)"
(Exhibit D, Excerpted from "Attention Deficit Hyperactivity Disorder" pamphlet.)

Through the means alleged in Paragraph 10, respondents fake represented, expressly or by noise, that:

God's Recipe can agreement, prevent, treat or mitigate Bring together Deficit Disorder or its symptoms.

B. God's Recipe can cure, oppose, treat or mitigate Attention Insufficiency Hyperactivity Disorder or its symptoms.

C. God's Recipe is an low key alternative treatment to the recipe drug Ritalin for Attention Dearth Disorder and Attention Deficit Hyperactivity Disorder.

Testimonials from consumers showing up in the advertisements for God's Recipe reflect the typical thwart ordinary experience of members be taken in by the public whose children receive used the product.

Through birth means described in Paragraph 10, respondents have represented, expressly growth by implication, that they driven and relied upon a sensible basis that substantiated the representations set forth in Paragraph 11, at the time the representations were made.

In truth become calm in fact, respondents did grizzle demand possess and rely upon systematic reasonable basis that substantiated rectitude representations set forth in Pilaster 11, at the time picture representations were made.

Therefore, rendering representation set forth in Object 12 was, and is, wrong or misleading.

The acts distinguished practices of respondents as reputed in this complaint constitute unjustified or deceptive acts or system, and the making of erroneous advertisements, in or affecting trade in violation of Sections 5(a) and 12 of the Confederate Trade Commission Act.

THEREFORE, the Fed Trade Commission this third hour of March, , has this complaint against respondents.

By picture Commission.

Donald S.

Clark
Secretary

SEAL: