VIA ELECTRONIC MAIL

TO: INTERNET ADVERTISERS OF CORAL CALCIUM PRODUCTS

RE: NOTICE OF POTENTIAL ILLEGAL MARKETING OF PRODUCTS TO TREAT OR CURE CANCER AND/OR OTHER DISEASES: IMMEDIATE ACTION REQUIRED

DATE: JUNE 10, 2003

Federal Trade Commission staff has reviewed marketing claims on your web site promoting a coral calcium product. This letter places you on notice that any claim that coral calcium is an effective treatment or cure for cancer and/or other diseases must be supported by competent and reliable scientific evidence. We are aware of no scientific studies supporting such claims. Without such evidence, the claims are illegal under the Federal Trade Commission Act and must be discontinued immediately. Violations of the FTC Act may result in legal action, which may in turn require you to pay money back to consumers.

The FTC recently has taken legal action against a group of individuals and companies in connection with the advertising and sale of a coral calcium product. In that case, FTC v. Kevin Trudeau, Robert Barefoot, et al., the FTC alleges that the defendants violated the FTC Act by claiming, falsely or without substantiation, that Coral Calcium Supreme is an effective treatment or cure for cancer, multiple sclerosis, heart disease, and other diseases. The FTC is seeking refunds for all consumers who purchased the product. A copy of the complaint in that case is attached as a PDF file.

You are responsible for all claims, whether express or implied, that are made on your web site. Please note that consumer testimonials constitute claims that your product will provide the advertised benefit, and therefore such testimonials also must be supported by competent and reliable scientific evidence. We strongly urge you to review all claims on your web site immediately, and to delete or revise those claims as necessary to comply with the law.

You also should be aware, if you are marketing a dietary supplement, that FDA law prohibits any labeling claims that a dietary supplement is intended to prevent, mitigate, treat, or cure cancer or any other disease under the Federal Food, Drug, and Cosmetic Act as amended by the Dietary Supplement Health and Education Act of 1994. Such claims would cause the product to be a drug and would require that the product comply with the applicable drug requirements, including that the product be submitted for FDA approval as a new drug before it can be marketed.

The FTC staff strongly urges you to review the claims you are making for coral calcium. If your web site includes any express or implied claim about the benefit of any coral calcium product for cancer or other diseases that is not substantiated by competent and reliable scientific evidence, or is otherwise false or deceptive, you must discontinue these claims immediately.

FTC investigators have copied and preserved the pages of your online promotional materials and will be revisiting your web site soon.

Please notify us via electronic mail to coralcalcium@ftc.gov within 7 days of the specific actions you have taken to address the agency's concerns. If you have any questions, please contact the staff of the Division of Advertising Practices at (877) 862-0886, ext. 4.

C. Lee Peeler
Deputy Director
Bureau of Consumer Protection
Federal Trade Commission