Source: FTC Warning Letter to Modere, Inc. (2020)

Summary

The FTC staff letter of April 24, 2020 to Modere, Inc. of Springville, Utah — the third of the three Utah letters sent that day, and the one whose quoted earnings pitch is dated most precisely to the collapse of the labor market. A participant video the FTC reproduces cites the 3.3 million unemployment claims filed the previous week and offers viewers the chance to "make an extra $200, $300, $400, $500 right part time right now."

The quoted health claims follow the same pattern as the other letters: participants marketing an immune-support product as a "Standard coronavirus protection kit" and, in one post, telling readers to "forget about toilet paper" because a Modere formula "will assist the immune and respiratory systems."

The legal content is the standard April 2020 template — substantiation for disease claims, Section 5 on earnings claims, and the company's duty to both instruct and monitor its participants.

Useful Claims

• The FTC addressed the letter to Modere, Inc. c/o General Counsel Michelle Wilson at 588 S 2000 W, Springville, Utah 84663 — a federal record of the company's Utah headquarters as of April 2020.
• Quoted participant health claims present Modere products as coronavirus protection, including a "Standard coronavirus protection kit" post and an immune/respiratory-system claim.
• The quoted earnings pitch is explicitly keyed to pandemic job losses, citing 3.3 million unemployment filings in a single week and offering part-time income of a few hundred dollars, with the speakers describing themselves as "7-figure earners."
• A second quoted post offers "earning $500-$1500 a month from home."
• Modere was placed in the group warned about both health and earnings claims, and given 48 hours to report remedial action. No violation was found.

Verbatim

"Modere, Inc. c/o Michelle Wilson, General Counsel 588 S 2000 W Springville, Utah 84663" — Addressee block

"STAY SAFE!! MAKE YOUR IMMUNE SYSTEM STRONG!!! Standard coronavirus protection kit . #antiseptics and #immunity_support." — Quoted participant post, health-claim examples

"We have been so blessed as 7-figure earners and we are here to help you, achieve your financial or time freedom goals" — Quoted participant video description, earnings-claim examples

"In the United States alone, 3.3 million people filed for unemployment last week alone. So guess what? They're looking to make an extra $200, $300, $400, $500 right part time right now." — Quoted participant video, earnings-claim examples

"Connect with me to talk about earning $500-$1500 a month from home." — Quoted participant post, earnings-claim examples

Reliability Notes

Primary record of an allegation. Created by the FTC in the course of its enforcement work, so primary tier — but it contains no finding and no admission. Cite it as "the FTC warned Modere about claims by its participants."

The claims are participants', and the letter says so. All quoted material is attributed to "business opportunity participants or representatives." The FTC's theory is that Modere is responsible for them regardless; that is not the same as Modere having advertised them.

Shared template. The paragraphs of law match the doTERRA and Tranont letters word for word, so the boilerplate is quoted once, on the doTERRA page.

Modere's Utah presence is dated. This letter fixes a Springville address for April 2020 and nothing later; Modere's corporate arrangements have changed since, and this document cannot be used for its current status. The company has no wiki fact page, and a warning letter alone does not warrant one.

Capture detail. Text extracted from the FTC's PDF. The stray space in "protection kit ." and the misplaced quotation mark in the video passage are artifacts of the original document's typography, preserved so the quotes match the capture.

Related Pages

• Utah's Direct-Selling Industry
• FTC Announcement of Warning Letters to Ten Multi-Level Marketers (2020)
• FTC Warning Letter to dōTERRA (2020)