# Source: FTC Warning Letter to dōTERRA International, LLC (April 2020) **Type:** source **Status:** Draft **Confidence:** High **Source Type:** government-record **URL:** https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_doterra_international_llc.pdf **Archive:** https://web.archive.org/web/20260619134545/https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_doterra_international_llc.pdf **Archived:** 2026-06-19 **Publisher:** U.S. Federal Trade Commission **Retrieved:** 2026-08-12 **Raw:** raw/ftc-warning-letter-doterra-2020/2026-08-11-28d61f96eb99.txt **Published:** 2020-04-24 **Updated:** 2026-08-11 ## Summary The FTC staff letter of April 24, 2020 to doTERRA International, LLC of Pleasant Grove, Utah, one of [ten sent that day](ftc-mlm-covid-warning-letters-2020.md) and one of three to Utah companies. It reproduces social-media posts by doTERRA Wellness Advocates advertising essential oils as coronavirus protection — including a post claiming the virus can be beaten by eating alkaline foods and naming doTERRA lemon, lime, tangerine, wild orange and ginger oils — alongside posts pitching the business opportunity to people who had just been laid off. The letter's operative content is the FTC's statement of law: a disease-prevention claim requires competent and reliable scientific evidence, no such evidence existed for COVID-19, and the company must make its participants stop. It also states that doTERRA is responsible for its participants' claims and must both instruct and monitor them, citing the FTC's January 2019 MLM business guidance. For the wiki this is a primary record with two uses. It establishes doTERRA's Utah headquarters address from a federal document, and it is direct evidence of the compliance problem structurally built into a sales force of hundreds of thousands of independent contractors: the company did not publish these claims, and the FTC's position is that this does not matter. ## Useful Claims - The FTC addressed the letter to doTERRA International, LLC at 389 South 1300 West, Pleasant Grove, Utah 84062 — a federal record of the company's Utah headquarters as of April 2020. - FTC staff reviewed posts by doTERRA "business opportunity participants or representatives" that advertised products as treating or preventing COVID-19 and misrepresented likely earnings. - Quoted health claims are participant posts, not company advertising: essential oils framed as "protection" for medical responders and grocery clerks, oil bottles hashtagged "#covid #prevention," and an alkaline-pH theory of beating the virus naming specific doTERRA oils. - Quoted earnings claims target the newly unemployed — "Were you laid off/ #fired? Be your own Boss w/doTERRA essential oils." - The FTC's legal position: disease claims require competent and reliable scientific evidence; for COVID-19 no such study was known to exist; the company must immediately cease such claims. - The FTC's responsibility rule: an MLM must direct participants not to make false or unsubstantiated representations **and** monitor them, per the January 2019 Business Guidance Concerning Multi-Level Marketing. - doTERRA was given 48 hours to describe the actions it had taken. ## Verbatim > "doTERRA International, LLC c/o Mark A. Wolfert, General Counsel 389 South 1300 West Pleasant Grove, > Utah 84062" > — Addressee block > "FTC staff has reviewed social media posts made by doTERRA International, LLC ('doTERRA') business > opportunity participants or representatives that unlawfully advertise that certain products treat > or prevent Coronavirus Disease 2019 (COVID-19) and misrepresent that consumers who become doTERRA > business opportunity participants are likely to earn substantial income." > — Opening paragraph > "This is to inform us all that the pH for corona virus varies from 5.5 to 8.5…. All we need to do, > to beat corona virus, we need to take more of an alkaline foods that are above the above pH level > of the Virus." > — Quoted participant post, health-claim examples > "Need to make extra money? Find it difficult to pay your bills? Were you laid off/ #fired? Be your > own Boss w/doTERRA essential oils. Msg me to achieve financial independence" > — Quoted participant post, earnings-claim examples > "As a consequence, an MLM should (i) direct its participants not to make false, misleading, or > unsubstantiated representations and (ii) monitor its participants so they don't make false, > misleading, or unsubstantiated representations." > — Quoting the FTC's January 2019 Business Guidance Concerning Multi-Level Marketing ## Reliability Notes **Primary, and narrow.** This is a record the FTC created in the course of its enforcement work, so it is primary tier — but it is primary evidence of *what the FTC said*, not of a finding. A warning letter contains no adjudication and doTERRA admitted nothing by receiving one. Any page citing it must say the FTC warned the company about claims made by its participants. **The quoted posts are participants', not the company's.** The letter is explicit that the reviewed posts were made by business-opportunity participants or representatives. Attributing the alkaline-pH claim to doTERRA itself would misstate the document. **Nearly identical to its siblings.** The [Tranont](ftc-warning-letter-tranont-2020.md) and [Modere](ftc-warning-letter-modere-2020.md) letters share this letter's legal paragraphs verbatim; only the addressee and the quoted examples differ. That is worth knowing before treating the shared language as company-specific: it is a template, and the boilerplate is quoted here once rather than three times. **Outcome unknown from this document.** The letter demanded a 48-hour response; the response, and whatever doTERRA did about the posts, are not in the record captured here. For the company's own current account of participant earnings see the [2026 earnings disclosure](doterra-earnings-disclosure-2026.md). **Capture detail.** The raw file is text extracted from the FTC's PDF; the bullet glyphs that mark each quoted example do not survive extraction, so quoted posts appear as paragraphs. ## Related Pages - [Utah's Direct-Selling Industry](utah-direct-selling-industry.md) - [FTC Announcement of Warning Letters to Ten Multi-Level Marketers (2020)](ftc-mlm-covid-warning-letters-2020.md) - [dōTERRA 2026 Opportunity and Earnings Disclosure Summary](doterra-earnings-disclosure-2026.md)