CC Pollen Company

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IN THE MATTER OF CC POLLEN COMPANY, ET AL.

CONSENT ORDER, ETC., IN REGARD TO ALLEGED VIOLATION OF SECS. 5 AND 12 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3419. Complaint, March 16, 1993--Decision, March 16, 1993 This consent order prohibits, among other things, a Phoenix-based firm, and its owners, from making false claims about the effect consumption of their bee pollen products has in regard to allergies, aging, impotence, sexual dysfunction, weight loss and antibiotic treatment, and requires that they have scientific evidence to support any other health-benefit claims they make about any food or other product for human consumption, in the future. In addition, the respondents are prohibited from producing or distributing any advertisement that is represented to be something other than a paid ad, and are required to prominently disclose in all future infomercials they create that the programs are paid ads. Finally, the respondents are required to pay $200,000 as disgorgement of profits.

Appearances For the Commission: Brinley H. Williams, Michael Milgrom and Melissa R. Sternlicht.

For the respondents: Daniel C. Smith, Arent, Fox, Kintner, Plotkin & Kahn, Washington, D.C.

COMPLAINT The Federal Trade Commission, having reason to believe that CC Pollen Company, a corporation, and Bruce R. Brown, Carol M. Brown, and Royden Brown, individually and as officers and/or directors of said corporation (“respondents”) have violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, alleges:

CC POLLEN COMPANY, ET AL. 207 206 Complaint PARAGRAPH 1. Respondent CC Pollen Company is a corporation organized, existing and doing business under and by virtue of the laws of the State of Arizona, with its office or principal place of business located at 3627 East Indian School Road, Suite 209, Phoenix, Arizona.

Respondents Bruce R. Brown, Carol M. Brown, and Royden Brown are officers and/or directors of the corporate respondent named herein. They formulate, direct and control the acts and practices of said corporate respondent, including the acts and practices hereinafter set forth. Their addresses are the same as that of the corporation.

PAR. 2. Respondents have advertised, offered for sale, sold and/or distributed food products, including bee pollen products (various products containing bee pollen, and/or bee propolis, and/or royal jelly) intended for human consumption. Bee pollen products are “foods” or “drugs” within the meaning of Section 12 of the Federal Trade Commission Act, 15 U.S.C. 52.

PAR. 3. The acts and practices of respondents alleged in this Complaint have been in or affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act, 15 U.S.C. 44.

PAR. 4. Respondents have disseminated or caused to be disseminated advertisements for bee pollen products. These advertisements have been disseminated by various means in or affecting commerce, including, but not limited to, television signals transmitted across state lines, for the purpose of inducing the purchase of bee pollen products by members of the public. These advertisements include, but are not necessarily limited to, two television productions, “The Search for the Fountain of Youth” (transcript attached hereto as Exhibit A, copy of program attached as Exhibit D) and “TV Insiders” (transcript attached hereto as Exhibit B, copy of program attached as Exhibit C), and the print advertisements attached hereto as Exhibits E and F, PAR. 5. The aforesaid television productions contain the following statements and depictions:

Complaint 116 F.T.C.

(A) MR. MURPHY: Ladies and gentlemen, the show you're about to see was first broadcast a few months ago. Since that time, we have received literally thousands of letters, some of which I'd like to share with you. But let us first watch the show that changed the lives of so many people. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (B) Norman Errington Productions Presents “The Search for the Fountain of Youth.” (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (C) MR. MURPHY: Welcome to our program to explore new ways to improve your life. I'm your host, Paul Murphy. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (D) MR. MURPHY: Across the world’s cultures, we found similarities in their style of living that seem to unlock some of the mysteries of longevity. Many of these cultures have groups who have extended their years, and we found that each of these cultures has a common link. And we'll be exploring these similarities. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (E) MR. MURPHY: “The Search for the Fountain of Youth” is not offering any medical miracles, nor are we making any medical claims at all in this report. We're simply going to present the facts as we have found them, so you can explore this phenomenon with us. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (F) MR. MURPHY: We’ll be back in a minute with more information on our search for the Fountain of Youth. First, we’ll meet Noel Johnson, who is turning back the pages of time. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.’’) (G) Title of 30-minute television program: “TV Insiders.” (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.”) (H) MR. INNEO: Hello, I'm Vince Inneo, your inside information investigator. Welcome to this very special edition of “TV Insiders.” No matter what walk of life or what the subject, it’s no secret that having inside information keeps you steps ahead of the others. That’s why we're here. This installment is critically important. Many of you have written possibly the most valuable inside information we have yet uncovered. Here are some of the hundreds of letters asking us or telling us about a 73-year-old Phoenix, Arizona man who many of you have claimed has rediscovered nature's formula for youth. Listen to some of these amazing stories. (Exhibit B, transcript; Exhibit C, video tape of TV Insiders.) (J) MR. INNEO: Let me restate something. It’s your cards and your letters alerting “TV Insiders” to new discoveries, interesting people and inside information. We need inside information. You tell me the stories and what you’ve heard, we will research it, investigate it, and we will share our findings with everyone. If we use your information, we will send you a “TV Insiders” CC POLLEN COMPANY, ET AL. 209 206 Complaint investigator’s card. This you can count on. So until next mission, this is your inside investigator, Vince Inneo, wishing you good health and God's blessings. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.”) (J) Statements and depictions of apparent unpaid, spontaneous, and unscripted interviews between Vince Inneo and Dr. Gary Null, Ms. Carol Brown, and Mr. Royden Brown. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.’’) (K) Statements and depictions that portray individuals as users of bee pollen products who have submitted unsolicited testimonials to “T'V Insiders.” (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.”) (L) All materials, whether real or recreated, represent factual events. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.”’) PAR. 6. Through the use of the statements contained in the advertisements and promotional materials referred to in paragraph five, including, but not necessarily limited to, the advertisements attached as Exhibits A, B, C and D, respondents have represented, directly or by implication, that “The Search for the Fountain of Youth” and “TV Insiders” are not paid-for advertisements, but rather are independent and objective documentary or news programs. PAR. 7. In truth and in fact, “The Search for the Fountain of Youth” and “TV Insiders” are paid-for advertisements and not independent and objective documentary or news programs. Therefore, the representations set forth in paragraph six, above, were and are false and misleading.

PAR. 8. The aforesaid advertisement also contains the following statements:

(A) MR. MURPHY: Across the world’s cultures, we found similarities in their style of living that seem to unlock some of the mysteries of longevity. Many of these cultures have groups who have extended their years, and we found that each of these cultures has a common link. And we'll be exploring these similarities. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (B) DR. JENSEN: There’s no doubt in my mind that bee pollen is the one thing I have found in all of my travels and in all of my experience that brings on long life and good health. (Exhibit A, transcript, Exhibit D, video tape of “The Search for the Fountain of Youth.”) (C) UNIDENTIFIED SPEAKER: Now, for the first time, the magic of High Desert Bee Pollen is available with this television offer. If you want to feel a Complaint 116 F.T.C.

renewed vitality and increased energy, then you may wish to order today. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (D) UNIDENTIFIED SPEAKER: If you order today, we will also include a thirty-day supply of chewable royal jelly tablets for longevity. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (E) MR. MURPHY: Bee pollen is the answer to mankind’s quest for the Fountain of Youth. Bee pollen is the activating substance which rejuvenates and slows the aging process. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (F) MR. MURPHY: Leading British medical authority, Dr. G. J. Binding, provides a scientific viewpoint: “Pollen is the finest, most perfect food. A giant germ killer in which bacteria simply cannot exist.” (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.) (G) DR. JENSEN: There's no doubt in my mind that the High Desert Bee Pollen is one thing that I have felt will bring more health, more longevity, a greater power in that body, for the rest of your life. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (H) MR. MURPHY: Dr. Jensen speaks as an expert. He has spent a lifetime looking for ways to increase longevity. He’s traveled to hundreds of places on earth where longer lives share a common thread with each of these cultures. And that thread is bee pollen. (Exhibit A, transcript; Exhibit D, video tape of “The Search for the Fountain of Youth.”) (I) MR. ROYDEN BROWN: ... Royal Jelly is the greatest rejuvenating and sex stamina food known to man, and you certainly want to have, be active sexually al] the rest of your life. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.’’) (J) MR. INNEO: For those people who are allergic to pollen, will they be able to use Mountain-High Bee Pollen? MR. BROWN: Bee pollen according to Leo N. Conroy, M.D. in Denver, Colorado, an allergist, says that bee pollen is the best reliever of allergies that he's ever found. He's had, he had over 60 thousand patients documented and 94 percent of them were completely relieved of the symptoms by ingesting the bee pollen.

MR. INNEO: Never have pollen-related allergies again? MR. BROWN: Never have pollen allergy symptoms again, rest of their lives. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.”) (K) MR. INNEO: I’ve heard from people that Mountain-High Bee Pollen helps them lose weight. Can you tell me how? MR. BROWN: Well, Mountain-High Bee Pollen has all the nutrients you need for perfect health. So when you eat the Mountain-High Bee Pollen before each meal, it satisfies your appetite. As a result, you eat a little less food with each meal you eat and you lose weight constantly as long as you're eating the CC POLLEN COMPANY, ET AL. 211 206 Complaint Mountain-High Bee Pollen. (Exhibit B, transcript; Exhibit C, video tape of “TV Insiders.’’) (L) Propolis is considered the strongest of the natural antibiotics. . . . Propolis is widely recommended by natural health-care practitioners in preference to chemical antibiotics in many conditions where an antibiotic is useful. . . . [Propolis] is being enthusiastically welcomed as the strongest of the natural “preventative” medicines. (Exhibit E, portion of CC Pollen Company printed advertisement.) (M) Extra High Potency High Desert Honeybee Pollens: 6. Weight Control...

10. Increased Sexual Stamina & Endurance...

11. Long Lives are attained by bee pollen users . . . (Exhibit F, topic headings, portion of CC Pollen Company printed advertisement.) PAR. 9. Through the use of the statements contained in paragraph eight, above, including, but not necessarily limited to, the advertisements attached as Exhibits A, B, C, D, E and F, respondents have represented, directly or by implication, that: (A) Consumption of any bee pollen product cannot result in an allergic reaction;

(B) Consumption of CC Pollen Company’s bee pollen products will permanently alleviate all of the consumer’s pollen allergy symptoms;

(C) Consumption of bee pollen products slows or prevents or reverses the aging process;

(D) Consumption of bee pollen products can cure, or prevent, or alleviate impotence and/or sexual dysfunction; (E) Consumption of bee pollen products causes weight loss; (F) Bee pollen products, such as those advertised by CC Pollen Company, are an effective antibiotic for human use. PAR. 10. In fact and in truth:

(A) Consumption of a bee pollen product can result in an allergic reaction;

Complaint 116 F.T.C.

(B) Consumption of CC Pollen Company’s bee pollen products will not permanently alleviate all of the consumer’s pollen allergy | symptoms;

(C) Consumption of bee pollen products does not slow or prevent or reverse the aging process;

(D) Consumption of bee pollen products cannot cure, or prevent, or alleviate impotence and/or sexual dysfuction; (E) Consumption of bee pollen products does not cause weight loss;

(F) Bee pollen products, such as those advertised by CC Pollen Company, are not an effective antibiotic for human use. Therefore, the representations set forth in paragraph nine, above, were and are false and misleading.

PAR. 11. Through the use of the statements set forth in paragraph eight and others not specifically set forth herein, respondents have represented, directly or by implication, that at the time they made the representations set forth in paragraph nine, respondents possessed and relied upon a reasonable basis for each such representation.

PAR. 12. In truth and in fact, at the time respondents made the representations set forth in paragraph nine, they did not possess and rely upon a reasonable basis for making each such representation. Therefore, respondents’ representation as set forth in paragraph eleven was and is false and misleading.

PAR. 13. The acts and practices of respondents as alleged in this complaint, and the placement in the hands of others of the means and instrumentalities by and through which others may have used said acts and practices, constitute unfair and deceptive acts or practices in or affecting commerce, and the dissemination of false advertisements, in violation of Sections 5(a) and 12 of the Federal Trade Commission Act.

CC POLLEN COMPANY, ET AL. 213 206 Complaint EXHIBIT A AUDIO TEXT VIDEO STATEMENTS Norman Errington Productions Presents The Search for the Fountain of Youth MURPHY: Ladies and gentlemen, the show you’re about to see was first broadcast a few months ago. Since that time, we have received literally thousands of letters, some of which Id like to share with you. But let us first watch the show that changed the lives of so many people.

MURPHY: Welcome to our program to explore new ways to improve your life. I’m your host, Paul Murphy. For centuries, mankind has searched for that elusive Fountain of Youth. Ponce de Leon spent his entire life searching. Others have traveled and visited ancient cultures, hoping to find clues and answers. For centuries, people have looked for ways to renew that youthful vitality, and for ways to live longer and more productive lives. What we're about to present to you may change your life. Across the world's cultures, we found similarities in their style of living that seem to unlock some of the mysteries of longevity. Many of these cultures have groups who have extended their years, and we found that each of these cultures has a common link. And we'll be exploring these similarities.

The locations of these cultures range from the mountains of Tibet to the rich heritage of Aztec and Mayan civilizations, in Europe and to the Orient. One thing we've found is that America is behind in reaching for those lessons to provide longer and healthier lives.

The man who has obviously bathed in the Fountain of Youth is this nearly 90year-old man they call Superman. Twenty-five years ago he was not able to walk and his son wanted him to go to a nursing home because of poor health. We're going to meet Noel Johnson. Not only did he stay out of the nursing home and prove his doctors wrong, this Superman is the oldest person to ever complete the New York Marathon. He's treated like a king in Thailand; he's appeared on hundreds of television programs, and he's a national treasure for his ability to overcome aging. He improves his condition with every marathon he runs. We'll meet Bob Kite. He's an athlete who doesn’t fit the mold. Due to his heavy business schedule, he's unable to work out on a regular basis, so he relies on an energy source to carry him to victory in some of the toughest endurance races in the world.

In the next few minutes, we'll also meet the father of the health food movement today, Dr. Bernard Jensen. Dr. Jensen has traveled the world searching for the answers to provide information on how all of us can live more vital lives. He's studied cultures across the world, and you'll be surprised at his findings. Complaint 116 F.T.C.

And we'll meet a man who has devoted the past 30 years to a mission, to find the Fountain of Youth. His travels led him down many roads. He's developed a company devoted to providing the Fountain of Youth. The Search for the Fountain of Youth “The Search for the Fountain of Youth" is not offering any medical miracles, nor are we making any medical claims at all in this report. We're simply going to present the facts as we have found them, so you can explore this phenomenon with us. It's not surprising today that people are turning away from medicines to treat the sick and turning to wellness efforts to ensure the well-being of people before they become sick. :

This is a story that begins almost a half-century ago in war-torn England. An American from Eaton, Colorado, volunteered to assist the Royal Canadian Air Force in England. His story will have a remarkable effect on the American quest for vitality. Royden Brown was first introduced to the opportunity for improvements in health through nutrition in 1943 at an officers’ dining table. He was introduced to a food that changed his life and changed others’. MURPHY: Royden, are the benefits of bee pollen a recent discovery? BROWN: Bee pollen was on earth before man. It's as old as antiquity. Bee pollen and the products of the beehive are ... were ... found in the tombs of the pharaohs of Egypt, five and six thousand years ago. The products of the beehive have been reverenced in all major religions. The Torah, the code of Islam, the scrolls of the middle east, the writings of China, everywhere, the products of the beehive have been held in reverence.

For example, in the St. James version of the Bible, they're mentioned 68 times. And, of more recent vintage, the risen Jesus Christ, when He came back to earth, the first food He ate was bee pollen. God had Him eat bee pollen, symbolically, for the reason that Man was supposed to make bee pollen an integral part of his life.

MURPHY: Why haven’t we heard more about the positive aspects of bee pollen? BROWN: Mainly because the pharmaceutical companies cannot patent bee pollen and make their 40- and 50-times markup of their cost. Bee pollen is a low- - profit food.

MURPHY: Let's find out a little more about the magic of bee pollen. In every corner of the earth, we're blessed with flowers. Ever wonder about the purpose of flowers? They provide beauty to the eye and a lift to the spirit. Scientists have found a far greater purpose. Wildflowers provide a source for honeybees who must visit 1,500 individual flowers to collect just one granule of bee pollen. Just one tablet of bee pollen can contain pollen from as many as 100,000 flowers. Bee pollen has been called Nature's5 1 5 8 7 9 1501 2554 109 38 96.941444 perfect5 1 5 8 7 10 1621 2554 85 29 80.642159 food because it has CC POLLEN COMPANY, ET AL. “215 206 Complaint everything the body requires - all the protein, all the minerals, and a great source of energy. It's the essence of life itself.

Bee pollen is brought back to the hive and is collected in special traps. In addition to pollen, another element of the hive is royal jelly. Now, just as the name implies, royal jelly is given to a selected bee and that alone makes an ordinary bee the queen. Not only does the royal jelly create the queen, it also extends her life from an average of 35 days to five or six years. Depiction of Print Article Containing Royal Family Photos and Headline: Secret Love Potion Made Fergie Pregnant It's been reported in newspapers and magazines for years that the Royal Family has used royal jelly. Although the Royal Family is obviously protective of all information, the British press regularly features the Royal Family's use of royal jelly. The press also has highlighted reports that the Queen Mother attributes royal jelly for her remarkable stamina and that Princess Anne uses it when she competes in equestrian évents. It's even been reported that the Queen herself takes extra royal jelly when she has particularly arduous engagements to undertake. We'll be back in a minute with more information on our search for the Fountain of Youth. First, we'll meet Noel Johnson, who is turning back the pages of time.

JOHNSON: I’m Noel Johnson from San Diego, California. I'll soon be 90 years old. I'm running marathons, I'm boxing - a World Senior Boxing Champion. I’m a bee pollen lover. I use bee pollen every day of my life. Without the bee pollen, you cannot have the energy to continue to live. High5 1 5 1 1 2 985 1839 106 29 96.752144 Desert5 1 5 1 1 3 1103 1839 62 29 96.616440 Bees 1 5 1 1 4 1177 1839 119 29 92.243889 Pollen Candy Bars and Pills VOICE-OVER: Now, for the first time, a special selection of High Desert Bee Pollen products are available through this television offer. You will receive a selection of the delicious bee pollen bars, the President's and First Lady's lunch bars, plus your kit will include a 30-day supply of Pollenergy and one box of bee pollen honey chewable tablets.

Call Toll-Free Number or Send Check or Money Order If you order today, we will also include a supply of chewable royal jelly tablets. To order your Presidential energy assortment with Visa or Mastercard, call toll-free 1-800-321-5100 or send check or money order for $39.95 plus $3.50 for postage and special handling to Tele-Mart, Box B, Elfers, Florida 34680. Complaint 116 F.T.C.

The Search for the Fountain of Youth MURPHY: Welcome back to Thes 1 3 1 1 6 1279 668 108 30 96.755173 Search5 1 3 1 1 7 1401 668 48 30 96.346901 for5 1 3 1 1 8 1460 669 48 30 96.346901 thes 1 3 1 1 9 1521 670 142 30 96.724213 Fountains 1 3 1 1 10 1677 671 35 30 97.012077 of5 1 3 1 1 11 1723 671 125 30 96.256744 Youth. We found one man who actually seems to be growing younger. Now you may not believe the growing success of Noel Johnson, but his unique story has been the focus of national magazine articles, with Dan Rather special profiles on national television, and in national magazines. And he's now treated like a prince in many countries for his ability to battle the ravages of time. David Letterman called him Superman and he's now astounding medical doctors as he approaches his ninetieth birthday - Let's meet Noel Johnson. He's a world-class marathon runner - that's a 26-mile run. He's a world-class boxer. He's defeated boxers half his age. His name is synonymous with longevity throughout the world. Simply, he’s reversed the aging process. Recently, Reader's Digest summarized the success story of Noel Johnson. At 70, Noel K. Johnson of San Diego had heart trouble, arthritis and gout. He drank too much. He was 50 pounds overweight. He was in such bad shape that his son suggested he enter a nursing home. Today, at nearly 90, he's a trim 138 pounds and claims his afflictions have disappeared. We had a chance to meet the remarkable Noel Johnson. JOHNSON: My son one day came over and said that, Dad, he says, Why4 1 3 3 2 0 596 1489 1320 41 -1 5 1 3 3 2 1 596 1489 84 29 96.636742 don’t5 1 3 3 2 2 693 1498 57 29 97.013145 you5 1 3 3 2 3 764 1498 39 29 96.948906 go5 1 3 3 2 4 816 1495 29 23 96.564293 to5 1 3 3 2 5 859 1498 16 20 95.762810 a5 1 3 3 2 6 887 1490 167 29 95.762810 retirement5 1 3 3 2 7 1067 1491 89 29 96.656326 homes 1 3 3 2 8 1169 1500 33 20 95.811638 or5 1 3 3 2 9 1214 1491 207 38 93.736618 someplace? He says, You5 1 3 3 2 13 1683 1494 75 28 96.513367 can't5 1 3 3 2 14 1771 1494 66 29 96.982506 takes 1 3 3 2 15 1849 1503 67 21 96.996910 care4 1 3 3 3 0 595 1537 1319 41 -1 5 1 3 3 3 1 595 1537 35 29 96.949722 of5 1 3 3 3 2 638 1547 73 28 97.003387 yours 1 3 3 3 3 722 1537 83 38 97.001495 places 1 3 3 3 4 817 1546 55 29 96.377357 any5 1 3 3 3 5 885 1539 105 28 95.182289 more. And he was right. I didn't argue with him. So I decided, well, there must be something wrong in this world when a person has to be put away when you're seventy, seventy-five years old. Everybody seems to be that way. Ail my neighbors and things were that way, so why shouldn’t I be that way, and I questioned it. I thought, Well,5 1 3 3 7 8 1237 1731 68 37 96.955124 why5 1 3 3 7 9 1321 1731 73 29 96.991959 does5 1 3 3 7 10 1409 1732 57 29 96.889977 this5 1 3 3 7 11 1482 1732 74 29 96.641785 have5 1 3 3 7 12 1571 1738 30 23 96.414612 to5 1 3 3 7 13 1616 1733 150 37 83.563004 happen? Nobody ever found out anything about the Fountain of Youth, and I thought, Well,5 1 3 3 8 14 1856 1782 57 29 95.950333 I’m4 1 3 3 9 0 593 1825 1321 41 -1 5 1 3 3 9 1 593 1833 99 29 96.901703 gonna5 1 3 3 9 2 706 1825 38 29 96.148972 do5 1 3 3 9 3 760 1825 48 29 96.406677 it.”5 1 3 3 9 4 821 1825 117 29 94.274307 There's5 1 3 3 9 5 954 1826 167 37 96.586662 something5 1 3 3 9 6 1136 1827 60 28 96.989578 that5 1 3 3 9 7 1210 1836 59 27 96.347069 you5 1 3 3 9 8 1284 1836 55 20 96.936668 cans 1 3 3 9 9 1354 1828 39 28 96.994835 do5 1 3 3 9 10 1407 1833 29 23 96.472298 to5 1 3 3 9 11 1451 1828 75 38 96.472298 keeps 1 3 3 9 12 1540 1828 78 29 96.266174 from5 1 3 3 9 13 1631 1829 103 37 95.951019 getting’5 1 3 3 9 14 1752 1829 72 29 93.420868 sick.5 1 3 3 9 15 1852 1830 62 28 93.420868 Our4 1 3 3 10 0 592 1873 1321 42 -1 5 1 3 3 10 1 592 1873 103 29 96.456039 bodies5 1 3 3 10 2 709 1882 46 20 97.010406 ares 1 3 3 10 3 768 1874 149 37 96.695030 supposed5 1 3 3 10 4 929 1879 30 23 96.870117 to5 1 3 3 10 5 972 1874 57 30 83.403343 liye5 1 3 3 10 6 1042 1874 123 29 96.247475 forever.5 1 3 3 10 7 1190 1875 69 29 96.987389 Ands 1 3 3 10 8 1272 1884 34 20 91.736526 so5 1 3 3 10 9 1318 1875 10 29 91.736526 I5 1 3 3 10 10 1342 1881 78 24 96.964119 went5 1 3 3 10 11 1432 1875 61 30 96.602608 into5 1 3 3 10 12 1504 1876 55 29 96.602608 bees 1 3 3 10 13 1571 1877 110 37 96.900520 pollen,5 1 3 3 10 14 1696 1877 57 28 95.833817 ands 1 3 3 10 15 1765 1878 11 27 94.246498 J5 1 3 3 10 16 1789 1878 124 37 96.919197 thought4 1 3 3 11 0 592 1921 1321 42 -1 5 1 3 3 11 1 592 1927 28 23 96.987442 at5 1 3 3 11 2 634 1921 59 29 96.879921 that5 1 3 3 11 3 707 1921 80 33 94.529221 time,5 1 3 3 11 4 802 1921 103 34 85.122910 Well, maybe I can continue until I’m 80.” So I took bee pollen for about two years, and when I was 80 years old, I was in much better condition than I had ever been since I was 70. I was improvin’, and I said, “Well, I'm gonna continue." So I continued to take the bee pollen and doing’ my light exercise and things like that, and by the time it got to be 85, I was much better than I was at 80. And now I'm getting near 90, I’m better'n I was at 85. I'm improving right along. I’ve found . . . I'm finding out new things all the time. Bee pollen is one of the things that has done it.

I was running in the New York Marathon one time, running down Brooklyn, a lady came out and put her arms around me and says, “"How’d you like to run home with me?" I said, Listen.5 1 3 4 3 7 1148 2405 67 29 91.561340 You5 1 3 4 3 8 1233 2429 26 5 91.561340 ...5 1 3 4 3 9 1276 2414 58 29 96.343918 you5 1 3 4 3 10 1345 2405 63 38 96.386292 just5 1 3 4 3 11 1423 2411 63 32 96.668190 stays 1 3 4 3 12 1501 2406 69 29 96.803566 here5 1 3 4 3 13 1585 2406 56 29 96.636200 ands 1 3 4 3 14 1656 2406 69 29 96.856003 wait5 1 3 4 3 15 1740 2407 57 28 92.895447 ands 1 3 4 3 16 1811 2407 47 29 85.753021 I’ll5 1 3 4 3 17 1873 2407 37 29 96.641594 be4 1 3 4 4 0 589 2452 1320 41 -1 5 1 3 4 4 1 589 2452 103 28 90.335075 back.”5 1 3 4 4 2 714 2452 94 29 90.335075 When5 1 3 4 4 3 821 2452 11 29 96.331024 I5 1 3 4 4 4 845 2461 51 20 94.420570 runs 1 3 4 4 5 910 2461 16 20 94.420570 a5 1 3 4 4 6 938 2453 160 32 96.215965 marathon,5 1 3 4 4 7 1103 2448 13 49 71.591690 I5 1 3 4 4 8 1136 2477 25 5 90.935104 ...5 1 3 4 4 9 1176 2454 48 28 96.807281 thes 1 3 4 4 10 1237 2454 70 37 96.511765 only5 1 3 4 4 11 1320 2454 81 37 96.914574 things 1 3 4 4 12 1414 2454 11 28 96.900948 I5 1 3 4 4 13 1437 2460 46 22 95.817322 eats 1 3 4 4 14 1495 2454 28 29 95.817322 in5 1 3 4 4 15 1537 2455 47 28 96.748695 thes 1 3 4 4 16 1598 2455 144 37 95.117180 morning,5 1 3 4 4 17 1758 2455 9 29 96.911476 I5 1 3 4 4 18 1781 2456 66 28 96.451218 takes 1 3 4 4 19 1861 2464 48 29 96.992767 my4 1 3 4 5 0 589 2500 1321 40 -1 5 1 3 4 5 1 589 2500 54 29 96.628799 bees 1 3 4 5 2 655 2500 108 37 96.922516 pollen,5 1 3 4 5 3 777 2500 56 29 96.893547 ands 1 3 4 5 4 845 2500 67 29 96.862328 then5 1 3 4 5 5 926 2500 11 29 96.704567 I5 1 3 4 5 6 950 2500 74 29 96.651886 have5 1 3 4 5 7 1037 2501 54 29 96.651886 bees 1 3 4 5 8 1103 2501 104 29 96.889473 tablets5 1 3 4 5 9 1220 2501 71 29 96.778511 with5 1 3 4 5 10 1304 2511 55 19 96.513748 me.5 1 3 4 5 11 1384 2502 99 28 96.221230 About5 1 3 4 5 12 1495 2512 88 28 96.539841 every5 1 3 4 5 13 1597 2503 78 33 94.996849 mile,5 1 3 4 5 14 1689 2503 11 28 96.923401 I5 1 3 4 5 15 1713 2503 65 29 96.646591 takes 1 3 4 5 16 1792 2512 16 20 94.165337 a5 1 3 4 5 17 1820 2503 90 29 94.165337 tablet4 1 3 4 6 0 589 2548 1319 40 -1 5 1 3 4 6 1 589 2548 34 29 96.932144 of5 1 3 4 6 2 631 2548 55 29 96.742935 bees 1 3 4 6 3 697 2548 107 37 95.469482 pollen.5 1 3 4 6 4 828 2548 22 29 96.484680 It5 1 3 4 6 5 862 2557 71 28 96.751854 goes5 1 3 4 6 6 946 2548 60 29 96.933617 into5 1 3 4 6 7 1018 2558 74 28 96.863182 yours 1 3 4 6 8 1103 2549 200 29 96.128441 bloodstream5 1 3 4 6 9 1311 2550 61 37 96.602997 just5 1 3 4 6 10 1384 2559 16 19 96.492241 a5 1 3 4 6 11 1411 2550 58 28 96.342438 few5 1 3 4 6 12 1483 2551 125 28 95.763168 minutes5 1 3 4 6 13 1621 2551 73 28 96.933388 after5 1 3 4 6 14 1705 2560 58 28 96.892494 you5 1 3 4 6 15 1777 2551 131 29 96.059776 swallow4 1 3 4 7 0 589 2596 1319 40 -1 5 1 3 4 7 1 589 2596 28 33 96.929726 it,5 1 3 4 7 2 631 2596 56 29 95.777878 ands 1 3 4 7 3 700 2596 9 28 88.321449 J5 1 3 4 7 4 723 2596 80 29 96.530449 thinks 1 3 4 7 5 816 2596 59 29 96.851242 that5 1 3 4 7 6 887 2597 54 28 97.016777 bees 1 3 4 7 7 954 2597 100 37 96.636299 pollen5 1 3 4 7 8 1067 2597 84 37 96.648781 gives5 1 3 4 7 9 1165 2606 58 25 96.384056 me,5 1 3 4 7 10 1236 2607 90 28 96.502769 every5 1 3 4 7 11 1340 2598 80 33 96.675491 mile,5 1 3 4 7 12 1435 2598 20 29 96.969246 it5 1 3 4 7 13 1468 2599 83 36 96.617096 gives5 1 3 4 7 14 1565 2608 48 20 96.763824 me5 1 3 4 7 15 1625 2608 120 28 96.813934 energy.5 1 3 4 7 16 1770 2599 70 34 96.580444 Yes,5 1 3 4 7 17 1854 2600 54 29 97.002617 bee CC POLLEN COMPANY, ET AL. 217 206 Complaint pollen would help you. It’ll help you. I don’t care if you’re an athlete ora secretary, whichever you are.

MURPHY: Noel Johnson’s book, A Dud at Seventy ... Stud at 80, has received world-wide recognition. It’s been printed in dozens of languages. Johnson’s new book is about to be published: Be Healthy to 100. It’s sure to be another international hit. Johnson is certainly a unique individual. In just a few minutes, we'll let you know how to order the same High Desert Bee Pollen that Johnson uses daily.

Certainly, a lot of world-class athletes are using this food, bee pollen. It offers energy that can’t be achieved any other way, no matter what kind of condition you may be in. It also offers the non-athlete the ability to achieve. A great example is Bob Kite of Phoenix, Arizona. Kite began taking bee pollen seven years ago, and now he's the envy of the running group in Arizona and California. But what makes him unique is that he does not train like the competition. He freely admits to being a junk food fan, but feels bee pollen lets him mix irregular workouts with running competition and still be a winner. We caught up with Bob Kite and asked him how long has he been taking bee pollen. KITE: I’ve been taking’ it for about seven years now, off and on. I’m not a devout athlete, nor a nutritionist by any means. I eat a lot of garbage food. I’ve been known to get comfortable at a Burger King every now and then and, in fact, I’m a soft drink junkie, but at the same time I supplement it with the bee pollen and I think that's more or less my ace in the hole as far as mixing athletics with decadence in life. If you eat enough of the right stuff, it makes up for the bad stuff that you typically put into your diet.

A lot of the success of that was the fact that I took quite a bit of bee pollen before the race, and then during the race I’d be eating’ the bee pollen bars, mainly because your body can only last about two, two-and-a-half hours on what it can store, what ... the carbo loading theory. After that, you're ... you're turning cannibal on yourself, and it's just whatever the body can consume. If you can put something else new in there, it won't eat yourself up. I think that the bee pollen really kicked into effect in those third, fourth and fifth hours of running. Whereas everybody else was bonking and trying to survive on bananas and chocolate, I was doing just fine on the pollen. If you can take it long enough, you will be healthier. It ... it just is nothing more than a food. It's a pure food; it's a complete food. So, if your diet is bad, or if you’re inconsistent with your diet, this bee pollen is kinda like mortar. You can build a nice wall with rocks, but if you don't have that mortar in there it'll fall apart sooner or later. Bee pollen kinda fills it all in and makes it solid because you can live on it. You can ... bee pollen and water, you can live on it.

MURPHY. In just a minute, we'll be meeting a world-renowned individual who is credited with being the father of today's growing wellness orientation. Dr. Bernard Jensen has traveled the world in search of answers on the Fountain of Youth, and he's found some answers. We’ll be right back. Complaint 116 F.T.C.

JENSEN. There's no doubt in my mind that bee pollen is the one thing I have found in all of my travels and in all of my experience that brings on long life and good health.

VOICE-OVER: Now, for the first time, the magic of High Desert Bee Pollen is available with this television offer. If you want to feel a renewed vitality and increased energy, then you may wish to order today. This Presidential kit includes a generous selection of delicious bars; the President’s lunch bar and the First Lady's lunch bar. In addition, you will also receive a thirty-day supply of Pollenergy and one box of bee pollen honey chewable tablets. If you order today, we will also include a thirty-day supply of chewable royal jelly tablets for longevity. To order your Presidential energy kit with Visa or Mastercard, call tollfree 1-800-321-5100. Or, send a check or money order for $39.95 to Tele-Mart, Box B, Elfers, Florida 34680. Please add $3.50 for shipping and special handling. Once again, to order your Presidential bee pollen kit, call toll-free 1-800-321- 5100, or send a check or money order for $39.95 to Tele-Mart, Box B, Elfers, Florida 34680. Please add $3.50 for shipping and special handling. Credit card and money orders are processed for shipment within forty-eight hours. The Search for the Fountain of Youth MURPHY: There is no doubt that the bee pollen story is a fascinating one. In the next few years, you’ll see the growth in bee pollen sales to levels like in Scandinavian and oriental cultures. Remember, bee pollen is not a drug; it's a food. High Desert Bee Pollen is America's number one pollen distributor to other nations.

One country uses more High Desert Bee Pollen than any other. Nearly one in four people in Iceland use High Desert Bee Pollen regularly. This is due to the remarkable story of Gissur Gugmondsson. Gissur was nearly bedridden for years and was in pain all the time. Here is his story, translated from the Rekjavik daily newspapers on November 10, 1987:

TRANSLATOR: Around the age of sixty, I began to suffer from a marked lack of breath, especially when I had to carry or lift heavy objects. I mentioned this to my doctor who, after careful examination, diagnosed hardening of the arteries and other ailments afflicting my muscles and joints. He advised me to give up all heavy manual labor immediately to avoid making my condition worse, hinting I could even drop down dead any minute. In the following years, I was plagued with various ailments, in particular with rheumatism, which caused me unbearable suffering in most of my joints.

I was provided with a specially constructed table and chair for reading and writing, and had supports strapped around my knees for walking and had begun using a walking stick. I underwent tests during this period. Everything was tried. I underwent therapy and massage and all of this was positive as far as it went. I read about the body's nutritional needs, and when I read about bee pollen I felt it CC POLLEN COMPANY, ET AL. 219 206 Complaint was something worth looking into. I began taking it in tablet form and then bought a box of grains and increased my intake. Then my body really started to return to form. A miracle happened. The effect snowballed. The pain disappeared from joints, and other improvements followed, such as a vast increase in my stamina and general zest for life. My heartbeat is perfectly normal, my vision no longer impaired, and I have stopped using the reading glasses which I needed for thirty-seven years. I have also quit using the leg straps and walking stick. My doctor for the past five years confirmed the truth of everything I have said about the time I have been her patient. I am now nearing the age of 81, and I am absolutely satisfied with the life I lead and enjoy doing so. Pollen has done so much for me and I shall never stop taking it. MURPHY: Since bee pollen's history parallels the history of civilization, let's highlight what the authorities have said about bee pollen. Dr. Carlton Fredericks, noted health author, feels Honeybee5 1 2 3 1 9 1711 1209 100 38 95.504318 pollen5 1 2 3 1 10 1829 1208 24 30 95.504318 is5 1 2 3 1 11 1870 1208 48 29 96.995979 thea 1 2 3 2 0 599 1252 1317 52 -1 5 1 2 3 2 1 599 1266 71 38 93.306190 only5 1 2 3 2 2 685 1264 214 39 91.528679 super-perfect5 1 2 3 2 3 911 1263 74 30 96.721626 foods 1 2 3 2 4 997 1271 38 21 96.365021 on5 1 2 3 2 5 1049 1262 57 29 96.365021 this5 1 2 3 2 6 1119 1261 89 30 96.350601 earth.5 1 2 3 2 7 1233 1261 23 29 93.558990 It5 1 2 3 2 8 1269 1260 24 30 93.558990 is5 1 2 3 2 9 1307 1265 51 25 93.895027 not5 1 2 3 2 10 1370 1268 17 21 93.895027 a5 1 2 3 2 11 1400 1259 116 37 96.832581 subjects 1 2 3 2 12 1528 1263 30 24 96.966499 to5 1 2 3 2 13 1570 1258 106 29 96.942314 debates 1 2 3 2 14 1689 1265 33 22 96.992874 or5 1 2 3 2 15 1734 1252 182 46 90.777710 challenge. Many, many years ago, Hippocrates said, Lets 1 2 3 3 8 1376 1317 76 28 96.884834 yours 1 2 3 3 9 1465 1307 148 29 96.413315 medicines 1 2 3 3 10 1626 1306 37 29 96.942795 be5 1 2 3 3 11 1676 1314 75 29 96.480003 yours 1 2 3 3 12 1763 1304 83 34 96.821800 food,5 1 2 3 3 13 1861 1304 57 29 96.641525 anda 1 2 3 4 0 600 1359 479 42 -1 5 1 2 3 4 1 600 1372 74 29 96.212265 yours 1 2 3 4 2 684 1362 74 29 96.784523 foods 1 2 3 4 3 770 1362 36 28 96.784523 be5 1 2 3 4 4 819 1370 74 28 96.660774 yours 1 2 3 4 5 905 1359 174 30 92.766899 medicine. According to Dr. William Hedgepeth, leading holistic medicine doctor, Bee4 1 2 4 2 0 600 1448 1318 49 -1 5 1 2 4 2 1 600 1460 97 37 95.183144 pollen5 1 2 4 2 2 711 1458 23 29 96.838043 is5 1 2 4 2 3 748 1458 47 29 96.947151 thes 1 2 4 2 4 808 1466 113 20 96.906487 answers 1 2 4 2 5 932 1462 29 23 96.906487 to5 1 2 4 2 6 975 1455 163 30 96.558990 mankind's5 1 2 4 2 7 1151 1459 85 33 97.005196 quests 1 2 4 2 8 1248 1454 47 28 96.933327 for5 1 2 4 2 9 1307 1454 48 28 96.773727 thes 1 2 4 2 10 1367 1452 144 29 96.983231 Fountains 1 2 4 2 11 1525 1451 36 29 96.899361 of5 1 2 4 2 12 1570 1451 109 28 96.905884 Youth.5 1 2 4 2 13 1705 1450 61 29 97.010040 Bees 1 2 4 2 14 1779 1449 101 38 96.981270 pollen5 1 2 4 2 15 1893 1448 25 29 96.980705 is4 1 2 4 3 0 600 1497 1197 46 -1 5 1 2 4 3 1 600 1508 47 28 97.013054 thes 1 2 4 3 2 661 1506 158 37 96.873764 activating5 1 2 4 3 3 833 1506 157 28 96.949707 substances 1 2 4 3 4 1003 1503 97 30 96.841431 which5 1 2 4 3 5 1114 1503 184 37 96.860741 rejuvenates5 1 2 4 3 6 1312 1501 57 29 95.868744 ands 1 2 4 3 7 1382 1501 91 29 95.868744 slows5 1 2 4 3 8 1487 1500 48 28 97.015831 thes 1 2 4 3 9 1548 1499 89 37 97.001556 aging5 1 2 4 3 10 1650 1497 147 39 90.364746 process. Dr. John R. Christopher, considered by many to be the greatest herbalist, adds, I5 1 2 5 2 3 730 1602 135 30 95.367424 considers 1 2 5 2 4 876 1601 151 37 96.297836 honeybee5 1 2 5 2 5 1039 1600 97 38 96.978271 pollen5 1 2 5 2 6 1148 1599 47 29 96.978271 thes 1 2 5 2 7 1206 1604 77 23 96.709305 most5 1 2 5 2 8 1294 1597 108 29 96.709305 natural5 1 2 5 2 9 1414 1596 73 30 96.818642 foods 1 2 5 2 10 1498 1596 28 29 96.680565 in5 1 2 5 2 11 1538 1596 47 29 96.680565 thes 1 2 5 2 12 1597 1595 99 29 96.596344 world.5 1 2 5 2 13 1719 1594 100 29 96.729782 Pollen5 1 2 5 2 14 1831 1593 25 30 96.233452 is5 1 2 5 2 15 1867 1593 52 29 96.709549 life4 1 2 5 3 0 601 1651 103 30 -1 5 1 2 5 3 1 601 1651 103 30 93.514107 itself. Leading British medical authority, Dr. G. J. Binding, provides a scientific viewpoint Pollen5 1 2 6 2 3 910 1745 24 28 96.444122 is5 1 2 6 2 4 948 1745 48 28 96.919044 thes 1 2 6 2 5 1009 1744 100 32 96.971497 finest,5 1 2 6 2 6 1123 1749 77 23 96.971497 most5 1 2 6 2 7 1213 1743 112 36 96.956223 perfect5 1 2 6 2 8 1339 1742 82 28 96.475281 food.5 1 2 6 2 9 1448 1742 26 28 96.201721 A5 1 2 6 2 10 1489 1740 80 38 96.338600 giants 1 2 6 2 11 1583 1749 82 27 96.950233 germs 1 2 6 2 12 1678 1739 86 28 96.363495 killer5 1 2 6 2 13 1777 1738 28 29 96.363495 in5 1 2 6 2 14 1819 1737 100 30 97.003937 which4 1 2 6 3 0 599 1792 484 39 -1 5 1 2 6 3 1 599 1794 129 30 96.176384 bacteria5 1 2 6 3 2 741 1794 107 37 96.785271 simply5 1 2 6 3 3 862 1798 108 24 95.826530 cannot5 1 2 6 3 4 982 1792 101 29 89.401222 exist. Another noted nutritional authority, Ernest Cantreras, states, To5 1 2 7 1 9 1869 1842 50 29 96.539261 my4 1 2 7 2 0 601 1882 1318 46 -1 5 1 2 7 2 1 601 1891 187 37 95.819618 knowledge,5 1 2 7 2 2 803 1890 79 29 96.861671 there5 1 2 7 2 3 895 1890 25 28 96.861671 is5 1 2 7 2 4 933 1898 39 20 96.943642 no5 1 2 7 2 5 985 1889 92 28 96.725151 better5 1 2 7 2 6 1090 1888 57 29 96.725151 ands 1 2 7 2 7 1159 1896 82 20 96.434532 more5 1 2 7 2 8 1253 1886 150 38 96.643303 completes 1 2 7 2 9 1417 1885 110 29 96.997108 natural5 1 2 7 2 10 1542 1884 126 30 96.366432 nutrients 1 2 7 2 11 1680 1884 69 28 96.218414 than5 1 2 7 2 12 1762 1882 157 38 96.218414 honeybee4 1 2 7 3 0 601 1940 124 38 -1 5 1 2 7 3 1 601 1940 124 38 81.697479 pollen. Our next guest is the world-renowned Dr. Bernard Jensen. Dr. Jensen's credits read like a Who’s5 1 2 8 2 6 1027 2033 78 28 96.844200 Who5 1 2 8 2 7 1117 2032 27 29 96.784157 in5 1 2 8 2 8 1157 2031 47 29 96.784157 thes 1 2 8 2 9 1216 2030 174 30 96.962852 Nutritional5 1 2 8 2 10 1402 2028 127 31 68.549065 World. He has written over 50 books in his life-long quest for knowledge about nutrition. His search for long life and to discover the secrets of health has led him to over 55 countries. He received the Dag Hammerskjold Award for his efforts in nutritional research, ana .1lso was presented a special award from Queen Juliana of the Netherlands. Dr. Jensen is an outspoken advocate of bee pollen.

JENSEN: There are very few foods I consider whole foods. Bee pollen is one of those foods. It feeds every part of the body, and especially the glandular side of our body. And when it feeds those glands, this gives us the energy and the pep for repair and rebuilding. And we find that bee pollen is part of the food that the bee lives on. That is what feeds the queen bee. We find out that this is .. gives us the best part of that bee colony to build a whole bee: the eye, the nerves, the spine, the responsiveness, the nervous system, the digestive system. It feeds Complaint 116 F.T.C.

and makes a whole body, and it does that for the human as well as it does for the bee. There’s no doubt in my mind that the High Desert Bee Pollen is one thing that I have felt will bring more health, more longevity, a greater power in that body, for the rest of your life.

MURPHY: Dr. Jensen speaks as an expert. He has spent a lifetime looking for ways to increase longevity. He’s traveled to hundreds of places on earth where longer lives share a common thread with each of these cultures. And that thread is bee pollen. Jensen has spent thousands of hours with people over 100 years of age and all of these cultures, no matter the location, are bee keepers. The Search for the Fountain of Youth VOICE-OVER: Now, for the first time, the magic of High Desert Bee Pollen is available with this television offer. If you want to feel a renewed vitality and increased energy, then you may wish to order today. This Presidential kit includes a generous selection of delicious bars: the President's Lunch Bar and the First Lady's Lunch Bar. In addition, you will also receive a 30-day supply of Pollenergy and one box of bee pollen honey chewable tablets. If you order today, we will also include a 30-day supply of chewable royal jelly tablets for longevity. To order your Presidential energy kit with Visa or Mastercard, call toll-free 1-800- 321-5100. Or send a check or money order for $39.95 to Tele-Mart, Box B, Elfers, Florida 34680. Please add $3.50 for shipping and special handling. Once again, to order your Presidential bee pollen kit, call toll-free 1-800-321-5100, or send a check or money order for $39.95 to Tele-Mart, Box B, Elfers, Florida 34680. Please add $3.50 for shipping and special handling. Credit card and money orders are processed for shipment within forty-eight hours. MURPHY: As I promised earlier, we'd like to share with you just a few of the many letters we've received. From Wisconsin, this viewer writes, I5 1 5 2 2 12 1754 1882 74 29 96.512199 have5 1 5 2 2 13 1840 1883 73 28 96.567322 used4 1 5 2 3 0 593 1923 1319 43 -1 5 1 5 2 3 1 593 1923 48 29 96.292381 thes 1 5 2 3 2 654 1923 155 38 96.509392 honeybee5 1 5 2 3 3 823 1924 99 37 96.721558 pollen5 1 5 2 3 4 937 1925 70 37 96.640953 only5 1 5 2 3 5 1021 1934 16 20 96.640953 a5 1 5 2 3 6 1051 1926 80 28 96.993408 short5 1 5 2 3 7 1144 1926 69 29 96.740692 times 1 5 2 3 8 1228 1927 55 28 96.658920 ands 1 5 2 3 9 1297 1926 43 30 94.470314 it's5 1 5 2 3 10 1353 1928 121 38 96.789482 helping5 1 5 2 3 11 1489 1937 33 20 96.862373 so5 1 5 2 3 12 1537 1929 88 28 96.006584 much5 1 5 2 3 13 1638 1929 11 28 96.006584 I5 1 5 2 3 14 1663 1935 77 23 96.338699 wants 1 5 2 3 15 1753 1935 29 24 96.338699 to5 1 5 2 3 16 1795 1930 37 29 96.676270 be5 1 5 2 3 17 1846 1939 66 20 96.949440 sure4 1 5 2 4 0 593 1971 1317 43 -1 5 1 5 2 4 1 593 1972 11 28 73.946838 I5 1 5 2 4 2 616 1971 91 30 85.722206 won’t5 1 5 2 4 3 718 1981 51 20 85.722206 runs 1 5 2 4 4 781 1977 57 24 96.571358 out.5 1 5 2 4 5 862 1973 44 29 81.723099 It's5 1 5 2 4 6 919 1973 88 38 96.028770 really5 1 5 2 4 7 1020 1974 190 29 96.860497 wonderful.”5 1 5 2 4 8 1223 1975 25 28 96.782913 A5 1 5 2 4 9 1262 1975 66 38 96.245956 lady5 1 5 2 4 10 1340 1975 75 30 96.249046 from5 1 5 2 4 11 1428 1976 152 38 95.963928 Michigan5 1 5 2 4 12 1594 1977 103 34 92.926117 writes,5 1 5 2 4 13 1713 1977 114 30 92.926117 Please send me another order of bee pollen. My husband absolutely cannot be without it.” According to Mr. Mack of Florida, who states, “Your pollen is the best we've ever had. We're recommending it to all our nutritional counseling clients." I5 1 5 2 7 12 1835 2123 75 29 96.486137 have4 1 5 2 8 0 592 2165 1317 43 -1 5 1 5 2 8 1 592 2165 74 29 97.016708 been5 1 5 2 8 2 681 2165 130 29 96.593582 relieved5 1 5 2 8 3 825 2166 35 28 96.688644 of5 1 5 2 8 4 872 2175 102 20 97.018463 severe5 1 5 2 8 5 988 2166 174 38 96.636581 depression5 1 5 2 8 6 1177 2167 148 38 96.354332 episodes.5 1 5 2 8 7 1352 2169 11 28 82.371841 I5 1 5 2 8 8 1378 2169 75 29 96.640381 have5 1 5 2 8 9 1468 2169 70 38 96.515633 high5 1 5 2 8 10 1552 2178 111 30 96.515633 energy5 1 5 2 8 11 1678 2171 102 29 96.916161 levels.5 1 5 2 8 12 1807 2171 102 29 96.808434 Pollen4 1 5 2 9 0 592 2213 1192 40 -1 5 1 5 2 9 1 592 2213 105 38 88.969948 helped5 1 5 2 9 2 711 2214 28 28 96.707222 in5 1 5 2 9 3 753 2223 50 28 96.623688 my5 1 5 2 9 4 815 2214 111 38 96.415749 weights 1 5 2 9 5 939 2214 152 31 96.644829 reductions 1 5 2 9 6 1106 2224 145 29 96.951622 program,5 1 5 2 9 7 1265 2217 90 33 95.003838 also, said Mrs. G. H. of Texas.

A 71-year-old writes to say, “At 71, I’m more capable than I was 15 years ago. I feel good!" For those interested in weight reduction, this person from New Jersey writes, At5 1 5 3 3 4 886 2368 54 29 96.046196 ages 1 5 3 3 5 952 2359 48 34 96.470375 73,5 1 5 3 3 6 1014 2360 10 28 96.470375 I5 1 5 3 3 7 1036 2359 58 30 94.203880 feels 1 5 3 3 8 1108 2360 58 29 96.271889 likes 1 5 3 3 9 1178 2361 88 29 96.954895 about5 1 5 3 3 10 1278 2361 38 30 96.908356 505 1 5 3 3 11 1328 2370 84 29 96.971413 years5 1 5 3 3 12 1424 2362 35 30 96.682961 of5 1 5 3 3 13 1468 2367 64 33 97.009392 age,5 1 5 3 3 14 1546 2364 56 28 96.763306 ands 1 5 3 3 15 1615 2364 74 28 96.763306 have5 1 5 3 3 16 1702 2364 56 29 96.956032 lost5 1 5 3 3 17 1770 2364 88 29 96.602821 about5 1 5 3 3 18 1870 2364 39 30 96.646080 504 1 5 3 4 0 589 2407 1318 38 -1 5 1 5 3 4 1 589 2407 143 37 78.538986 pounds. A professional dietitian at Florida wrote, As5 1 5 3 4 9 1516 2420 17 20 94.405960 a5 1 5 3 4 10 1548 2411 142 34 96.199089 dietitian,5 1 5 3 4 11 1712 2412 4 28 94.054085 I5 1 5 3 4 12 1731 2412 76 29 96.343033 have5 1 5 3 4 13 1822 2413 85 28 96.343033 taken4 1 5 3 5 0 589 2454 1319 39 -1 5 1 5 3 5 1 589 2455 96 37 96.309227 pollen5 1 5 3 5 2 697 2454 28 29 90.204773 in5 1 5 3 5 3 738 2455 34 29 90.204773 its5 1 5 3 5 4 784 2464 87 29 97.004578 many5 1 5 3 5 5 882 2455 91 30 96.991295 forms5 1 5 3 5 6 985 2455 76 30 96.492096 from5 1 5 3 5 7 1073 2457 114 29 96.888428 various5 1 5 3 5 8 1201 2466 125 25 96.589127 sources,5 1 5 3 5 9 1339 2458 49 29 96.589127 but5 1 5 3 5 10 1400 2458 11 29 95.140274 I5 1 5 3 5 11 1423 2459 56 29 95.140274 had5 1 5 3 5 12 1491 2468 89 20 96.107033 never5 1 5 3 5 13 1590 2460 55 28 96.107033 had5 1 5 3 5 14 1657 2460 47 28 96.895775 thes 1 5 3 5 15 1715 2460 124 30 96.882614 benefits5 1 5 3 5 16 1852 2461 56 29 96.964188 anda 1 5 3 6 0 589 2503 1318 42 -1 5 1 5 3 6 1 589 2503 102 29 96.769234 results5 1 5 3 6 2 703 2503 155 30 96.769234 contained5 1 5 3 6 3 871 2504 28 29 96.997276 in5 1 5 3 6 4 912 2513 74 29 96.822945 yours 1 5 3 6 5 997 2505 54 28 96.995850 bees 1 5 3 6 6 1064 2506 126 36 90.932625 pollen.”5 1 5 3 6 7 1214 2506 85 30 90.932625 From5 1 5 3 6 8 1311 2507 137 38 96.250885 Georgia,5 1 5 3 6 9 1462 2508 55 29 96.953758 this5 1 5 3 6 10 1532 2508 109 29 96.121933 viewers 1 5 3 6 11 1652 2518 77 27 88.493881 says,5 1 5 3 6 12 1745 2509 97 29 88.493881 Your bee pollen is all you claim it to be. I thought all bee pollen was the same, but there's no comparison. I have never experienced such energy in my body.” Another CC POLLEN COMPANY, ET AL. 221 206 Complaint gentleman wrote, My5 1 2 1 1 4 1009 579 70 29 96.979057 wife5 1 2 1 1 5 1092 581 58 28 96.742134 ands 1 2 1 1 6 1162 581 11 28 96.655060 I5 1 2 1 1 7 1187 581 52 36 96.655060 (725 1 2 1 1 8 1251 583 99 36 96.265381 years)5 1 2 1 1 9 1358 583 63 37 96.265381 just5 1 2 1 1 10 1434 584 107 29 96.792122 started5 1 2 1 1 11 1553 584 102 38 96.792122 taking5 1 2 1 1 12 1666 586 56 28 96.408737 bees 1 2 1 1 13 1735 586 100 37 96.276901 pollen5 1 2 1 1 14 1848 595 39 20 96.966278 on5 1 2 1 1 15 1900 587 49 29 96.736313 thea 1 2 1 2 0 627 625 1321 44 -1 5 1 2 1 2 1 627 625 104 29 97.006943 advice5 1 2 1 2 2 743 625 36 30 96.843079 of5 1 2 1 2 3 787 635 17 20 91.942215 a5 1 2 1 2 4 816 626 277 31 91.942215 nutrition-minded5 1 2 1 2 5 1105 629 84 29 93.273148 M.D.5 1 2 1 2 6 1203 629 56 30 96.809792 We5 1 2 1 2 7 1271 639 78 20 96.806770 were5 1 2 1 2 8 1363 630 147 31 96.599564 informed5 1 2 1 2 9 1523 641 60 28 96.974266 you5 1 2 1 2 10 1595 632 76 30 96.936371 have5 1 2 1 2 11 1684 633 49 29 96.913605 thes 1 2 1 2 12 1744 634 74 34 96.878761 best,5 1 2 1 2 13 1832 635 57 29 96.896042 ands 1 2 1 2 14 1902 644 46 20 96.748085 we4 1 2 1 3 0 627 674 1318 45 -1 5 1 2 1 3 1 627 678 78 24 96.704544 wants 1 2 1 3 2 720 679 29 24 96.979256 to5 1 2 1 3 3 763 674 115 30 96.652390 order.”5 1 2 1 3 4 893 675 26 29 96.803757 A5 1 2 1 3 5 934 675 84 29 96.192474 letters 1 2 1 3 6 1030 675 77 31 96.119385 from5 1 2 1 3 7 1121 677 51 29 93.136497 Dr.5 1 2 1 3 8 1186 677 32 30 92.971634 T.5 1 2 1 3 9 1234 678 31 29 92.906914 T.5 1 2 1 3 10 1282 683 98 30 96.897484 states,5 1 2 1 3 11 1398 679 121 31 95.674416 Health improvements have been phenomenal! Thank you.” An 81-year-old California viewer says, After5 1 2 1 4 10 1846 732 100 38 96.890198 eating4 1 2 1 5 0 625 771 1322 44 -1 5 1 2 1 5 1 625 771 152 37 96.365379 honeybee5 1 2 1 5 2 789 772 97 37 96.113029 pollen5 1 2 1 5 3 899 773 56 28 96.929306 ands 1 2 1 5 4 967 773 95 38 96.522202 honey5 1 2 1 5 5 1074 779 27 23 96.046844 at5 1 2 1 5 6 1114 774 33 29 96.046844 815 1 2 1 5 7 1163 783 83 29 96.861237 years5 1 2 1 5 8 1258 776 58 33 96.956963 old,5 1 2 1 5 9 1328 776 12 29 96.878799 I5 1 2 1 5 10 1351 785 74 29 96.878799 gave5 1 2 1 5 11 1437 786 38 29 96.531166 up5 1 2 1 5 12 1487 787 50 28 96.825127 my5 1 2 1 5 13 1549 778 111 37 96.814438 glasses5 1 2 1 5 14 1673 779 58 30 96.847183 that5 1 2 1 5 15 1742 779 63 30 96.183685 I’ve5 1 2 1 5 16 1818 781 70 28 96.837662 used5 1 2 1 5 17 1900 780 47 30 96.640938 fora 1 2 1 6 0 622 819 1322 47 -1 5 1 2 1 6 1 622 819 40 28 96.946724 445 1 2 1 6 2 674 827 84 29 96.851921 years5 1 2 1 6 3 771 820 56 29 95.720047 ands 1 2 1 6 4 840 820 138 38 95.720047 regained5 1 2 1 6 5 992 830 49 29 97.015808 my5 1 2 1 6 6 1054 823 103 29 96.811394 sexual5 1 2 1 6 7 1170 829 128 33 96.794647 potency5 1 2 1 6 8 1312 824 97 31 96.970711 which5 1 2 1 6 9 1423 825 57 30 96.551781 had5 1 2 1 6 10 1492 827 76 28 96.874748 been5 1 2 1 6 11 1582 827 125 38 96.096855 missing5 1 2 1 6 12 1720 827 47 30 96.298149 for5 1 2 1 6 13 1782 828 35 30 96.298149 165 1 2 1 6 14 1830 829 114 37 96.920547 years.”4 1 2 1 7 0 623 866 1320 46 -1 5 1 2 1 7 1 623 866 45 30 88.295792 W.5 1 2 1 7 2 681 867 35 29 88.295792 H.5 1 2 1 7 3 730 867 75 30 95.782242 from5 1 2 1 7 4 817 868 76 29 96.663925 Utah5 1 2 1 7 5 905 869 96 29 95.450989 writes5 1 2 1 7 6 1012 875 30 23 96.868553 to5 1 2 1 7 7 1054 878 60 29 94.540306 say,5 1 2 1 7 8 1129 870 25 30 86.079117 I love your honeybee pollen. I've not tried a more delicious bee pollen yet. Yours is soft, clean and fresh. Am I impressed.” And that's a good point, ladies and gentlemen. All our products go directly to you from harvesting, right here in the good old U.S.A. While many of the imported pollens lose up to 70% of their potency in shipment from other countries or while sitting on shelves for many months. And I’d like to add that we have supplied the White House, Camp David, Air Force One and Executive One for many years. Now ‘these bars even went to the Moscow Summit and we're very proud of that. Our pollen bars were named in honor of President and Mrs. Reagan. This is Paul Murphy saying, Be5 1 2 1 16 7 1241 1306 129 38 96.817238 healthy,5 1 2 1 16 8 1384 1307 37 30 96.988487 be5 1 2 1 16 9 1434 1307 107 39 96.758392 happy,5 1 2 1 16 10 1556 1309 57 29 96.410271 ands 1 2 1 16 11 1626 1310 68 29 96.410271 God5 1 2 1 16 12 1706 1310 81 30 94.349899 bless5 1 2 1 16 13 1800 1311 88 38 96.976410 you.”2 1 3 0 0 0 1021 1401 507 134 -1 3 1 3 1 0 0 1021 1401 507 134 -1 4 1 3 1 1 0 1021 1401 507 39 -1 5 1 3 1 1 1 1021 1401 132 29 96.828300 Norman5 1 3 1 1 2 1165 1401 156 39 95.930305 Errington5 1 3 1 1 3 1334 1404 194 30 96.743935 Productions4 1 3 1 2 0 1233 1450 74 30 -1 5 1 3 1 2 1 1233 1450 74 30 96.760559 19884 1 3 1 3 0 1106 1497 332 38 -1 5 1 3 1 3 1 1106 1497 49 29 95.540909 All5 1 3 1 3 2 1169 1497 105 38 96.186539 Rights5 1 3 1 3 3 1288 1499 150 31 96.728638 Reserved2 1 4 0 0 0 1173 1643 193 133 -1 3 1 4 1 0 0 1173 1643 193 133 -1 4 1 4 1 1 0 1197 1643 146 37 -1 5 1 4 1 1 1 1197 1643 146 37 96.567535 Ordering4 1 4 1 2 0 1173 1689 193 32 -1 5 1 4 1 2 1 1173 1689 193 32 96.484032 Information4 1 4 1 3 0 1193 1739 151 37 -1 5 1 4 1 3 1 1193 1739 151 37 96.691124 Repeated Complaint 6 F.T.C.

EXHIBIT B AUDIO TEXT VIDEO STATEMENTS UNIDENTIFIED VOICE: Insider One Safety Tower. Runway three five right cleared for takeoff.

PILOT: Insider One, Roger UNIDENTIFIED VOICE: TV Insiders with Investigator Vince Inneo. VIDEO: TV Insiders, with Investigator Vince Inneo MR. INNEO: Hello. I’m Vince Inneo, your inside information investigator. Welcome to this very special edition of TV Insiders. No matter what walk of life or what the subject, it’s no secret that having inside information keeps you steps ahead of the others. That's why we're here. This installment is critically important. Many of you have written possibly the most valuable inside information we have yet uncovered. Here are some of the hundreds of letters asking us or telling us about a 73-year-old Phoenix, Arizona man who many of you have claimed has rediscovered nature’s formula for youth. Listen to some of these amazing stories.

VIDEO: From D.A.L.’s Letter MALE SPEAKER: I had arthritis in a very painful state in my left foot to the extent that I was limping quite noticeably. Now the arthritic pain has vanished completely, I am now able to walk normally.

VIDEO: Pat Patten, Homemaker FEMALE VOICE: I’ve been using it about a year now. I had dry patches on my face. They are gone. My energy level has increased. I feel great all over. Even my fingernails have grown. It's been a godsend. VIDEO: From Dr. F.M.’s Letter MALE SPEAKER: It helped me a lot. I’m telling the patients that are interested in their health. Keep up the good work. MR. INNEO: These are only a sampling of the letters from people around the world who want to share this information.

Here is one from Mr. Magnus Bjornsen in Iceland. He writes that his health had deteriorated to being confined 24 hours a day to a wheelchair. However, CC POLLEN COMPANY, ET AL. 223 206 Complaint today he has regained his health, has left the wheelchair behind, exercises and works a ten-hour day and he is 70 years old. Mrs. Ragner Breeford of Norway writes of how she suffered ten to twelve days every month with PMS. She would be bedridden for several days at a time. Now she is free of pain for the first time in her adult life. Some have written books. Noel Johnson’s autobiography tells us that at the age of 70 he was about to be committed to a nursing home because he could no longer care for himself. But something happened. Eighteen years later at the age of 88 he is now participating in the 26-mile New York Marathon and leads a healthy, happy and more vital life.

Look at these letters from advocates the world over who are sharing this discovery, hundreds of them, all of them documented and some quoted in this book Thes 1 2 3 3 3 813 1181 125 30 95.574165 World's5 1 2 3 3 4 952 1181 79 39 96.119118 Only5 1 2 3 3 5 1043 1182 114 30 96.893555 Perfect5 1 2 3 3 6 1168 1184 110 29 93.157478 Food. But this is the most exciting, a copy of December's Parade Magazine. President Ronald Reagan was asked how he keeps so youthful and why he doesn’t have gray hair. The President said his secret comes from something he obtains in Phoenix, Arizona.

President Reagan is the only president I can remember who looks as good, if not better, after eight years as President of the United States in what many claim to be the world's toughest job.

Think about this for a second. Presidents Johnson, Nixon, Ford and Carter all seem to have aged after only four years in the White House. Stay with me as we fly to Phoenix to meet this mysterious man and uncover the Reagan secret.

But first, let me share with you this interview I had earlier with Miss Carol Brown. Miss Brown was the liaison in the Reagan White House. MR. INNEO: Hi, Carol. I’m Vince Inneo from TV Insiders. MS. BROWN: Hi, Vince. It's nice to meet you. Have a seat. VIDEO: Carol Brown Liaison MR. INNEO: Thank you. We have letters from people all over the world telling us that former President Reagan and Mrs. Reagan know about something that reportedly makes people live longer and healthier lives. As liaison to the White House in this area, do you know about this and are you able to talk about it? MS. BROWN: Yes. I’ll be happy to tell you anything you need to know. MR. INNEO: Is it true then? Is there really something to all this? MS. BROWN: It's absolutely true.

MR. INNEO: And former President Ronald Reagan and Mrs. Reagan are ardent advocates? MS. BROWN: That's also true. I have a letter here from Mrs. Reagan and her picture. She's a wonderful lady.

Complaint 116 F.T.C.

MR. INNEO: Okay. Carol, what is it? What is the Reagan secret? MS. BROWN: It's bee pollen much of which comes from mountainous areas. MR. INNEO: Bee pollen will really do all this for you? MS. BROWN: That and more.

MR. INNEO: Now, you say mountainous areas of the world. Does this really make a difference? MS. BROWN: Oh yes. Bee pollen from high altitudes is much richer there and more potent. Just ask Dr. Gary Null. He knows everything bee pollen can do for you.

MR. INNEO: Who else knows about this secret? MS. BROWN: The Queen of England and the Royal Family have been consuming bee pollen products for generations. In a recent January article they reported about Lady Di's consumption of royal jelly. MR. INNEO: Can I walk into any health food store and purchase Mountain- High Bee Pollen? MS. BROWN: Mountain-High Bee Pollen is rather an exclusive item and you must contact the maker directly.

MR. INNEO: Well, thank you, Carol. This inside information has really been of tremendous help to us. I appreciate the time that you spent with us. MS. BROWN: Thank you. It's been my pleasure. MR. INNEO: Now you know why we're going to Phoenix. Mountain-High Bee Pollen. Listen to what health and nutritional expert Dr. Gary Null has to say about it.

In the last 20 years Gary Null has written not less than 51 books, three of which are presently on the best seller's list. He is a research scientist in the field of nutrition and publishes the Natural Living Newsletter. He’s a world class lecturer at colleges and universities. He has appeared on such shows as the Phil Donahue Show, the Tonight and Today shows and has his own radio and TV shows. He is also a health food columnist for national publications. Materials from his investigations have been used by 20/20 and 60 Minutes. Gary Null knows his stuff. He practices what he preaches. Via satellite this is my Insider interview with Dr. Gary Null.

Gary, this is Vince Inneo with TV Insiders. Thank you for giving us the opportunity to talk to you.

Dr. Gary Null, Nutritionist, Scientist, Author MR. GARY NULL: Thank you very much for inviting me. I'm happy to share any information on bee pollen that might help the people in the audience. What questions do you have? MR. INNEO: To be very honest with you, Gary until the Insider team received so many letters about Mountain-High Bee Pollen’s Company, I’d never heard of it. My question is why? If Mountain-High Bee Pollen is supposed to be so good for you, why haven't we heard more about it? CC POLLEN COMPANY, ET AL. 225 206 Complaint MR. NULL: The reason that we haven’t heard more about bee pollen is that we have taken a pharmaceutical look at disease, we haven’t emphasized wellness, and it's only now that we're beginning to examine the role of vitamins and minerals, Vitamin C and Vitamin E and B-6 and even some of the exotic nutrients like Co-enzyme Q-10, Germanium and Carnitine for our good health. Well, if there is not a way of profiting by exclusively being able to patent a product and market it under your own brand name, then why promote it? You don't want something that everyone can find that's inexpensive - bee pollen’s inexpensive, royal jelly's inexpensive - that's readily available, but also there's not a supply enough for everyone. That's why the pharmaceutical industry has not Jumped on the bandwagon. With a drug you can take even an herb, and you can make a chemical extract. And ah! Here's something you should know. This substantiates bee pollen's importance. Time and again they've tried to chemically in a laboratory duplicate bee pollen and royal jelly, and they have failed every . time. They can’t get the same results, which is telling us that nature provided the bee pollen and royal jelly with some intrinsic factor, some mysterious factor, that science cannot duplicate. And that’s why it's so perfect. But again you don’t have enough bee pollen and you don’t have enough royal jelly to feed everyone who can benefit from it. So it’s kind of an Insider's health secret.

MR. INNEO: What exactly is bee pollen? MR. NULL: Bee pollen is one of the most perfect foods ever found in nature. In fact, it's probably the most concentrated in enzymes. You see, our body functions because of enzymes. You age because you don't produce éenough enzymes. So one way to slow down the aging process is to have more enzymerich foods. That's why fresh juices and raw foods are better than over-processed and cooked foods.

Well, you can't get any better food than bee pollen because it's not cooked, it's not processed. It is loaded with vitamins, minerals, enzymes. In fact, there's one nutrient that it has that can help the inside of your body prevent the capillaries from aging.

Did you ever notice when you hit at yourself, you’ll bruise? Well it could be a deficiency of bioflavinoids, and one way of getting bioflavinoids is through bee pollen because you're getting rutin.

Rutin has been shown to help the fragilities capillaries. Therefore, you don't get those little splotches on the legs and wherever you might bruise. So it's antiaging.

Now, the bees go out, they collect from these beautiful flowers, they collect the pollen. They bring the pollen back, and‘60 percent to 70 percent is kept for the person collecting it and 30 percent is allowed to remain with the bees because that’s what they eat. Because after all, as good as it is for humans. It's the life thread for the bees, and that's what we benefit from. Complaint 116 F.T.C.

MR. INNEO: TV Insiders’ investigation team has seen letters from people throughout the world claiming they not only look and feel younger, but their friends and family have noticed changes. Is it reasonable for people to really expect to live longer and healthier lives by adding Mountain-High Bee Pollen to their daily regimen? MR. NULL: I think it's entirely reasonable. Gloria Swanson, the famous actress who’s a very good friend of mine, she looked magnificent with no facelifts. Her skin, if you saw her up close, her hands and her face were very very smooth, almost like a baby's. She had bee pollen and royal jelly twice a day, and she would rely and say, .

Gary, this is part of my secret. It wasn't the only thing, but it was a primary part.

And throughout centuries people who have lived around bee hives or who have been the aviary keepers. People who have formed bees, these are the people who have had really long, vital lives and have looked better. And Loni Anderson commented in an article that one of the reasons she keeps her health, along with a good diet and the exercise, is she includes bee pollen. MR. INNEO: Okay. Let me put it to you directly. I start using Mountain- High Bee Pollen today, what can I look forward to? What can I honestly expect? MR. NULL: I think reasonably we could expect to enhance our overall wellbeing. It’s not always easy to measure because some of the changes are subtle. For instance, when you’re ten years older and you've been eating right and you've been exercising and you’ ve been taking in bee pollen or royal jelly and you don’t look the same age as your contemporaries, when you don’t feel the same way, when you have boundless energy, when you don’t go through those up-anddowns, as peaks and valleys that you normally would, when instead of needing a cup of coffee, you have sustained energy, when your sex life is improved, do you ascribe that just to bee pollen? Well, you can ascribe some of it possibly to bee pollen. It certainly will do two things. It will certainly enhance our overall well-being because we are what we eat, we're what we breathe, we're what we drink and we're what we think. Positive living, positive diet and a positive amount of bee pollen, I feel, enhances the total quality of life.

MR. INNEO: The Insiders’ message is becoming clear. If you do nothing else, if you can’t or won’t exercise, if you’re interested in your well-being but you're not willing to jump on the health food mega-vitamin bandwagon, if you're concerned about the side effects of adding unnatural, manufactured or artificial vitamins or chemical supplements to your diet, if you, like the other people we’ ve heard from and spoken to, want to live longer, healthier and happier lives, if you want that second chance at life, there is something you can do. I’.1] be right back after this message.

CC POLLEN COMPANY, ET AL. 227 206 Complaint (VIDEO: 1-800-553-5500 Mountain High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full 30 day supply of...) UNIDENTIFIED SPEAKER: Mountain-High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full 30-day supply of Mountain-High Bee-Young Wafers. Stay young and alert throughout your life. Pollenergy 520 capsules restore that missing energy and 24hour Royal Jelly tablets to keep sexually active at any age. (VIDEO: 1-800-553-5500 with depictions of three bottles labeled inter alia Bee Young, Pollenergy 520, Royal Jelly.) Also receive as our gift a President's and a First Lady's lunch bar. To start feeling young, energetic and vital again, simply take one Bee- Young Wafer and one Pollenergy 520 capsule with each meal. Take one Royal Jelly capsule before bedtime. Unlock nutrient shortages in your body and reawaken parts of your system long neglected.

(VIDEO: Depicting Presidents and First Lady lunch bars and “1-800-553-5500" followed by depiction of three product bottles with ordering information.) By special arrangements with the producers of TV Insiders, you will receive this 62.35 value for only 39.95 plus 3.50 postage and special handling. Have your credit card handy and call now 1-800-553-5500. 1-800-553-5500. That's 1-800-553-5500. Call now.

MR. INNEO: Welcome back to TV Insiders and our conversation with Dr. Gary Null.

Gary, is Mountain-High Bee Pollen a drug, and are there any side effects to worry about? MR. NULL: Oh, absolutely not. Bee pollen is not a drug. It’s 100 percent natural. It’s organic. It's loaded with good nutrition. The only side effect of eating bee pollen is improved well-being.

MR. INNEO: Can you cite specific medical or scientific studies which are proof positive that Mountain-High Bee Pollen leads to a longer, healthier life? MR. NULL: There have been a lot of medical studies and scientific studies on the benefit of bee pollen and especially when it comes to the aging. DR. GARY NULL Nutritionist, Scientist, Author: One of the men who first studied bee pollen was a man named Dr. Price. And Dr. Price studied a group of people called the Hunzacotts. The Hunzacotts lived in an area called Hunza. Now, if you remember Hilton's movie, Lost Horizons, the movie with Ronald Colbin [sic], well, that Shangri-la was actually a real place. It was called Hunza. Complaint 116 F.T.C.

Now, that doesn’t mean everything that was in the movie actually happened, but it was based upon a real people and that people still exist today. There's some 70,000 who live at an altitude of 10,000 feet in that area of the world, and they have as a part of their diet, and I know because I’ve interviewed the Mir, the ruler's family Said Khan, and he told me about what they eat, and they eat almost everyday bee pollen and royal jelly.

So there you had a whole culture that benefitted over the centuries, the last 2,000 years, from eating this.

MR. INNEO: With all due respect, isn't there an age level where sexual dysfunction is automatic no matter what you do? MR. NULL: There is no age to where the sexual apparatus diminishes or dies. MR. INNEO: Our inside information shows that some bee pollen to be better than others. Can Mountain-High Bee Pollen make this claim? Is it really the best? MR. NULL: Not all bee pollen is the same; please keep that in mind. Much of the pollen in the United States is from the Florida and Texas area, and California where a lot of pesticides can be used and pesticides can get on the bee pollen.

The best bee pollen comes from your mountainous areas, the mountains of Arizona, the mountains of Wisconsin, of the high area of Indiana, where you have very little pesticides or none at all. In fact, in some of the states they've forbidden pesticides because of the dairy lobby, which is good, and so you want that. Also the bees are heartier at a higher altitude.

MR. INNEO: So you were saying that bee pollen from mountains is the best? MR. NULL: The mountainous area is the best MR. INNEO: Why would you recommend that people use Mountain-High Bee Pollen over other nutritional supplements? MR. NULL: Because you're starting off with the best. You're starting off with the most potent, the most balanced, the most whole food that we could take in as a nutritional supplement, and then all the other changes you make in addition to that are only going to enhance your total well-being. MR. INNEO: Gary, sum up the Insider Information for us. MR. NULL: There is something to this that the American public is not aware of that the rest of the world seems to be taking and has been for a long time. We should be ailowed in on this very important nutrient. MR. INNEO: Thank you for being our guest today, Dr. Null. Your inside information has been invaluable.

MR. NULL: Thank you.

MR. INNEO: As I said, Dr. Gary Null is the authority on health and nutrition. He really does know his stuff.

UNIDENTIFIED SPEAKER: Please buckle your seat belt. We are now arriving in Phoenix.

MR. INNEO: Now we’re going to meet who developed Mountain-High Bee Pollen. His name is Mr. Royden Brown.

CC POLLEN COMPANY, ET AL. 229 206 Complaint Mr. Brown.

MR. ROYDEN BROWN: Yes, sir.

MR. INNEO: Hi, Mr. Brown. My name is Vince Inneo with TV Insiders. How are you, sir? MR. BROWN: I'm perfect, thank you, sir. Would you have a chair? MR. INNEO: Thank you. According to what we found out about you, you've really come up with something. Can you tell us when you learned about the effects of Mountain-High Bee Pollen? VIDEO: Royden Brown, Chairman of the Board, C C Pollen Co. MR. BROWN: It was in 1943 in the officers’ mess in London, England. I was a pilot at the RAF at the time. Another pilot gave me an article in some newspaper, and I think it was the London Sunday Times, about bee pollen. It described this miraculous food that it had all the nutrients you needed for perfect health, and it would do everything for you. Well, frankly, I must admit I didn't think any food was that good.

MR. INNEO: Mountain-High Bee Pollen does all that? MR. BROWN: Yes, sir. It’s uh. It’s a marvelous food. If it has all the nutrients, and I know it does, for perfect health, it will do everything for you. It will move you toward perfect health. It's mentioned 68 times in the Bible. It was given to the risen Jesus Christ after the resurrection and that was symbolically, in my opinion, that every person on earth should make bee pollen a staple part of their diet every day of their lives.

MR. INNEO: I understand former President Ronald Reagan is one of your best customers? MR. BROWN: He certainly is. He's been eating bee pollen since 1961, and we've been furnishing the bee pollen since he was governor. He's the best specimen I know of, of what bee pollen does for you. President Reagan has had the toughest job in the world. He's had the most responsibility of anybody in the world. He was shot and near death, and look where he is; he's in perfect health, sharp as a tack. Bee pollen, perfect example of ingesting bee pollen.

MR. INNEO: Why haven't we heard more about, Mountain-High Bee Pollen? MR. BROWN: Because Mountain-High Bee Pollen is a food and not a drug. It can’t be patented. There's not 50 or 100 times markup in the price of it, so the pharmaceutical companies can’t make money on selling bee pollen. That's why we haven’t heard about it.

MR. INNEO: For those people who are allergic to pollen, will they be able to use Mountain-High Bee Pollen? MR. BROWN: Bee pollen according to Leo N. Conroy, M.D. in Denver, Colorado, an allergist, says that bee pollen is the best reliever of allergies that he's ever found. He's had, he had over 60 thousand patients documented and 94 Complaint: 16 F.T.C.

percent of them were completely relieved of the symptoms by ingesting the bee pollen. , MR. INNEO: Never have pollen-related allergies again? MR. BROWN: Never have pollen allergy symptoms again, rest of their lives. MR. INNEO: Mr. Brown, what if someone were taking vitamins, would they have to continue them or will Mountain-High Bee Pollen alone be enough? MR. BROWN: Well, the only problem with the individual taking vitamins, he doesn't know how much Vitamin C to take or how much Vitamin E. If you take bee pollen, it's all in the bee pollen. God made bee pollen the perfect balance of perfect nutrients of all the nutrients, so you don’t need to take vitamins when you take bee pollen.

MR. INNEO: I’ve heard from people that Mountain-High Bee Pollen helps them lose weight. Can you tell me how? MR. BROWN: Well, Mountain-High Bee Pollen has all the nutrients you need for perfect health. So when you eat Mountain-High Bee Pollen before each meal, it satisfies your appetite. As a result, you eat a little less food with each meal you eat and you lose weight constantly as long as you’re eating the Mountain-High Bee Pollen.

MR. INNEO: I have never taken Mountain-High Bee Pollen. Start me off, I mean, what do I get? MR. BROWN: Well, if I were you, I would get three things. First, 1 would get the Bee-Young tablets. Bee-Young tablets will prevent you from losing your memory. You certainly want to have your memory all the rest of your life. Loss of memory is the first step into the nursing home, and you certainly don’t want to do that.

The second thing I would get would be the Mountain-High Royal Jelly. Royal Jelly is the greatest rejuvenating and sex stamina food known to man, and you certainly want to have, be active sexually all the rest of your life. The third thing you want to get is the Pollenergy 520 capsules. The Mountain-High Bee Pollen is the greatest energy source, greatest energy food known to man.

With these three things, I guarantee you that you will have a higher quality of life the last half of your life than you had the first half. MR. INNEO: Thank you, Mr. Brown, I really thank you for giving TV Insiders this inside information not only has it been inspirational to me, but I’m sure motivational not only to myself but to our viewers. Thank you again for all of us.

MR. BROWN: Any time. My pleasure.

MR. INNEO: That was simply amazing. I told you in the beginning that this edition of TV Insiders would be critically important. The message is clear. If you do nothing else, if you can’t or won’t exercise, if you’re interested in your wellbeing but you’re not willing to jump on the health food mega-vitamin bandwagon, if you’re concerned about adding unnatural, manufactured or artificial vitamins or CC POLLEN COMPANY, ET AL. 231 206 Complaint chemical supplements to your diet, if you, like the people we've heard from and talked to today, want to live a longer, healthier and more vital life, if you want that second chance at life, there is something we can do about if after all. (VIDEO: 1-800-553-5500 Mountain High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full 30 day supply of...) UNIDENTIFIED SPEAKER: Mountain-High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full. 30-day supply of Mountain-High Bee-Young Wafers. Stay young and alert throughout your life. Pollenergy 520 capsules restore that missing energy and 24hour Royal Jelly tablets to keep sexually active at any age. (VIDEO: 1-800-553-5500 with depictions of three bottles labeled inter alia Bee Young, Pollenergy 520, Royal Jelly.) Also receive as our gift a President's and a First Lady's lunch bar. To start feeling young, energetic and vital again, simply take one Bee- Young Wafer and one Pollenergy 520 capsule with each meal. Take one Royal Jelly capsule before bedtime. Unlock nutrient shortages in your body and reawaken parts of your system long neglected.

(VIDEO: Depicting Presidents and First Lady lunch bars and “1-800-553-5500 followed by depiction of three product bottles with ordering information.) By special arrangements with the producers of TV Insiders, you will receive this 62.35 value for only 39.95 plus 3.50 postage and special handling.) Have your credit card handy and call now 1-800-553-5500. 1-800-553-5500. That’s 1-800-553-5500. Call now.

VIDEO: From Mrs. V.M.O.’s Letter (VIDEO: 1-800-553-5500) FEMALE SPEAKER: I’ma senior citizen and I thought I felt good, but now _ I feel wonderful. I’m never tired and Mountain-High Bee Pollen is the best money I ever spent.

Complaint {6 F.T.C.

VIDEO: Frits Forrer, Health Insurance Salesman MALE SPEAKER: Every year I used to suffer from ragweed allergies, I tried everything! Nothing worked. I used to hate the fall season. (VIDEO: 1-800-553-5500) Since I’m in health insurance, it really looks bad when I’m sick. Now my allergies disappeared. It's been wonderful and I owe my recovery to bee pollen. VIDEO: Myrna Haag, Tri-Athlete FEMALE SPEAKER: I compete in tri-athlons. I just finished the Hawaiian Tron Man, which is a two-and-a-half-mile ocean swim, 112-mile bike ride and a 26-mile run. I don’t believe in any kind of diets. Diets really don’t work for me. What worked for me was Mountain-High Bee Pollen. It worked great during Iron Man.

VIDEO: From Rev. D.A.L.’s letter MALE SPEAKER: J had arthritis in a very painful state in my left foot to the extent that I was limping quite noticeably. After eating Mountain High-Bee Pollen, the arthritic pain vanished completely. Now I’m able to walk normally. VIDEO: From Dr. F.M.’s letter MALE SPEAKER: Mountain-High Bee Pollen helped me a lot. I'm telling most of the patients that are interested in good health, keep up the good work. (VIDEO: 1-800-553-5500) (VIDEO: 1-800-553-5500) Mountain High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full 30 day supply of...) UNIDENTIFIED SPEAKER: Mountain-High Bee Pollen is available exclusively from the maker. It is not sold in stores. Call now to receive your full 30-day supply of Mountain-High Bee-Young Wafers. Stay young and alert throughout your life. Pollenergy 520 capsules restore that missing energy and 24hour Royal Jelly tablets to keep sexually active at any age. CC POLLEN COMPANY, ET AL. 233 206 Complaint (VIDEO: 1-800-553-5500 with depictions of three bottles labeled inter alia Bee Young, Pollenergy 520, Royal Jelly.) Also receive as our gift a President's and a First Lady's lunch bar. To start feeling young, energetic and vital again, simply take one Bee-Young Wafer and one Pollenergy 520 capsule with each meal. Take one Royal Jelly capsule before bedtime. Unlock nutrient shortages in your body and reawaken parts of your system long neglected.

(VIDEO: Depicting Presidents and first Lady lunch bars and “1-800-553-5500" followed by depiction of three product bottles with ordering information.) By special arrangements with the producers of TV Insiders, you will receive this 62.35 value for only 39.95, plus 3.50 postage and special handling. Have your credit card handy and call now 1-800-553-5500. 1-800-553-5500. That's 1-800-553-5500. Call now.

MR. INNEO: Let me restate something. It's your cards and your letters alerting TV Insiders to new discoveries, interesting people and inside information. We need inside information. You tell me the stories and what you've heard, we will research it, investigate it, and we will share our findings with everyone. If we use your information, we will send you a TV Insider investigator's card. This you can count on. So until next mission, this is your inside investigator, Vince Inneo, wishing you good health and God's blessings. VIDEO- CREDITS on screen- Statement on screen - VIDEO: All materials, whether real or recreated, represent factual events. EXHIBIT C ‘The video tape described in Exhibit B has been placed in the permanent records of the Commission, and is incorporated herein by reference. EXHIBIT D The video tape described in Exhibit A has been placed in the permanent records of the Commission, and is incorporated herein by reference. Ke i > Bee “ee 2 .

ety uD Complaint L16F.T.C.

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0 0 1947 703 5 1611 -1 3 1 44 1 0 0 1947 703 5 1611 -1 4 1 44 1 1 0 1947 703 5 1611 -1 5 1 44 1 1 1 1947 703 5 1611 95.000000 2 1 45 0 0 0 1363 2308 584 7 -1 3 1 45 1 0 0 1363 2308 584 7 -1 4 1 45 1 1 0 1363 2308 584 7 -1 5 1 45 1 1 1 1363 2308 584 7 95.000000 2 1 46 0 0 0 1276 2436 518 69 -1 3 1 46 1 0 0 1276 2436 518 69 -1 4 1 46 1 1 0 1276 2436 518 69 -1 5 1 46 1 1 1 1276 2440 133 63 95.827087 Pages 1 46 1 1 2 1442 2442 24 46 96.794380 15 1 46 1 1 3 1500 2436 54 53 96.714798 of5 1 46 1 1 4 1578 2443 28 46 96.943810 25 1 46 1 1 5 1633 2442 161 63 96.411537 Pages CC POLLEN COMPANY, ET AL. 235 206 Complaint We wrote the beck on pcliien...

AND WE 50 IT RIGHT! Fer ‘Ze anc lar con router anc man in the Unite cannot te ciscuted as i Comeany is the ultima: Dy ane on heneytee ccllen, many wi jelly in any form.

We maintain ne THE STANDARD OF EXCELLENCE Orcs, Ev whicn eit cthers Musi be jucgsc rasults with cova jelly a ne ecole with he pracece. 7 ahe bees 0? Senver, oy iSFin 3¢o yer ercies with See ocilen jeve ecllen immuniz nievec Sy incorscrating celles i sistance ig built cyec bees-sainerec poliens iecations.

“7 2. o SO TN OW “Propolisctheracy in Bronchial Asthma,”

a Rumemian stucy, recerts treating 3¢ patients suftering tromcnial astnmé successfully with a Zropolis compounc whicn provec even mere eftective than conventional tre2iment! If you dent know why these stat make us srcuc - reac on - enc lez Hign-Deser? cuality is se impor i] whe Styl SSF en aah eet you. bet S “Royal Jelly in Oiet, Prophylaxis & Therapy,” H.W. Scmmict, German Mecical Asscecieton. savs. Rovai5 1 28 1 3 4 874 1991 58 24 94.128738 Jelly5 1 28 1 3 5 943 1991 18 20 94.128738 is5 1 28 1 3 6 972 1995 11 16 88.642853 a5 1 28 1 3 7 994 1991 128 23 30.290924 scwerulé4 1 28 1 4 0 675 2019 404 22 -1 5 1 28 1 4 1 675 2019 2 3 73.149399 i5 1 28 1 4 2 734 2020 117 20 77.806122 evitalizes5 1 28 1 4 3 868 2022 38 19 74.232071 ines 1 28 1 4 4 920 2021 99 20 40.304161 functions 1 28 1 4 5 1033 2022 46 19 6.057190 cic4 1 28 1 5 0 862 2051 262 21 -1 5 1 28 1 5 1 862 2055 43 17 29.885551 cs. the maetaoclism, siced circulation and the interpiay cf al! factors preserving life anc sirengin in the organism. It delays the aging crocess anc retains fer as !cne as possicie tne ycuiniul freshness of Decy, elasticity of the mine and psycnic bucyancy.”

onoefly arc $ atis sroviced ‘er ecucat yen not scic with any seenive product.

This pam metro Se 3:

£1923 C C Pollen Company Proanmx, Arizona a$018 Page 2 of 2 Pages Ate mga es WANT TO KNOW MORE? Ask your retailer for your tree copy ef tne Scientific Stucy on pollen, “The World's Only Pertect Food", or write C Pollen Co.. 7960 E. Camelback, Scottsdale, AZ 5251 EXTRA-WHICH FoTENCY .

SB’ 2rod:

we Degart’ Rese sce2 st AVAILABLE FROM:

rlONEYBEE PoflenS~ CANDY A delicious and nutritious confection c T Mix thoroughly by hand and enjoy your fi an be made from fresh Pollens™.

my this on the kids after school! Put 4 oz. Fresh Pollens™ ina mixing bowl.

Stir in 2 Tablespoons powdered carob (natural chocolate) dissolved in:

2 Tablespoons water Mix in 3 Tablespoons raw honey Add 4 oz. crunchy natural peanut butter rst taste of Mother Nature's Perfect Candy! ©1981 C C Pollen Company Scottsdale, Arizona = rogue Complaint 116 F.T.C.

EXHIBIT F (THE PERFECT FOOD FOR TR Extra-High Potency”

High Desert* Honeybee Pollens~ Page 1 of 2 Pages a o CC POLLEN COMPANY, ET AL. 237 . Cemplate Nutriticn — Honeybee poilen gives ycu all the essential nutrients — ail vitamins, minerals, enzymes anc trace elements to feed every hungry cell alt over your body.

. Guiek Energy — Honeybee pollen gives you the quick extra energy of sugar and caffeine, naturally — without undesirable elements.

. Increased Strencin — The British Sperts Council has recorded increases in strength up to 25% with poilen power, Unbelievably, the British Royal Society has reported height increases in adults who take pollen! . Better Fearlormanc? — Harry McCarthy in his latest book states, “Pollen contains ingredients which boost an athlete's performance further — and much more safely ~ than any “peo pill" in existence.

Sport sucerstars in particular are using bee pollen.”

. Increased Recovery Powar— A two-year research program conducted at Pratt Institute in NY shows that pollen improves the crucial recovery power of athletes atter stressed performance. Just think what it can do for you daily! . Weight Control — “Honeybee pollen is the greatest body-builder on earth, contributing not one ounce to obesity or excess fat on the bocy. Honeybee pollen should be the cornerstone for every weight-loss diet.” in the words of Francis Huber, German naturalist.

to Lower Pulse Rate — Honeybee pollen lowers tne pulse rate naturally while permitting an increase in strength anc endurance.

Reponed by Alex Wecd!y, Heac Coach, Education Athletic Cius, Philacelphia.

. INeresaseas Red Slee Cahs — Studies show that honeybee pollen increases the vital oxygen-carrying red blood cells up to 25%! You feel better when your circulation is better! The Sewer si Slersics — Honeybee pollen power out pertorms harmful steroids, without chemical side effects. Except ‘or the one sideeffect thatno one complains about...

2as20 Sexual Siemins & nce ~ Soma Health magazine. July/August 1980 issue.

reports that honeybee pollen contains natural hormonal substances which stimulate & nourish the reproductive systems of both men and women with a direct impact on sexual ability.

“Long lives are attainec by See ccilen users: it is one of the original treasure houses of nutrition and mecicine, 23ch grain contains avery imecrant sues.ance ‘hat is Necessary to fife.” says Dr. N.P. Joirich, Chief U.S.S.R. Scientist at the Soviet Academy.

Page 2 of 2 Pages Decision and Order 116 F.T.C.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents been furnished thereafter with a copy of a draft of complaint which the Regional Office proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondents with violation of the Federal Trade Commission Act; and The respondents, their attorney, and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondents of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondents that the law has been violated as alleged in such complaint, and waivers and other provisions as required by the Commission’s Rules; and The Commission having thereafter considered the matter and having determined that it had reason to believe that the respondents have violated the said Act, and that complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public. record for a period of sixty (60) days, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings, and enters the following order: 1. Respondent CC Pollen Company is a corporation organized, existing and doing business under and by virtue of the laws of the State of Arizona, with its office or principal place of business located at 3627 East Indian School Road, Suite 209, Phoenix, Arizona.

Respondents Bruce R. Brown, Carol M. Brown, and Royden Brown are officers and/or directors of the corporate respondent named herein. They formulate, direct and control the acts and practices of said corporate respondent, including the acts and CC POLLEN COMPANY, ET AL. 239 206 Decision and Order practices hereinafter set forth. Their addresses are the same as that of the corporation.

2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

ORDER The following definition shall apply throughout this order: Bee pollen product means any product(s) intended for human consumption or use consisting in whole or in part of bee pollen, bee propolis, and/or royal jelly in any form.

1.

It is ordered, That respondents CC Pollen Company, a corporation, and Bruce R. Brown, Carol M. Brown, and Royden Brown, individually and as officers of said corporation, their successors and assigns, and their officers, agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device in connection with the advertising, packaging, labeling, promotion, offering for sale, sale or distribution of any product or service in or affecting commerce, as “commerce” is defined in the Federal Trade Commission Act, do forthwith cease and desist from creating, producing, selling or disseminating:

(A) Any advertisement that misrepresents, directly or by implication, it is not.a paid advertisement; and (B) Any commercial or other video advertisement fifteen (15) minutes length or longer, or intended to fill a broadcasting or cable casting time slot of fifteen (15) minutes in length or longer, that does not display visually, in a clear and prominent manner and for a ~ length of time sufficient for an ordinary consumer to read, within the first thirty (30) seconds of the commercial and immediately before Decision and Order H6E.T.C.

each presentation of ordering instructions for product or service, the following disclosure:

THE PROGRAM YOU ARE WATCHING _IS A PAID ADVERTISEMENT FOR [THE PRODUCT OR SERVICE].

Provided that, for the purposes of this provision, the oral or visual presentation of a telephone number or address for to contact to place an order for the product or service shall be deemed a presentation of ordering instructions so as to require the display of the disclosure provided herein.

Provided further that should the Federal Trade Commission adopt a trade regulation rule requiring different disclosures or a different frequency of making such disclosures than that required by subpart 1(B), above, compliance with such trade regulation rule shall be deemed compliance with subpart 1(B). II.

It is further ordered, That respondents CC Pollen Company, a corporation, and Bruce R. Brown, Carol M. Brown, and Royden Brown, individually and as officers of said corporation, their successors and assigns, and their officers, agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of any bee pollen product in or affecting commerce, as “commerce” is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, directly or by implication, that: (A) Consumption of any bee pollen product cannot or will not result in an allergic reaction;

(B) Consumption of any bee pollen product will permanently alleviate all pollen allergy symptoms;

CC POLLEN COMPANY, ET AL. 24] 206 Decision and Order (C) Consumption of any bee pollen product slows or prevents or the aging process;

(D) Consumption of any bee pollen product can cure, or prevent, or alleviate impotence and/or sexual dysfunction; (E) Consumption of any bee pollen product can cause weight loss;

(F) Any bee pollen product is an effective antibiotic for human use.

Provided, however, that use of any statement approved by the United States Food and Drug Administration (“FDA”) for inclusion on the label of the product will be deemed not to violate this part when its use is consistent with the FDA approval. II.

It is further ordered, That respondents CC Pollen Company, a corporation, and Bruce R. Brown, Carol M. Brown, and Royden Brown, individually and as officers of said corporation, their successors and assigns, and their officers, agents, representatives and employees, directly or through any partnership, corporation, subsidiary, division or other device, in connection with the advertising, offering for sale, sale or distribution of any product or service for human consumption or use, in or affecting commerce, as “commerce” is defined in the Federal Trade Commission Act, do forthwith cease and desist from representing, directly or by implication, that any such product or service will have any effect on the user’s health or physical condition unless, at the time of making such representation, respondents possess and rely upon competent and reliable scientific evidence that substantiates the representation. For purposes of this order, “competent and reliable scientific evidence” shall mean tests, analyses, research, studies or other evidence based on the expertise of professionals in the relevant area that have been conducted and evaluated in an objective manner by persons qualified to do so, using procedures generally accepted by others in the profession to yield accurate and reliable results. Decision and Order 116 F.T.C.

IV.

It is further ordered, That respondents, their successors and assigns, shall pay two hundred thousand dollars ($200,000) to the United States Treasury as disgorgement. Such payment shall be by two cashier’s checks or certified checks made payable to the Treasurer of the United States, the first such check, in the amount of one hundred thousand dollars ($100,000), to be tendered within five (5) days of the date of service of this order, and the second, also in the amount of one hundred thousand dollars ($100,000), to be tendered no later than one year to the day after this agreement becomes final. Respondents shall provide security for the second payment in a manner agreed to by the parties before provisional acceptance of this order by the Federal Trade Commission. In the event of any default in payment, which default continues for more than ten (10) days beyond the due date of payment, respondents shall also pay interest as computed under 28 U.S.C. 1961, which shall accrue on the unpaid balance from the date of default until the date the balance is fully paid.

V.

It is further ordered, That for a period of three (3) years from the date that a representation last covered by this order is last disseminated, respondents shall maintain and upon request make available to the Federal Trade Commission for inspection and copying:

(A) All materials that were relied upon by respondents in disseminating any representation covered by this order; and (B) All reports, tests, studies, surveys, demonstrations or other evidence in any respondent’s possession or control that contradict, qualify or call into question such representation or the basis upon which respondents relied for such representation, including complaints from consumers.

CC POLLEN COMPANY, ET AL. 243 206 Decision and Order VI.

It is further ordered, That respondent CC Pollen Company shall: (A) Within thirty (30) days after service of this order, provide a copy of this order to each of the respondent’s current principals, officers, directors and managers, and provide a complete copy of parts I through III of this order to all personnel, agents and representatives having advertising or policy responsibility with respect to the subject matter of this order, and to each employee of CC Pollen Company who is engaged in the sale of CC Pollen products; and (B) For a period of seven (7) years from the date of entry of this order, provide a copy of this order to each of the respondent’s principals, officers, directors and managers, and provide a complete copy of parts I through III of this order to all personnel, agents and representatives having advertising or policy responsibility with respect to the subject matter of this order, and to each employee of CC Pollen Company who is engaged in the sale of CC Pollen products, within three (3) days after the person assumes his or her position.

VIL.

It is further ordered, That respondent CC Pollen Company shall notify the Commission at least thirty (30) days prior to the effective date of any proposed change in the corporate respondent such as dissolution, assignment or sale resulting in the emergence of a successor corporation, the creation or dissolution of subsidiaries, or any other change in the corporation which may affect compliance obligations arising out of this order.

VI.

It is further ordered, That respondents Bruce R. Brown, Carol M. Brown, and Royden Brown shall, for a period of seven (7) years from the date of entry of this order, notify the Federal Trade . Decision and Order 16 E.T.C.

Commission within thirty (30) days of the discontinuance of his or her present business or employment and of his or her affiliation with any new business or employment. Each notice of affiliation with any new business or employment shall include the respondent’s new business address and telephone number, current home address, and a statement describing the nature of the business or employment and his or her duties and responsibilities.

IX.

It is further ordered, That respondents shall, for at least three (3) years after service of this order, maintain and make available to the Federal Trade Commission upon request, for inspection and copying, complete records regarding respondents’ compliance with this order, X.

It is further ordered, That respondents shall, within sixty (60) days after service of this order, and such other times as the Federal Trade Commission may require, file with the Commission a report, in writing, setting forth in detail the manner and form in which they have complied with this order.

VALUE RENT-A-CAR, INC. 245 245 Complaint