Complaint Counsel's Post Trial Brief - Federal Trade Commission
Complaint Counsel's Post Trial Brief - Federal Trade Commission
Complaint Counsel's Post Trial Brief - Federal Trade Commission
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priced with most other brands but with ours you get a great deal more. Remember you<br />
are not only getting 32 ounces per bottle, when some of the other brands are only 16<br />
ounces; you are also getting 2 more expensive herbs (Cat's Claw and Siberan Ginseng).<br />
We use 3 times the herbs and prepare each individually using a double water filterg<br />
process. If that is the case you must at least double the price they are asking to get equal<br />
price comparson." (CX 18 (emphasis added)).<br />
GDU<br />
87. GDU is a product that contains, among other ingredients, Bromelain, Turerc,<br />
Quercetin, Feverew, and Boron. (Answer ~ 10). Respondents' GDU product label<br />
directs users to take 3-6 capsules 2 to 4 times per day or as directed by a physician or by<br />
a BioMolecular Nutrtion health care professional. (Answer ~ 10; CX 17).<br />
88. Respondents offer GDU for $45.95 (300 capsules) and $29.95 (120 capsules). (Answer<br />
~ 10).<br />
89. Respondents pay Universal Nutrtion $3.28 per unt for the 120 tablet ( sic) bottle of GDU<br />
and $7.07 per unt for the 300 tablet (sic) bottle ofGDU. (R17 (Bauhoffer-Kiey, Dep.<br />
at 34-35)).<br />
90. Durg 2008, Respondents paid Universal Nutrtion approximately $5,127 to<br />
manufactue 1,709 unts ofthe 120 tablet (sic) bottle ofGDU and approximately $52,661<br />
to manufactue 7,523 unts ofthe 300 tablet (sic) bottle ofGDU. (R17 (Bauhoffer-<br />
Kiey, Dep. at 34-35)).<br />
BioMI<br />
91. BioMixx is a product that contains, among other ingredients, Goldenseal, Echiacea, and<br />
Ginseng. (Answer ~ 12). Respondents' product label for BioMixx directs users to take<br />
five scoops daily. (Answer ~ 12; CX 17).<br />
92. Respondents offer BioMixx for $40.95 (3 lb. powder) and $22.95 (lIb. powder).<br />
(Answer ~ 12).<br />
93. Respondents pay Universal Nutrtion $11.50 per unt for the 3 pound bottle of BioMixx.<br />
(R17 (Bauhoffer-Kinney, Dep. at 46)).<br />
94. Durng 2008, Respondents paid Universal Nutrtion approximately $8,778 to<br />
BioMixx. (R17 (Bauhoffer-Kinney, Dep.<br />
manufactue 798 unts of the 3 pound bottle of<br />
at 46)).<br />
2. Respondent James Feijo Controls Respondent DCO's Finances and<br />
Operations<br />
95. Respondent James Feijo is ultimately in charge of<br />
Tr. 112).<br />
8<br />
Danel Chapter One. (J. Feijo, HOJ
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