Source: FTC Announcement of Warning Letters to Ten Multi-Level Marketers (2020)

Summary

The FTC's April 24, 2020 announcement that it had sent warning letters to ten multi-level marketing companies over claims — made by the companies or by their distributors — that products could treat or prevent COVID-19, or that people who had just lost income could earn substantial money by signing up. The agency notes this was the first batch of pandemic warning letters to cover earnings claims as well as health claims.

The value of this page is the recipient list, because it is the FTC naming who it thought was worth warning at the moment unemployment claims spiked. Three of the ten are Utah-headquartered — doTERRA (Pleasant Grove), Tranont (Lehi), and Modere (Springville), all in the "Both Health and Earnings Claims" group — and each individual letter is captured separately, which is where the letters' actual text and the quoted distributor posts live.

The release also states the FTC's theory of responsibility plainly: a company is answerable for what its distributor network says. That is the legal hinge on which the wiki's coverage of the Utah industry's compliance record turns.

Useful Claims

• The FTC sent 10 warning letters on 2020-04-24 to MLM companies over product claims about coronavirus, earnings claims aimed at the newly unemployed, or both.
• Utah recipients, all in the both-health-and-earnings group: doTERRA International, LLC; Tranont; Modere, Inc. The other seven were Pruvit Ventures, Total Life Changes, Arbonne International, IDLife, It Works Marketing, Rodan & Fields, and Zurvita.
• The FTC's position is that MLMs are responsible for the product and earnings claims their distributors make — stated on the record by the Director of the Bureau of Consumer Protection.
• This was the first FTC coronavirus warning-letter batch to include earnings claims alongside health claims, tied explicitly to the pandemic's economic fallout.
• Recipients were instructed to report back within 48 hours on what they had done. A warning letter is not an enforcement action and carries no finding of violation.

Verbatim

"The Federal Trade Commission today announced it has sent 10 letters warning multi-level marketing companies (MLMs) to remove and address claims that they or their participants are making about their products' ability to treat or prevent coronavirus disease or about the earnings people who have recently lost income can make, or both." — Opening paragraph

"MLMs and other companies that distribute their products through networks of distributors are responsible for the product and earnings claims those distributors are making" — Andrew Smith, Director, FTC Bureau of Consumer Protection

"The FTC has previously sent a number of warning letters about health claims related to the coronavirus pandemic, but this group of letters is the first to also include warnings related to claims about potential earnings related to the economic fallout from the pandemic." — Body

"The letters instruct the recipients to notify the FTC within 48 hours about the specific actions they have taken to address the agency's concerns." — Body

Reliability Notes

A press release about primary records, not the records. This page is typed press-release (self-reported tier) because it is the agency's account of its own action. The letters themselves are the primary records and are captured individually — see doTERRA, Tranont, and Modere. Quote the letters for what the FTC told a company; quote this release only for the fact and shape of the batch.

A warning letter alleges; it does not adjudicate. No recipient was found to have violated anything by receiving one, and any page citing this should say "the FTC warned X about claims made by it or its distributors," never "X was found to have made false claims."

On who made the claims, the release is deliberately ambiguous and this page should not resolve it. It says the letters highlight "specific claims made by the companies or their distributors", and it does not attribute either of its two quoted examples to one or the other. Elsewhere it goes further than the distributor framing: the FTC "states that one or more of the efficacy claims made by the companies are unsubstantiated," and it notes parenthetically that It Works Marketing "was also itself warned to stop making earnings claims." So the record supports company-or-distributor and, in the efficacy letters, company claims — not the reading that this was only distributors' social media.

Recipient grouping matters. The FTC split the ten into health-and-earnings, earnings-only, and health-only groups. The three Utah companies are all in the first, which is the most serious of the three, and that grouping is the release's own.

Capture detail. The raw capture is the full rendered ftc.gov page, so it carries the site's navigation chrome around the release body; the quoted material is in the release itself, below the "For Release" heading.

Related Pages

• Utah's Direct-Selling Industry
• FTC Warning Letter to dōTERRA (2020)
• FTC Warning Letter to Tranont (2020)
• FTC Warning Letter to Modere (2020)