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MLM Policy: A Closer Look at Possible Deceptive Nu Skin Websites

VitaMeal Update

Last week, DOJ and six other U.S. government agencies announced sweeping criminal and civil actions against

dietary supplement manufacturers for violations including deceptive marketing. The announcement came two days

after our November 16th article, which examined Nu Skin’s sales practices and possible UDAP violations as well

as the specific UDAP criteria that regulators examine, such as a reasonableness test to determine whether the

representation of the sale is likely to mislead “reasonable consumers”.

With many stakeholders wondering if there are specific examples in which Nu Skin distributors ask for “donations”

of VitaMeal – despite this being against company policy because Nu Skin is not a charity and the transaction is a

for-profit sale – The Capitol Forum recently conducted a quick internet search to identify screen shots of Millions

of Meals websites run by Nu Skin that promote the donation of VitaMeal, as well as screenshots of other distributor

websites.

This Internet search revealed at least twenty five examples of distributor sites that promote the donation of VitaMeal

and that also may highlight other possible violations of Nu Skin’s own policies and federal/state UDAP laws. Given

how central the donation theme is to the sale of VitaMeal and how widespread the potential violations appear to be,

our sources agree that websites run by Nu Skin and their independent distributors are deceptive in the way they

represent the sale of VitaMeal.

Millions of Meals Screenshots

November 23, 2015

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Distributor’s Screen Shots

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