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
You also want an ePaper? Increase the reach of your titles
YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.
ww.danelchapterone.com. ww.7herbformula.com. ww.gdu2000.com. CCPF ~ 180. James<br />
and Patrcia Feijo also co-host the radio program, "Danel Chapter One Health Watch," on which<br />
they have counseled cancer patients who have called into the Danel Chapter One radio program<br />
about takng the DCO Products. CCPF ir 183-84.<br />
2. Respondents Sell Products to Consumers<br />
DCO curently offers consumers 150 to 200 products. CCPF ~ 8. DCO adverses those<br />
products on the Interet. CCPF ir 28, 134. Over one thousand consumers have purchased<br />
DCO's products. CCPF ~ 37. DCO has generated approximately $2 million in anual sales for<br />
-<br />
2006,2007, and 2008. CCPF ~ 38. DCO offers consumers coupons for their next online store<br />
order. CCPF ~ 52. Respondents ru promotions from time to time to "give (consumers) more of<br />
an opportty to . . . get thigs at a lower rate." CCPF ~ 53. For example, consumers can buy<br />
multiple bottles and get a bottle free. CCPF ~ 54. Consumers can also join DCO's Bucket-A-<br />
Month Club to obtain volume discounts on DCO's products. CCPF ~ 55.<br />
The DCO Products are expensive. An FTC investigator, Michael Maro, purchased one<br />
bottle of each ofthe four DCO Products, which together cost $175.75, including DCO's shipping<br />
and handling fee of$20.95. CCPF ~ 50-51. Consumers have expressed concers about<br />
Respondents' high prices, as evidenced, for example, by a comment on Respondents' Web site<br />
that, "I thnk (7 Herb Formula) costs too much." CCPF ~ 86.<br />
3. The DCO Products<br />
a. Bio*Shark<br />
Bio*Shark contains, among other ingredients, Shark Carlage. CCPF ~ 75. Each<br />
Bio*Shark label directs users to take 2-3 capsules thee times a day or as directed by a physician<br />
or by a "BioMolecular Nutrtion health care professional." CCPF ~ 75. Respondents invented<br />
4